ML20247H126

Incomplete Nine Mile Point 1 Verification Rept

ML20247H126
Person / Time
Site:	Nine Mile Point
Issue date:	02/28/1986
From:	GAGE-BABCOCK ASSOCIATES, INC.
To:
Shared Package
ML20247H124	List: IA-89-221, Final Response to FOIA Request for Records.App a & B Records Available in Pdr.App B Records Encl.App C Records Withheld in Entirety (Ref FOIA Exemption 5) ML20247H118 ML20247H126
References
FOIA-89-221 NUDOCS 8907280289
Download: ML20247H126 (130)

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faCPA GAGE-BABCOCK & ASSOCIATES, INC.

February, 1986  !

File No. 8493

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NINE MILE POINT 1 f VERIFICATION REPORT -

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prepared for Niagara Mohawk Power Corp.

300 Erie Blvd. West Syracuse, New York 13202 prepared by Gage-Babcock & Associates, Inc.

105 Kisco Avenue Mt. Kisco, New York 10549

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TABLE OF CONTENTS ff l

EXECUTIVE

SUMMARY

1 Scope of Work 1 3 )

SUMMARY

OF GENERIC PROBLEMS 4 l Fire Doors 4 i Transient Fire Loads 4 Penetration Seals 5 Fire Alarm System 6

PROTECTION CRITERIA - MAJOR COMMITMENTS 7

1. . Fixed Fire Suppression Systems 9

2. Fire Alarm System l 12

3. Penetration Seals 13

4. Fire Doors 13 4

5. Fire and Heat Barriers 13 )

6. Cable Tray Fire Stops 14 Smoke Removal Systems ]

7. 14 j

8. Flame Retardant Materials - Cable Trays and Electric Panels 14

9. Emergency Shutdown Panel 15

10. Emergency Lighting .

16 MAJOR VERIFICATION ITEMS 17 {

1. Fixed Fire Suppression Systems 19

2. Fire Alarm System 21

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l 3. Penetration Seals V-1 VERIFICATION OF COMMITMENTS

• G-1 thru G-10

1. General R-1 thru R-43

2. Reactor Building

3. Control Building C-1 thru C-27

4. Diesel Generator Building D-1 thru D-34 r Turbine Building T-1 thru T-102

5. S-1 thru S-4

6. Screen and Pump House

7. Waste Building JK-lrp,ru W-28 l

Off-Gas Building OG-1 thru OG-5

8. AE-1 thru AE-12

9. Administration Building  ;-l thru T-3

10. Yard Area ACG-1 thru ACG-4

11. Administration & Controls General l SE-1 STRUCTURAL ENGINEERING REVIEW (Mcdonald & van der Poll) SE-4 1.0 Background SE-5 2.0 Scope of Structural Review SE-6 3.0 Stair Enclosures .

l 4,0 Sprinkler Systems, Seismic Pipe Retraints SE-{2 S --

5.0 Summary SE-2f ,

6.0 References i

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\lc APPENDIX .

A. Comparison of U.L. Tested Penetration A-1 thru 7 Seals and Seals on Design Drawings -

B. Survey of Cable Tray Penetration. Seals B-1 thru 53 C. Survey of Selected Penetration Seals C-1 thru 29 D. Smoke Removal System .

D-l'thru 8 E. Survey of Conduit Penetration Seals E-1 thru 4 F. Review of Surveillance Reports for Halon Systems. F-1 thru 7 G. Review of Surveillance Reports for CO2 Systems G-1 thru 21 H. Review of- Surveillance Reports for Fixed Fire H-1 thru 18 Suppression System I., Installation and Surveillance of Penetration Seals I-l thru,7 J. Survey of Fire Doors J-l thru 4 K.- Verification Action Sheets K-1 thru 22:

L. Review of Surveillance Reports for Fire Alarm L-1 thru 14 Systems.

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NI AGARA MOHAWK POWER COR P.

EXECUTIVE

SUMMARY

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Scope of Work l

Gage-Babcock and Associates was retained under Contract (609019 by Niagara Mohawk Corp. to perform a verification and fire hazard analysis survey of.Nine Mile Point Unit 1 Nuclear Power Station in Lycoming, New York.

" The verification survey was conducted using the Fire Protection SER dated July 26, 1979 as the base line document for Fire Protection improvement commitments to the Nuclear Regulatory Commission (NRC). Each commitment was listed and drawings and '

documentation were reviewed to assure modifications made were  ;

appropriate to the NRC concern. The drawings showing the i l modification were taken to the plant and compared with the installation; any deviations from the drawings were noted.

Technical Specifications, Administrative Procedures and Admin- )

istrative Controls (Fire Brigade) were reviewed with comments nade on any discrepancies noted.

A survey was conducted to obtain information on fire loading, fire zones, fixed fire protection systems, location of safety f, related equipment and electrical cables. This information was assimilated into a separate updated Fire Hazard Analysis.

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The work did not include review of Safe Shutdown nor review of compliance with " Guidelines for Fire Protection for Nuclear Power Plants" Appendix A to BTP APCB 9.5.1. Additional work vas added to the scope with the review of fire protection improvements f or Appendix R. The review was to determine compliance with drawings, applicable codes and good practices but no determination was made as to the adequacy of improve-ments to meet Appendix R Criteria.

The following is the written scope to which the surveys were conducted.

A. Verify that NMP-1 has met all commitments contained within Fire Protection Program submittal of 2/28/77 and NRC Safety l Evaluation report dated 7/26/79 including subsequent corres-pondence af fecting these commitments.

1. Determine and list all commitments. Review the Fire Protection Program, the SER and the subsequent corres-ponde nce .

2. Evaluate adequacy of design records. For each commit-ment requiring the installation of protection features, ascertain that plans were prepared and that required

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'$. engineering calculations were . performed andfare on Check the calculations for appropriate design

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criteria'and for correctness.

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3. Review as-built drawings- to determine that' all design commitments are incorporated.

4. Field verify as-built drawings. - Ascertain that the fea-tures shown in the as-built drawings are actually in place as shown in the - drawings. No ' destructive demoli-tion was done 'to verify concealed correction action. l S. Determine adequacy of " pre-op" test where required.  ;

Where new fire protection' systems' have been installed,.

j ascertain that " acceptance tests" were conducted i according to manufacturer's recommendations or National Fire Protection Association (NFPA)' standards, whichever o is more. demanding.

6. Evaluate implementation of- current surveillance program.

Ascertain that a schedule of inspection and testing has been- implemented as recommended by equipment manuf acturer i or NF PA , whichever is'more demanding.

7. Raview fire protection administrative controls, func-(i tional responsibilities and' QA ef festiveness.

8. Develop Verification Action sheets for~ any, problems or discrepancies noted during survey. Niagara Mohawk reviewed sheets and determined necessary corrective action. See Appendix K.

All problems identified during this verification effort .were  !

transmitted to NMPC on the verification action sheets found in 1 Appendix K. MNPC has provided written comments on all items j for acceptance or correction. 1 l

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SUMMARY

OF GENERIC PROBLEMS

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SUMMARY

OF GENERIC PROBLEMS The following is a summary of generic problems found in various areas of the plant.

Fire Doors A number of " fire door assemblies" have deficiencies which negate their fire rating or lack the proper labeling to deter-mine their fire rating. Some doors and frames in designated .

fire walls labels have dobeen not have the U.L.

modified by thelabels while others installation with the of conduit I

j through door frames, cutting doors in half to make Dutch doors and by the addition of electronic strikes. A number of sliding fire doors are not ' installed correctly and others are not the proper size for the opening being protected. j Maintenance on a number of doors is necessary due to improper-  ;

latching, inoperative door closures, lack of latching mechan-isms, and physical damage to doors.

At various tines during the survey, fire doors were noted blocked open without the proper fire watch. See Appendix J for j

detailed Survey of Fire Doors. I k

l Transient Fire Loads i I

i Considerable designated fortransient storage offire loads are stored combustible in areas not materials.

In areas designated for storage where automatic fire suppression is i i

provided, the material stored extends beyond the sphere of protection.

The improperly stored items include fire retardant wood, crates, mable liquids.

cutting and welding carts, oil drums and flam-Penetration Seals i

The penetration seals on Niagara Hohawk's Drawings C-27101-C i and NiagaraC-27102-C Mohawk. were compared with a U.L. test sponsored by The comparison revealed numerous discrepancies between the drawing the- construction See AppendixofA.theSome seals tested and the seals on of the differences were not significant enough to invalidate the test results; others are sufficiently different that additional testing is warranted.

! Due to the numerous penetration seals, only a random sample of the various types (over thirty) were surveyed. The penetration

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seals for results cable trays recorded in Tech B.

in Appendix Spec walls were all surveyed with The survey results of all but

( cable tray seals are found in' Appendix C. Of the 248 seals surveyed, 73 had problems (29.4%). See Page CIA for summary.

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l A separate survey was conducted for internal conduit penetra-  !

tion seals. Most of the conduit penetrations were found un-  !

sealed. See Appendix E. l l

Fire Alarm System i A number of local fire alarm panels were noted to be in the trouble mode and remained in that condition for extended per-iods of time. The mark-ups on a number of panels dated back to j 1982 and others are months old.

Plant personnel believe that the elevated temperatures in a number of areas cause the local fire alarm panels to go into the trouble mode.

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I INSULATED POWER CABLE ENGINEERING ASSOCIATION I PCEA Pub. No. S-66-524 cross-linked, thermosetting, polyethylene insulated wire and cable. i AMERICAN SOCIETY FOR QUALITY CONTROL ANSI Std. 21.8 General Requirements for a Quality Program i

NRC DOCUMENTS

" Guidelines for Fire Protection for Nuclear Power Plants" Appendix A to BTP APCB 9.5-1 1

3. PENETRATION SEALS The 1979 SER commits NMPC to penetration seals equal to  !

existing fire barriers. NMPC had no rated seals in the l plant prior to writing their FHA and committed to a testing l program to include existing and new penetration seal types.

IEEE Standard 634-1978 " Cable Penetration Fire Stop Quali-fication Test" was to be used as a basis for test proce-dure.

A " Test Plan and Specification for Pipe and Cable Penetra-tion Fire Stop, Qualification Tests for Existing gr Pro-( posed Pipe and Cable Penetration Fire Stop" was developed and carried through. Underwriters' Laboratories, Inc. was hired to construct and test the fire barrier assemblies.

NMPC's Quality Control inspected the U.L. f acility and NMPC personnel witnessed the tests. A letter / internal memo of 3/19/80 discussed the U.L. test program with subsequent letters discussing each of the four tests. It is in these letters that the 6 lb./cu. ft. Kaowool density was first introduced even though on review of the actual test assem-blies it is clear that this level of Kaowool fill was not consistetitly used.

A safety evaluation dated August, 1980 includes details of the U.L. tested floor penetration seals and all were based on 8 cu ./f t . A similar safety evaluation of January, 1981 based the. fill of the wall penetration seals on 6 cu./f t.

Section III discusses the test program in detail.

There are over 30 different types of penetration seals being used in the facility. Drawings C-27101-C and C-27102-C give insta3?ation details of the various floor and wall seals but do not include cable tray type penetrations.

There are both rated and .non-rated penetration seals in the pla nt . Non-rated cable tray seals are discussed under

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" Cable Tray Fire Stops". ,

4. FIRE DOORS The Safety Evaluation Report dated July 29, 1979 required Niagara Mohawk to upgrade the fire ratings of doors and f rames in walls separating fire zones, separating safety related equipment from hazards and fire rated enclosures.

Tha rating of the doors were to be commensurate with the rating of walls in which they were installed. Most of the walls were upgraded to 3 hrs. and the doors installed in these walls were 3 hr. rated fire doors and frames. Door to stairways, battery rooms, seal oil unit are two hour

f. ire rated.

5. FIRE AND HEAT BARRIERS Fire barriers are generally 3-br. fire rated walls with penetrations and doorways protected by fire rated seals and doors. These walls separate the plant into various fire zones. Fire barriers with a 2-hr. fire rating enclose stairways, battery rooms, seal oil unit and lacoratory. j These areas are located within a fire zone and the en-closing walls provide separation of critical equipment,

• enclosure of hazards and safe means of exit or egress to various floors.

Non rated barriers called " Thermal Shields" protect safety related cable trays and equipment from a fire in the Con-denser Bay (261 Level up). These walls are substantial concrete or concrete block with many penetrations not sealed with fire rated assemblies. The doorways to the area have 3-br. rated fire doors and frames but do not have the 4 inch overlap to protect the opening.

Flame shields are provided between redundant safety related equipment containing small quantities of oil or large elec-trical panels. These metal shields are to prevent direct flame impingement from one unit to the next. The shields do not protect the units from a common exposure fire.

6. CABLE TRAY FIRE STOPS Non-rated seals are provided at floors pierced by cable trays or cables. These seals are installed to prevent vertical propagation of flame along the cables.

Fire stops for cable trays in the horizontal are generally not provided. Fixed automatic suppression systems are in-stalled on any stack of trays three or more in height. &

Fire stops have been provided in the Reactor Building W l'.

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f N between the East and West sides where cable trays pass through the " combustible free" zone.

Where cable trays and cables pass through fire rated walls or floors, a rated and non rated assembly consisting of Flamemastic 77 and Kaowool is provided. See Appendix B for analysia. .

7. SMOKE REMOVAL SYSTEMS l The smoke removal system for the control complex and Tur-bine building basement is designed to remove smoke and moderate heat to permit personnel entry, restore visibility a,nd evacuate products of combustion. -

The smoke vent system in the turbine building is intended  !

to remove a major portion of the heat f rom the fire to help l prevent horizontal fire spread, improve conditions for )

manual fire fighting and to remove heat to preserve the unprotected steel roof structure.

The smoke removal system design is based on a minimum of 4 air changes / hour with 6 air changes / hour preferred.

The roof vents in the turbine building are based on one sq. )

- ft. of vent pe r 100 sq . f t . of floor area. This ratio was  !

based on NFPA 204, 1980 criteria for a " Moderate Heat Release Content" Occupancy. See Appendix D. .1

8. FLAME RETARDANT MATERI ALS - CABLE TRAYS AND ELECTRIC, PANELS 1

i Flamemastic has been provided on cables in trays over .

safety related electrical panel boards. The extent of the  !

flame retardant coating beyond the panel boards is depen- l dent on the number and arrangement of cable trays.

The Flamemastic is used in lieu of water suppression sys- j tems in areas with cable trays stacked three or more high.

The electrical panels with cable trays above have the tops sealed with Flamemastic to prevent firefighting water from entering the electrical panels.  ;

9. EMERGENCY SHUTDOWN PANEL Due to the existing arrangement of safety related circuits, the utility was required to provide an emergency shutdown panel independent of the control room and auxiliary cable (j' spreading rooms. Upon further investigation of circuits, saf ety related equipment and fire zones it was determined 1^ .

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that two emergency shutdown panels would be pro'vided.

(') panel is located Column line 16-BE elevation _277 of the One Turbine Building. The second panel is located at. Column i' Line 14A, Elevation 250' of the Turbine Building.

10. EMERGENCY LIGHTING 1

Emergency lighting is provided by the AC lighting system backed-up by diesel generator and station batteries. In means of egress and areas providing access to safety re -

lated equipment, 8-hour rated battery pack lights are pro- <

j vided. Battery packs are also provided in areas uhere saf ety related equipment is actuated, or readings taken. l j

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( 3. PENETRATION SEALS Due to the large number of penetration. seals, all the seals were not surveyed. Approximately ten (10) penetration seals of each . type (not including cable trays) were surveyed at random.

Over thirty (30) dif ferent types of seals are detailed on drawings C27101-C and C-27102-C. These drawings were used as the bases for inspecting the seals. On the following page is a graphic sysnopsis of the survey indicating problems with the penetration seals. Of the 248 seals surveyed, 73 had problems (29.4%). This does not include problems asssociated with con-duit or cable tray seals. For detailed findings of the survey, see Appendix C.

Part *of the verification was to compare the details of the penetration seals on drawings C-27101-C and C-27102-C with a U.L. test, File NC601, Project 79NK8678, November 17, 1980 Report on Floor and Wall Penetration Fire Stops. The test was sponsored by Niagara Mohawk and the purpose of the test was to' determine the adequacy of both existing and future penetration seals. The comparison of the Niagara Mohawk seals and the fire test is detailed in Appendix A. Along with the comparison are comments on the acceptability of the seal if modified from the fire test s pecime n .

A random survey of conduit penetrations was conducted to deter-mine the extent to which they have been sealed. The survey was done regardless of penetration type. Areas surveyed included the wall between the screenhouse and turbine building, and the Turbine Building 261' Elevation floors and walls. The survey indicated that a majority of the conduits are not sealed. For survey results, see Appendix E.

The survey of penetrations included the inspection of all cable tray seals through floors and walls and comparison with the ,

assembly tested in the U.L. penetration test. The assembly i installed at the plant was structurally different from the l assembly tested. Due to this structural difference, a compari- 1 son of seals is difficult and a retest should be investigated. I For comparison and survey results see Appendix B. j i

To determine the adequacy of the existing seals to meet.the i details required to obtain the necessary fire rating, the l installation procedure and Quality Control was investigated. i From the review one cannot be assured that the amount of cera- {

mic blanket or loose fill required by the " Installation De- l tails" were complied with. See Appendix A for the study.  ;

Once the penetration seals have been installed, the seal has to i r be inspected and maintained and if a problem exists a Work s Request has to be generated. The adequacy of the surveillance 21 ,

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is in question in both to the physical inspection and documen-See Appendix I .

E tation.

In summary, the surveys and studies revealed a number of prob-lems from design to verification of installation to inspection after installation. Corrective action is indicated in the various Appendices and should be initiated.

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NMP1 - FIRE PROTECTION VERIFICATION FORMAT DESCRI PTION OF COMMITMENT: Reactor Building - Elevations 237',

) 261', 281', 298', 318'. Fire stops for vertical. cable runs at floor penetrations .

ACTIVIT NO.: None.

REFERENCE:

SER Page 6, pa ra . 3.1.3 ; Pa ge 31, pa ra . 5.1. 2 . 6.

DESIGN REVIEW:

1. Drawing Reviewed - B-39537-C

2. Results - Non fire rated seals of Kaowool and Flamastic are used to prevent vertical propagation of fire.

3. Reviewer: M.A. Antonetti.

FIELD VERIFICATION:

1. Area of Plant Reviewed: Reacto'r Building, Elev. 261'.

2. Date Reviewed: . July 18, 1984.

3. Results - New cables have been added to penetrations and not sealed at the ceiling. Some seals are missing Kaowool.

Some are missing Fire Retardant. Some are missing both. (l)

4. Reviewer - M.A. Antonetti.

PRE-OP TESTING:

1. Testing Required: n/a

2. Test Report:

3. Evaluation:

4. Reviewer: l SURVEILLANCE REQUIREMENTS:

1. Testing and Inspection Requirements:

2. Evaluation:

3. Reviewer:

PROBLEMS - PAE-OP & SURVEILLANCE PROBLEMS - Fire stops improperly sealed af tcr addition of new cables in the following locations:

Elevation 237': Elevation 296':

a. Col. 4 between M & N a. Col. 4 between L & M

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NMP1 - FIRE PROTECTION VERIFICATION FORMAT

b. . Col . PE between 8 & 9 b. Col..4 between M & NL

c. Col PE'between 10 & 11 c. Col. PE between 8 & 9

d. Col. PE between 10 & 11 Elevati'on 261's

a. Col.-4 between L & M Elevation 318 's

b. Col . PE between 10. & 'll a. Col. PE between 8 & 9

b. Col. PE between 10 & 11 Elevation 281N's

a. Col. 4 between L.& M

b. Col . PE betwen 10 & 11 CLOSURE Due to the addition of new cables, the' commitment to NRC found in the SER dated July 26, 1979 has not been met. .

DATE:

SIGNATURE:

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i NMP1 - FIRE PROTECTION VERIFICATION FORMAT DESCRI PTION OF COMMITMENT: Control Building - Elev. 250'. Fire

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stops and/or penetration seals will be provided for electrical cable runs.

ACTIVITY NO.: 19-A. .

REFERENCE:

SER Page 6, Section 3.1.3 ( 2 ); Page 37, Section- j 5.2.1.6.

DESIGN REVIEW:

1. Drawing Reviewed - C-27101-C; C-27102-C. i

2. Results - See Penetration Section in Appendix for details. , j

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3. Reviewer: J. Behn and T. Tess. j FIELD VERIFICATION:

1. Area of Plant Reviewed: Cable spreading room.

2. Date Reviewed: September and October 1984.

3. Results - See penetration section in Appendix for Details.

4. Reviewer - V. Sbarra, J. Gruettner, J. Behn.

PRE-OP TESTING:

1. Testing Required: See Appendix.

2. Test Report : none.

3. Evaluation: See Penetration Seals Section in Appendix for Details.  !

4. Reviewer: T. Tess.

SURVEILLANCE REQUIREMENTS:

1. Testing and Inspection Requirements: See Penetration Section l in Appendix f or Details.

! 2. Evaluation: none.

3. Reviewer: T. Tess. j PROBLEMS - PRE-OP & , SURVEILLANCE PROBLEMS See Appendix.

GAGE-SABCOCK & ASSOC 4ATES. DC C-9

NMP1 -~ FIRE PROTECTION VERIFICATION FORMAT.

CLOSURE Due to a number of problems associated with penetration.

seals, the~ commitment to NRC found in the SER' dated July 26, 1979 has not been met.

DATE: ,

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NMP,1 FIRE PROTECTION VERIFICATION FORMAT j

( DESCRIPTION OF COMMITMENT: - Turbine Building, Elev. 750', ,

261', 277*, 711'. Suitable fire stops and/or penetration ' I seals will be provided for electrical cable runs; (floor, elev. 250', 261'; Elev. 277'; Elev. 291').

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ACTIVITY NO.: ll-C.

REFERENCE:

SER: Page 6, Sect. 3.1.3; Pg. 50, Sect. 5.4.2.6; Pg. 52, Sect. 5.4.3.6; Pg. 23, Sect. 4.8.

DESIGN REVIEW:

1. Drawing Reviewed: C-27103-C; C-27110-C; C-27112-C; C- 1 27113-C,; C-27115-C; C-27J93-C, C-39591-C, C-19448-C; C-27114-C.

. 2. Results: Noncombustible penetration seals provided. Only or)e fire stop provided for cable tray run on Elev. 261' . ,

3. Reviewer: R. Barnes, J. Gruettner.

FIELD VERIFICATION

1. Area of Plant Reviewed: Turbine Bldg., Elev. 250', 261',

277' and 291'.

2. Date Reviewed: July and August, 1984.

3. Results: Fire stops have generally not been provided for cable runs in the Turbine Building. Cable runs over power-boards are coated with Flamemastic in many areas.

4. Reviewer R. Barnes, J. Gruettner. I i

PRE-OP TESTING n/a i I

1. Testing Required: l

2. Test Reports

3. Evaluation:

4. Reviewer j SURVEILLANCE REQUIREMENTS:  !

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1. Testing & Inspection Requirements n/a l

2. Evaluation  !

3. Reviewers l PROBLEMS - PRE-OP & SURVEILLANCE:  !

e PROBLEHS Fire stops in general have not been provided for

( cable tray runs.

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o NMP 1 FIRE PROTECTION VERIFICATION- FORMAT

, CLOSURE The commitment for fire stops found in. the SER, dated ('

July 26, 1979 has not.been met.

DATE:

SIGNATURE f

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NMP1 - FIRE PROTECTION VERIFICATION FORMAT DESCRI PT70N OF COMMITMENT: Turbine Building. Provide rated seals on all cable penetrations commensurate with the barrier rating.

l ACTIVITY NO.: 19.C (Turbine Bldg. only) . , ,

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REFERENCE:

SER Pg. 6, Sect. 3.1.3 ; Pg . 2 6, Sect . 4.9.3 DESIGN R_EVIEW:

1. Drawings Reviewed: C-27069-C, Sheets 1 and 2; C-27101-C; C-27102-C, Sheet 1; C-27103-C, Sheets 1 through 4; C-27104-C; C-27106-C; C-27107-C; C-27109-C; C-27110-C through C-27117-C; C-27120-C, C-27148-C; C-27149-C; C-27150-C; C-27151-Cr C-27154-C; C-27157-C; C-35841-C.

2. Results: There are over 30 different types of penetration seals being used in the plant, including numerous cable penetration designs. Design details were not provided for cable tray penetrations. Many of the design details utilized have not been tested for fire resistance. l

3. Reviewer: J. Behn, T. Tess, R. Barnes.

FIELD VERIFICATION: ,

1. Area of Plant Reviewed: Various plant areas for representative examples of various penetration seal designs. >

2. Date Reviewed: June, July, August 1984. ,

3. Results: A representati-ve r eber of penetration seals of each type utilized in the plant were checked for compliance with installation details. Approximately 30% of the seals checked were not installed in accordance with the design detail drawings, whether the drawings depicted an acceptable seal or not.

4. Reviewer: R. Barnes, T. Tess, J. Gruettner.

PRE-OP TESTING l

1. Testing Required: Leak test of completed penetraiton seals

- is conducted e It is not required by Tech. Specs.

2. Test Reports: Breach permit will- indicate if leak test was completed af ter the penetration was sealed.

3. Evaluation: The leak test. currently being used is unreliable, inconsistently applied and lacks any procedural guidelines for its use. The " Downy Wand Test" utiliz'es a tuft of goose down held in a pair of tweezers. Drafts coming through the GAGE BAk,0CK & ASSOCLATES. WC

NMP1 - FIRE PRUTECTION VERIFf CATION FORMAT seal are detected by the a>ovement of the down, f

4. Reviewer: T. Tess.

e SURVEILLANCE REQUIREMENTS

1. Testing and Inspection Requirements: The Tech. Specs ,

require a visual inspectica of the fire barrier penetrations at least once per operating cycle.

2. Evaluation: Over the past year the Fire Barrier Penetration Fire Seals Inspection, NI-FST-C2, has been performed several times as a method of keeping up-to-date with initiated changes. 3 Inspections are conducted by the Fire Department . Staff . - i Satisfactory or Unsatisfactory are the responses indicating the seal condition given ty the inspector during the survey. The l penetrations are

• visually inspected to verify that they are l sealed in accordance with their referenced detail.' Of the 73 seals we found deficient, only one had been cited deficient in the 3/21/84 inspection. The most alarming problem cited is that 20 seals were incorrectly listed on the drawings and l surveillance, i .e . , they were not listed in accordance with their l referenced detail.

l l The inspection completed on 3/21/84 noted that fire watches were being instituted as a result of 63 seal deficiencies (63 Work Requests (W.R. 's) were issued). It did not note any fire patrols being issued and did not make note of any verification of detector operability. Only seven W.R. 's were marked off as done.

See Appendix for additional comments.

3. Reviewer: T. Tess.

l l

PROBLEMS - PRE-OP { SURVEILLANCE:

PROBLEMS - A sample survey of penetration seals indicate that i some seals are incorrectly identified, incorrectly sealed and do i not resemble the seals tested.

CLOSURE - The penetration seals do not meet the commitment to NRC i found in the SER dated July 26, 1979. j DATE:

SIGNATURE: l l

~~

OAGE BABCOCK & ASSOC 6ATES #C T-24 i

.i NMP1 - FIRE PROTECTION VERIFICATION FORMAT DESCRIPTION OF COMMITMENT: Turbine Building. Install piping j penetrations with fire resistance ratings equal to the barriers )

they penetrate between safety-related areas and between safety-related and non-safety-related areas.

ACTIVITY NO.: 20 (Turbine Bldg. only) .  !

1

REFERENCE:

SER Pg. 26, Sect. 4.9.4; Pg. 52, Sect. 5.4.3.6.

DESIGN REVIEW:  !

1. Drawings Reviewed: C-27069-C, Sheets 1 and 2; C-27101-C; C-27102-C, sheet _1; C-27103-C, Sheets 1 through 4; C-27104-C; C- l 27106-C; C-27107-C; C-27109-C; C-27110-C through C-27117-C; C- . I 27120-C, C-27148-C; C-27149-C; C-27150-C; C-27151-C; C-27154-C; C-27157-C; C-35841-C.

2. Results: There are over 30 dif ferent types' of penetration seals being used in the plant, including numerous cable penetration designs. Many of the design details utilized have not been tested for fire resistance.

i

3. Reviewer: J. Behn, T. Tess, R. Barnes.

• FIELD VERIFICATION:

. J

1. Area of Plant Reviewed: Various plant areas for

~

representative examples of various penetration seal designs.

2. Date Reviewed: June, July, August 1984.

3. Results: A representative number of penetration seals of l

each type utilized in the plant were checked for compliance with installation details. Approximately 30% of the seals checked were not installed in accordance with.the design detail drawings, l whether the drawings depicted an acceptable seal or not.  !

I

4. Reviewer R. Barnes, T. Tess, J. Gruettner.

PRE-OP TESTING

1. Testing Required: Leak test of completed penetration seals ,

is conducted. It is not required by Tech. Specs.

2. Test Re? orts: Breach permit will indicate if leak test was j completed adter the penetration was sealed.  !

3. Evaluation: The leak test currently being used is unreliable, inconsistently applied and lacks any nrocedural ,

guidelines for its use. The " Downy Wand Test" utilizes a tuft of '

goose down held in a pair of tweezers. Drafts coming through the l

oAme.sAacocx a issocares. ec T-25 l

T i

NMP1 - FIRE PROTECTION VERIFICATION FORMAT seal are detected' by the movement of the down.

4. Reviewer: T. Tess.

SURVEILLANCE REQUIREMENTS ,

1. Testing and Inspection Requirements: The Tech . Specs .

require. a visual inspection of the fire barrier penetrations at least once per operating cycle.

2. Evaluation: Over the past year the Fire Barrier Penetration Fire Seals Inspection, NI-FST-C2, has been performed several ,

times as a method of keeping up-to-date with initiated changes. I Inspections "are conducted by the Fire Department Staff.

l Satisfactory or Unsatisfactory are the responses indicating the seal condition given by the inspector during the survey. The 1 penetrations are " visually inspected to verify that they are- . i sealed in accordance with their referenced detail," Of the 73 1 seals we found deficient, only one had been cited deficient in l the 3/21/84 ins pectio n . The most alarming problem cited is that 20 seals were incorrectly listed on the drawings and surveillance, i.e., they were not listed in accordance with their referenced detail.

The inspection completed on 3/21/84 noted that fire watches werc being instituted as a result of 63 seal deficiencies (63 Work Requests (W.R.'s) were issued). It did not note any fire patrols being issued and did not make note of any verification of detector operability. Only seven W.R.'s were marked off as done.

See Appendix for additional comments.

3. Reviewer: T. Tess.

l PROBLEMS - PRE-OP 1 SURVEILLANCE r See Appendix.

PROBLEMS - A sample survey of penetration seals indicate that some seals are incorrectly identified, incorrectly sealed and do not resemble the seals tested.

CLOSURE - The penetration seals do not meet the commitment to NRC found in the SER dated July 26, 1979.

DATE:

SIGNATURE:- -

GAGE-BABCOCK & ASSOC 6ATES, DC T-26

NMP1 - FIRE PROTECTION VERIFICATION FORMAT

~

(

DESCRIPTION OF COMMITMENT: Turbine Building, Elev. 261'.

~

Provide rated penetration seals en all cable penetrations to the battery board rooms and the turbine generator lube oil reservoir room, i

ACTIVITY NO.: 19.B (1 of 2 parts)

REFERENCE:

SER Pg . 26, Sect , 4.9.3 s Pg. 50, Sect. 5.4.2.6, Pg .

52, Sect. 5.4.3.6.

DESIGN REVIEW:

1. Drawings Reviewed: C-27101-C; C-27102-C; C-27111-C; C-27117-C. -

2. Results: Drawings indicate 3 separate types of cable penetration seals utilized in these rooms. Seal types WP-3 and FP-3 provide 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated seals for cable penetraitons; 7 Seal .

ty pe WP-4B, utilized in the battery board room walls, has not been tested and is therefore not an acceptable cable penetration seal.

3. Reviewer: J. Behn, T. Tess, R. Barnes, J. Gruettner FIELD VERIFICATION: (

l. Area of Plant Reviewed: Various plant areas including battery board rooms and turbine generator lube oil reservoir room.

2. Date Pieviewed: June, July 1984

3. Results - A representative number of penetration seals of each type utilized in the plant were checked for compliance to installation details. Approximately 30% of the seals checked were not installed in accordance with the design detail drawings, whether the dctails depicted an acceptable seal or not.

Specifically, for seal type WP"3, only 10 to 20 seals checked >

were correctly installed or maintained. For seal type FP-3, only .

4 of 12 seals checked were correctly installed or maintained.

Based on this analysis, it is assumed that some of these same penetrations in the subject rooms will not be adequately installed even through they were not specifically checked.

4. Reviewer - R. Barnes, J. Behn, T. Tess, J. Gruettner PRE-OP TESTING: ,

1. Testing Required: Leak test of completed penetration seals 7

is conducted. It is not required by Tech. Spect.

2. Test Report: Breach permit will indicate if leak test was i

GAGE-BABCOCK & ASSOCNES. FC T-73

_____________.--_.m___u

NMP1 - FIRE PROTECTION VERIFICATION FORMAT r

completed af ter the penetration was sealed. .

3. Evaluation: The leak test currently being used is unreliable, inconsistently applied and lacks any procedural guidelines for its use. The " Downy Wand Test' utilized a tuft of goose down held in a pair of tweeters. Drafts coming thru the seal are detected by the movement of t!:.e down.

I

4. Reviewer T. Tess. I SURVEILLANCE REQUIREMENTS:

1. Testing and Inspection Requirements: The Technical Specifications require a visual inspection of the fire barrier penetrations at least once per operating cycle.

2. Evaluation: Over the past year the Fire Barrier Penetration Fire Seals Inspection, NI-FST-C2, has been performed several times as a method of keeping up-to-date with initiated changes.

Inspections are conducted by the Fire Department Staff.

Satisfactory or Unsatisfactory are the responses indicating the seal condition given by the inspector during the survey. The i I penetrations are " visually inspected to verify that they are

' sealed in accordance with their referenced detail." Of the 73 seals we found deficient, only one had been cited deficient in the 3/21/84 inspectios,. The most alarming problem cited is that 20 seals were incorrectly listed on the drawings and surveillance, i .e., they were not listed in accordance with their referenced detail.

The inspection completed on 3/21/84 noted that fire watches were being instituted as a result of 63 seal deficiencies (63 work Requests (W.R.'s) were issued). It did not note any fire patrols being issued and did not make note of any verification of detector operability. Only seven W.R.'s were marked off as done.  !

See Appendix for additional comments. '

3. Reviewer: T. Tess.

_ PROBLEMS - PRE-02 SURVEILLANCE i PROBLEMS - A sample survey of penetration seals indicate that some seals are incorrectly identified or incorrectly sealed and- {

do not resemble the seals tested. '

CLOSURE - The penetration seals do not meet the commitment' to

' NRC f ound in the SER dated July 26, 1979.  !

'~ DATE kU/ SIGNATURE GAGE SABCOCK & ASSOCLATES. E T-74

NMP 1 FIRE PROTECTION VERIFICATION FORMAT

( DESCRI PTION OF COMMITMENT: Waste Building. Install ' piping pene-trations with fire resistance ratings equal to the barriers they penetrate between safety-related areas and between safety-related and non-safety-related areas.

ACTIVITY NO.: 20 (Waste Bldg. only).

REFERENCE SER: Pg . 2 6, Sect . 4.9.4; Pg . 64, Sect . 5.6.1.6.

l DESIGN REVIEW:

1. Drawing Reviewed: C-27069-C, Sheets 1 and 2; C-27101-c; C-27102-C, sheet 1; C-27103-C, Sheets 1 t'arough 4; C-27104-C; C-27106-C; C-27107-C; C-27109-C; C-27110-2 through C-27117-C; C- ,

27120-6; C-27148-C; C-27149-C; C-27150-C; C-27151-C; C-27154-C; C-27157-C; C-35841-C.

2. Results: There are over 30 different types. of penetration seals being used in the plant, including numerous cable penetration designs . Design details were not provided for cable tray penetrations . Many of the design details utilized have not been tested for fire resistance.

3. Reviewer: J. Behn, T. Tess, R. Barnes.

FIELD VERIFICATION

1. Area Reviewed: Various plant areas for representative examples of various penetration seal designs.

2. Date Reviewed: June, July, August, 1984.

3. Results: A representative number of penetr6 tion seals of each type utilized in the plant were checked for compliance with installation details. Approximately 30% of the seals checked were not installed in accordance with the design detail drawings, whether the drawings depicted an acceptable seal or not.

1 Since many of the seal designs used in the plant are not fire rated designs as installed, the SER commitment has not been met.

4. Reviewer R. Barnes, J. Behn, T. Tess, J. Gruettner.

PRE-OP TESTING ~

1. Testing Required: Leak test of completed penetration seals is conducted. It is not required by Tech. Specs.

2. Test Reports: Breach permit will indicate if leak test was f- completed af ter the penetration was sealed.

s

. GAGE-BABCOCK & ASSOC 4ATES. N F-16 L, _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . ~ _ _ _ _ _ _ _ _ _ _ _ _ _ -_

NMP 1 FIRE PROTECTION VERIFICATION FORMAT

3. Evaluation: The leak test currently being used l's unreliable, inconsistently applied and lacks any procedural guidelines for its use. The " Downy Wand Test" utilized a tuft of goose -d.own held in a pair of tweezers. Drafts coming through the seal are detected by movement of the down. ,

4. Reviewer: T. Tess.

SURVEILLANCE REQUIREMENTS:

1. Testing and Inspection Requirements The Technical Specifications require a visual inspection of the fire barrier penetrations at least once per operating cycle.

2. Evsluation Over the past year the Fire Barrier Penetration Fire Seals Inspection, NI-FST-C2, has been performed . several times as a method of keeping up-to-date_ with initiated changes, j Inspe. cions are conducted by the Fire Deparment Staf f.

Satisif actory of unsatisf actory are the responses indicating the seal condition given by the inspector during the survey. The penetrations are " visually inspected to verify that they are sealed in accordance with their referenced detail." Of the 73 seals we found deficient, only one had been cited deficient in the 3/21/84 i nspection . The most alarming problem cited is that f 20 seals were incorrectly listed on the drawings and i surveillance, i.e., they were not listed in accordance with their referenced detail.

The inspection completed on 3/21/84 noted that fire watches were being instituted as a result of 63 seal deficiencies (63 Work Requests (W.R.'s) were issued). It did not note any fire patrols being issued and did not make note of any verification of detector operability . Only seven W.R.'s were marked off as done.

Sections 3.6.10.1 b and c of the Tech. Specs. state that a continuous fire watch on one side of non-functional fire barrier penetration be established within one hour or verify the operability of fire detectors on one side and establish a fire watch patrol .

Detector operability is verified by checking the fire alarm panel for trouble conditions; if none, then the last surveillance is cited as proof of operability. A fire watch patrol consists of a walk-through by a fire department member of the area affected by.

the non-functional penetration seal once every half hour.

Once the tire watch or patrol has been instituted, the W.R. 's are issued and listed on the fire department W.R. log.

Several problems exist. They ares (

GAGE BASCOCK & ASSOC 4ATES. PC U-17

- NMP.1 FIRE PROTECTION VERIFICATION FORMAT' r-6 . . ..

a. Those doing the surveillance are. not; identifying all .of the problems out in the plant. They have either been-inadequately trained or are not adequately doing-their job.

Summary: The fire barrier penetration sea 1 ' inspection-procedure has been documented to be inadequate.

b. 1. The surveillance form does not provida' adequate  !

- information to determine which nonfunctional penetrations j resulted in fire watches and which resulted 'in ; fire ' patrols.

2. The surveillance form does not note whether or not-any.

detectors ' were verified operable _ and .thus t allowing fire' ,

patrol.-

3. The surveillance report' does. not provide for< the check '

, of f of ~ pompleted W.R. 's and thus the termination of ' fire. ,

watches or patrols. ,

4. The fire department W.R. Log does ' not note if a ' fire watch or patrol is required as long as that particular W.R. . l 1s in effect.

5. The W.R. does not provide for. nor specifically state C.," whether a fire watch or patrol-is required while it is in effect.

NOTE: The issuing of a W.R. for a penetration seal does not i require a Breach Permit to be issued. As stated. earlier, the Breach Permit does state if a fire watch is required and assigned.

Summary: Fire patrols are being used extensively instead of fire watches and neither is properly documented or . controlled.

c. 1. The Technical Specificatf ons do not state what is' required to determine a, detector operable nor does it define fire patrol .

Summary: There is no specific requirements by which to judge the adequacy of NMPC's fire patrol procedures. -!

3. Reviewer: T. Tess. '

PROBLEMS - PRE-OP i SURVEILLANCE PROBLEMS CLOSURE Since many of the seal designs used in the plant are not 3 fire rated designs as installed, the SER commitment, dated JulyL 1 26, 1979, has not' been met.

., DATE  :

YW SIGNATURE l l

GAGE-SABCOCK & ASSOCAATES. K y ig -l

?

NI AGARA MOHAWK POWER ' CORP.

-1

, i 1

.)

1

'I

l APPENDIX C SURVEY OF' SELECTED.

PENETRATION _ SEALS i

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- 1

-1

-i GAGE SABCOCK & ASSOCIATES C-1  :<

I

_ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . - _ _ _ _ _ _ _ . _ _ _ _ _ . _ - _ _ _ _ _ _ __ _ . - _ . _ _ _ - . _ _ _ . . _ _. _.-.-__m..

i PEI '

$ FP-1 FP-I A [ F PROBLEMS 5 $ $ b $ 08 tb 8 h b n.

G 10 T O t -t 4 4 2 N l Woc 2D IN SLEEVE X X X X )( X 19 ADEQUATE OOF RESARS )( i IN co R R5c.T Li STI t 4 G c> M DRAW 1 bJ G )( X' ;

INA.Or.cusT, E KAf>WCO L FILL (SEE NOTE I.) y y IN C OM PL E.T E COMCR EETE y FILL )(

j s E. A. L coEs NOT MEET y ANY SPEctFIC TY PE*--

l . C.0 6.l DUI'i- WOT SEALED -

FLAMEMASTic INADEQUATE SLEFNE CoslDITIOhJ BAD , .

b FP-4B FP-4C 1 lspo v0 0 0 o o

- - o C PROBLEM 5 0 0 v o O n- Y *

• v O O m W y e e e e Q! _!

WOOD IN SLEEVf_

INADEGUATE 8 OF REEARS U

IN CO R RECT LISTihJG ON DRAWi M G INACEQ UATE KAOWO O L FILL (SEE MOTE t.) N N N N N r

I INCOM PLETE. CONCRETE .

FILL '

t SEAL DCE5 NOT ME E.T l A* W SPECIFIC TYP E I COMDUlT NOT SEALED j X X f FLAMEM ASTIC IWAO6QUATE;2 l X SLEEVE CONDITlOhJ B A.D  !

i, ; OPEW PEWETRATioM X )( )( X X MO RTA R ABouT SLEEVIE INA DEQ OATE S y) j^ PENETRATION

~

cu

1I ETRATION DETAll NO.5

"-2D FP- 3 FP-3A, kP FP- 4 A

$((5 v m e o v A N O d G 0 0 g a fq g $ g g o N 4 4 e e r- r- to o o + #0 r (o o 3 g m in to to to to to m in in e N g in a p g o 0 O o O n.. _ - - - - -

X X X X X X' X X X X X X X X X X X X X _

X X X X

! x x x x x li{

^'f WP-2 Nk~ WP-3 WP-3A WP-4E>

em . +

N b N N (Q T (f) $ P- (0 o v': N cs M _

o e (0 (0 N 1 0 G G 0 G t- t- r- N N N N e 9 (O GI C N v o e r- 10 in v t

}- LD O O O @ G W G O 0 W G G (D OI O W O' 0' 0' O O O W 4 l I ' l I

X X X X X X X XiX X X 'X X '

' X X X -

X XX X l x  :

x  ! -

X X X X X X X X l  !

X !l X

,X X i l i bJ O i E 1. SU t4 KEEAJ FL A MEE MASTIC LISTF D A5 IW6DECUAT E K Aow/ col FlLL EAL PROBLEMS - TABLE

NI AGARA MOHAWK POWER CORP.

. PENETRATION SURVEY LIST Legend:

Penetration detail no.: seal no. based on drawing C-27101-C and C-27102-C.

Description:

Description of seal.-

Number of penetration as specified by 4

Penetration Number:

Gasser usually stenciled on wall or floor 'near penetration.

• i Comments: Survey notes. ,

Priority: Based on severity of problem.

Priority I .immediate attention required Priority II - important, correct promptly Priority III - implement corrective action on program basis.

SAT /UNSAT Per GBA - (satisfactory / unsatisfactory) Indicating what GBA's response on the standard surveillance form would be based on our survey.

SAT /UNSAT Per NMPC Survey - indicating NMPC employee response to field con-dition of seals from latest surveillance report, NI-FST-C2, 3/21/1984.

j l

1 i

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l G l GAGE BABCOCK & ASSOCLATES C-2 l l

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.4 5

NIAGARA s uAWK POWER CORP.  :

j F1h0R PENETRATIONS, Penetration Detail No.: FP-1

Description:

Vertical steel sleeve with concrete fill a minimum of 8 inches deep and #3 rebar anchors. ,

CBA NMP Penetration No. Comments Priority Fval Eval 486 Good S S .q 487 Good S S 497 Wood in bottom of sleeve III U S 644 Good 5 S 730 Good S S j 642 Good S S  !

I 581 Good S S l

549 Good S S 558 13" diameter sleeve - has only II U S S,

2 rebar anchors 493 Good cap @ bottom of sleeve II U S j Rebar in bad condition 495, 499 Not checked from above III U S -)

500 Wood cap @ bottom of sleeve U S .

l 498 Wood cap @ bottom of sleeve III U S i

496 No longer FP-1 type. 17-3/4" III U S flex conduit thru, hole in  !

1 1

9 .

GAGE BABCOCK & ASSOCIATES C-3

NIAGARA MOHAWK POWER CORP.

LO Penetration Detail No.: TP-1A

Description:

steel sleeve at a 45 degree incline with concrete fill a minimum of 8 inches vertical depth and #3 rebar..anchorn Penetration No. Comments ' Priority 645 Good S S-645 Good S S

.535 Good - sleeve full of debris III U S .

above concrete fill 117 Incomplete concrete fill' II U' 'S 150 Good S S 129 Good - sma'11 fill void S S not signifcant 130 Good S S 261 Incomplete concrete fill III U. S 262 Good S S 270 Good S S 274 Good .S S 275 Good S' S 276 Good S S GAGE-BABCOCK & ASSO5ATES C-4

.m - - - - _ - - - - - - - - - - , .- - _ - - - - - - - - - - . - _ _ - - - - - - _ _ - - - - _ _ - , , - - - - - - - - - -

1 l

NIAGARA MDEN1K POWER 00RP.

'l I

Penetration Detail No.: TP-1B

Description:

Concrete fill with 2 f3 rebers as reinforcing. No steel sleeve. ,

l r

Penetration No. Comments Priority 731 Good - S S 732 Good - Concrete was flush S S at top and irregular 733 Cood - at bottom. S S 734 Good - S S Note: Only four penetrations of this type were identified.

J Seal Detail No.: FP-1C

Description:

This is a temporary seal consisting of either 1" minimum thickness of motar or fire rated pillows.

I 1

Eote: None of this type of seal vere rated on the drawings, as there should not be, and none were found during the random plant survey.

l 1

l l

I i

l GAGE BABCOCK & ASSOCIATES C-5

f. .

9

1 i

WT Af*191 MM AW D&WD PADD .-

'D '

Pentration Detail No.: FP-2

Description:

Steel sleeve packed witgh Kaowool ceramic fiber and sealed on both ends with 1/4" of Flamemastic. ,

1 Penetration No. Comments Priority 476 Good - Both had, a metal cap over S S the top that could not be 477 Good - removed. The Flamemastic S S on thi bottom was good.

. . See note. l Note: Without dismantling the seal, it is impossible to determine if adequate Kaovool had been filled into the sleeve. .

O  !

4

~~

GAGE BABCOCK & ASSCCATES C-6

i.

1 NIAGARA HOHAWK POWER CORP. ,

O Penetration Detail No.: FP-2A i

Dese.ription: Steel sleeve at 45 degree inclino filled with Kaowool banket at the bottom and bulk Kaowool above, the top and 6ottom are sealed with Flamemastic.

Penetration No. Comments Priority

$59 8" dia. sleeve. Flamemastic II U S at bottom sunken 6" at the j

. center. See note.

Note: Sunken fill at the bottom indicates that the Kaowool blanket material was not used. Recommend dismantling for review.

1 e

i i

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. 5 dll GAGE BABCOCK & ASSOCIATE 5 C-7

.__-____-___--___--__a

l

., .ij

.NIACARA MORAWK POWER CORP.- d Penetration Detail No.: FP-2C '

Desc'ription: For large openings - block or bulk Kaovop1 fill with -

1/4" Flamemastic top and bottom. l Penetration No. Comments Priority

. 1491 Steel plate on 3" curb at top, S S Flamemastic at bottom good, l Kaowool fill appears good. I

,1476 Flamemastic and fill from bottom S S ,

)

good, could not verify top. ]

1477 Steel plate on 3" curb at top, S S Flamemastic and fill at bottom I good.

993 15 x 48" steel plate on.3" curb S S at top, Flamemastic and block Kaowool at bottom.

995 12 x 48" steel pate on 3" curb .S S I at top, Flamemastic at bottom good.

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GAGE BABCOCK & ASSOCIATES C-8 '

1 i

l NIAGARA LOHAWK POWER CORP.

Penetration Detail No.: FP-2D l 1

Description. Bulk Kaowool fill with Flamemastic top and botton., no j steel sleeve.

Penetration No. Comments Priority 1

i No numbered: Both seals good S l

-2 in Aux. Control )

room, 261' El.

-3 in Aux. Control All had conduit passing thru. II U room 261' El. These do not met the design of any detail.

-1 in Aux. Control Has conduit passing thru. II U room, 261' El, at This does not meet any design.

Co. AB/16, near 1472 -

1488, 1489 Flanemastic & fill good at S S bottom. Top is capped - this ,

varies from design but insig-  !

nificant. l 1484, 1485 Both have conduit passing thru. II U S  ;

A conduit elbow 18" below is  !

sealed with putty. Both condi-tions are contrary to design.  ;

4 GAGE BABCOCK & ASSOCIATES C-9

NIAGARA E RAWK POWER CORP. 9 ps-Penetration Detail-No.: FP-2E

Description:

Used primarily for manholes - 1" thick by 12" wide Kao' wool blanket fill with 1/4" Flamemastic at top and bottom.

Penetration No. . Comments- Priority-1008 29" manhole - cover at top,- 'S S Flamemastic at bottom good, Kaowool not flush with bottom

- good one to check.

~438 29" manhole'- cover at top, S -S Flamemastic st bottom good.

439 29" manhole - cover at top, S S .

Kaowool blanket with flame-mastic good.

1009 29" manhole - good S S O

O GAGE BABCOCK & ASSOCIATES C-10

NIAGARA WHAWK POWER CORP.

)

Penetration Detail No.: FP-3

Description:

Vertical steel sleeve filled with Kaowool with 1/4" Flamemastic top and bottom, 1" maximum gap in Flamemastic around pipe acceptable.

Pctetration No. Comments Priority 501 Flamemastic good top & bottom, S S 643 3-1/2" water main thru, flame- S S mastic good top & bottom, no gap around pipe.

574 2" air line thru, opening in II U S-Kaowool at bottom, Flamemastic good.

573 Flamemasic good"but sunken. II U. S Good one to dismantle.

554 Two conduits thru, Flamemastic II U S good, conduit elbow at seal open - conduit not sealed.

553 1/2" conduit thru, Flamemastic II U S sunken 1-2" top & bottom. Good one to dismantle.

552 Not an FP-3 seal as drawings in- II U S dicate. 8" pipe grouted in place - like an FP-3C.

548 Flamemastic separated from sleeve II U S and sunken. Good to dismantle.

496 See FP-1 II U S 483 Good S S 532 Flamemastic at top sunken, at II U S bottom good .

503 Good. See note S S >

Note: In no case sas there a gap in the Flamemastic around the pipe, conduit, etc.

4 GAGE BABCOCK & ASSOCIATES C-ll

, _ _ _ . - ~ _ . _ _ . mensammmmmmmmense l

NIAGARA IClLWK POWER CORP.

/*

Penetration Detail No.: FP-3A

Description:

Steel sleeve at 45 deSree incline with pipe or conduit thru filled with Kaowool blanket at bottom, bulk Kaowood above and 1/4" Flamemastic top and bottom. See note below. <

i Penetration No. Comments Priority 576 Sunken 3" at bottom. Good to -III U S  ;

dismantle to check if Kaowoel  !

blanket was used.

~

533 Good S S I 536 Good S S l

538 Sunken at bottom. 2" conduit II U S i thru not sealed (open junction  ;

box).

560 1/2" conduit thru not sealed. II .U S 512 Good S S.

196 Not listed on drawings III U S correctly - listed as FP-1A.

Good.

l 210 Sunken 2".at bottom. . III U S 263 Good S S 264 Good S S 295 Flex. conduit with PVC. Seal S S good.

291 Good S S 714 Good S- S Mote: Generally there is no gap in the IIasemastic around the pipe.

O GAGE BABCOCK & ASSOCIATES C-12

NIAGARA N HAWK POWER CORP.

Penetration Detail No.: FP-3B k

Description:

Similar to FP-3A but filled at' top with 12" Kaowool blanket with 1/4" Flamemastic at top and bottom of blanket.

Penetration No. Comments Priority l

None were listed on the tirawings and none i

were found in the field.

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4; GAGE BABCOCK & ASSOCIATES C-13

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NIACAMA MOHAWK POWER CORP. )

O. Penetration Detail No.: FP-3C i

Description:

Conduit thru concrete floor - seal around pipe with mortar and seal conduit as described in Section , Conduit penetration seals.

Penetration No. Comments Priority 747 Good - S S Could not be check

,748 Good - from below. S S ,

552 Incorrectly listed as FP-3. III U S Good.

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G AGE BABCOCK & ASSOCIATES l C-14

_ _ _ _ . l

~ _ _ _ . -

NIAGARA lORAWK POWER CORP. 4 Penetration Detail No.: FP-3D

Description:

For sump pump penetrations - 1" vide Kaowool blanket with F1smemastic top & bottom.

Penetration No. Comments Priority l 597 Listed incorrectly as an FP-3C. III U S Seal not verified.

534 Good s s i

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GEGE BABCOCK & ASSOCIATES C-15 i

-_---__m

NIAGARA M) HAWK POWER CORP.

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O' Penetration Detail No.: TP-4 '

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l

Description:

Steel sleeve filled with bulk Kaowool with welded  !

cover plate one end and 1/4" Flasemastic at other.

9 I

Penetration No. Comments Priority l I

RT-10, 11, 13 Floor penetrations in air lock. ,S S l T1amemastic good at botton, I Welded plate abcve.

917, ,919, 921 Oil tank room, 261' Elevation. S S 924, 927, 930 All good. -

933 934 Kaovool exposed II U S 1

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i GAGE BABCOCK & ASSOCIATES C-16 i

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NIAGARA K) HAWK POWER CORP.

Penetration Detail No.: TP-4A

Description:

Steel sleeve with pipe or conduit thru filled with Kaovool with top plate and 1/4" T1anemastic at bottom.

Penetration No. Comments Priority 915, 916, 918 Oil tank room, 261' El. S S j 922, 923, 926 All good.

928, 929, 932, 935 931 Open conduit - not sealed. II U S 551 Incorrectly listed 6s TP-4A. II U S Seal does not meet any specific type.

100, 101, 102 Caustic /acjd area. 261' El. I U S l

103, 104 Turbine Building. All are in bad condition.

RF-9, 15, 16 Air lock. All good. S S O!!

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O GAGE BABCOCK & ASSCCtATES

_..___._____m ___-_____m..- _

1 NIAGARA K) HAWK POWER CORP.

Penetration Detail No.: FP-4B -

Description:

Duct penetration - filled with Knowool stound duct with steel angle iron at top and 1/4" Flasemastic at bottom.

Penetration No. Comments Priority 757 10 x 18 duct, angle iron 5 S top and bottom-987 40 x 16 duct, angle iron top III, U S and bottom, did not look filled with Kaowool. Good one to dismantle 1004 26 x 24 duct, no Kaovool fill. I U S 1003 20 x 20 duct, no Kaowool fill. I U S ,

541 34 x 32 duct. Angle iron. . II U S bracing on one side does not cover opening - Kaowool present, no Flamemastic. 1" conduit not .

sealed.

530 16 x 12 duct. No Kaovool seen II U S from bottom.

3 403 12 x 30 duct. Kaowool not well II U S packed.

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O GAGE BABCOCK & ASSOCIATES C-18 l I

NIAGARA MOHAWK POWER CORP. {

0, Penetration Detail No.: TP-4C i

Description:

Steel sleeve with steel plate and pyrocrete cover -

rated for only one hour. , I

{

Penetration No. Coment s Hone found in plant Miscellaneous Others:  !

Penetration No. Cument s Priority i

Near 150 Plastic pipe through floor. I U  !

261' E1. - 1567 j Near 102 Opening down to 250' E1. I U 261' E1. -

115, 382, 357 open drain pipe - funnel I U s  !

326, 354, 255 type.

244, 251, 260 941, 947 16 x 36 steel plate with I U S e

steel strap. Open to below.

940, 946 24 x 18 steel plate. Open to I U S below. Wood brace on underside.

1479 1-1/2" conduit not sealed. I U S i

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GAGE BABCOCK & ASSOCIATES C-19 i

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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . . _ __ _ _ _ _ _ J

'l NIAGARA MOHAWK POWER CORP.

o Wall Penetrations:

1 l

Penetration Detail No.: WP-1 .

l

Description:

Steel sleeve filled with concrete j Penetration No. -. Comments Priority T61 8" spare, concrete painted S S

'T62 Incorrectly _ listed as a WP-1. II U S -

3/4" conduit thru concrete.

' fill. This does not meet any I particular seal. type.

T107 Good S S T108 Good S S D33 Good S S D31 Good S. S Penetration Detail No.: WP-1A

Description:

Temporary seal of grout or fire rated pillow.

Non were found in the plant..

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GAGE BABCOCK & ASSOCIATES

NIAGARA MOHAWK POWER CORP.

Penetration Detail No.: WP-2 O

Description:

Steel sleeve with 8" minimum thickness of bulk Kaowool with Flaremastic on each end. See note. ,

Penetration No. Comments Priority OG24, 25 Seal within sleeve good. II U Seal around sleeve poor.

Cood S S

.OG5

$60, S61, S62 All good S S69 Good S S4, S5 Good, S S S48 Good S S67 1-1/2" Conduit not sealed. I U S40 12" pipe mortared in wall filled S S sith Kaowool and Flamemastic.

Note: The actual depth of Kaowool could not be determined.

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8 GAGE BABCOCK & ASSOCIATES C-21

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NIAGARA MOHAWK POWER CORP.

Penetration Detail No.: WP-2A'

Description:

Steel siteve filled with 12" vide Kaowool banket with Flamemastic both ends and vleded air tight plate one end.

Penetration No. Comments Priority E31, R33. R40 '

All good S .S R50 All good- S S R105l R102 R104, R141 R139 K140 Has 4" painted pipe. Seal good S S R13, R14 EIS All good S R17 RIB 56 Open I U S O

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1 I GAGE BABCOCK & ASSOCIATES

NIAGARA MOHAWK PCMER CORP. __

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1 Penetration Detail No.: WP-2B l i

Description:

Steel sleeve with 8" vide Kaowool blanket fill near each end eith Flamemastic at each end (outside face only). No fill )

is required between blar.kets. )1 Penetration No. Cotament s  !

l

,Several penetrations listed as being in the "K" row wall of the Waste Disposal Bilding. This area was not surveyed due to very l high radiation levels.

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l e GAGE BABCOCK & ASSOCIATES C-23

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- NIAGARA MORWK POWER CORP. _

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i Penetration Detail No.: WP-3 i

Description:

Steel sleeve with a pipe, cable or conduit passing thru, sleeve filled with Kaowool with Flamemastic on both ends..

i Penetration No. Comments Priority q S75, 574, S75 All iccorrect'ly listed as 1 U

. WP-4B., No Flamemastic, Knowool incomplete.

Seals in bad condition -

S26, S27, S28 I U U S29 Kaowool exposed. . j l

S24 Good ,

i 56 Incorrectly listed as a III U- S WP-2A. Seal good. .

() S35 S31, S32 6" sleeve, seal good. S S l

Good S S 59, S10 ,

Good S S l

S12 Incorrectly listed as WP-2A. II U S Flamemastic shrunk away from sleeve. .

S8 Incorrectly listed as WP-2A. III U S Seal good.

57 Good S S-OG4, 0011 Incorrectly listed as WP-2. III U C A22 Good S, S l

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GAGE-BABCCN;K & ASSCK;lATES I C-24 ,

- . - - - _ . _ - _ _ . - _ _ _ . _ _ . _ _ - -.D

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Penetration Detail No.: WP-3A '

Description:

Steel sleeve with pipe, cor,duit, etc. thru sleeve filled with Knowcol, with velded air tight plate on one end and Flam~emastic the other. '

i Penetration No. Conments Priority R27, R49 Welded plate outside the RX II U S R63, R61 building. Putty was used to seal around pipes - there is

. no documentation that this is .i acceptable. j RS1, R65 Good S S R64, R60 i

T110 Good . S $

l i Penetration Detail No.: WP-3B

Description:

Steel sleeve with pipe thru filled with 12" vide i Kaowool blanket. Flamemastic on the turbine sie end with air tight boot, i l

No penetration seals of this type were surveyed.

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O G AGE BABCOCK & ASSOCIATES C-25

NIAGARA ICHAWK POWER CORP.

Penetration Detail No.: WP-3C

Description:

Similar to WP-3B without airtight boot. In no case-was there a space around each pipe.

Penetration No. Comments Priority All seals listed below are in the seal oil unit room.

7c1,2,3,4,5, All good.- S S-6, 7, 8, 9, 15 e

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O l GAGE BABCOCK & ASSOCIATES C-26 j

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NIAGARA .'OHAWK POWER CORP. l I

1 1 Penetration Detail No.: WP-4

Description:

Split sleeve in concrete block wall. Clearance of 1-1/2" for large pipe and I" for those less than 6" dia. to be provided between the sletve and pipt. Clear space filled'with

! Kaovool blanket. No Flamemastic noted in detail.  !

l l Penetration No. Commects Priority RWI, RWS All good. S S Rv9, RW10 RW2 Clearance greater than allowed - l 12" sleeve, 6" pipe.. j l

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Penetration Detail No.: WP-4A I

Description:

Pipe or duct penetration filled with Kaovool with Plamemastic each side.

Penetration No. Comments Priority W35 Good S S RW6 12" x 24" duct with angle iron S S bracing and damper. )

577 Not listed on drawings. Good S

.I C43 16" x 36" duct with angle iron S S i bracing. l C44, C45 12" x 12" duet with bracing. S S l

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GAGE BABCOCK & ASSOCIATES C-27

NIAGARA MdHAWK POWER CORP.

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<J Penetration Detail No.: WP-45

Description:

- Pipe, conduit or cable penetration filled with mortar, minimum 1" depth.

Penetration No. Comments Priority A63 No completely filled. II .U 3/4" conduit S$6 Good S S34 1" conduit. Good S S S3) Incomplete fill. 1" conduit II- U S S76 Open. Automatic sprinkler pipe I U S53, S55 Cables and conduit. Good S A57 Coduit saled 3 from penetration, II U this should be scaled at the wall.

A41 - A47 Not listed on. drawings. Good III U A32 3" conduit. Good S A53 - A56 Conduit thru concrete block. S Mortar seal good.

AB3 1" conduit in, BX cable out. ,

S Mortar seal good.

GAGE-BABCOCK & ASSOCIATES C-28 1

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4 WTACADA M MALT DALTD PADD q Penetration Detail No.: WP-4C~ -

4

Description:

Steel sleeve s.crtared into concrete block wall. bulk l Kaowol fill in concrete block void space around sleeve. Pipe or '

l conduit penetration, sleeve filled with Kaovool blanket with 1/4" 1 Flamemastic both ends. l l

Penetration No. Comments Priority A41 Cood S S W140, W141 Good S S

+ -S S42 Good S E

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Miscellaneous Others:

1 Penetration No. Comments Priority Probably S70 Located 10' below and right of II U g{

S20 looking north. Bad seal. (l i

S38 Listed as a WP-2 but is like II U' S i a WP-1. Has Flamemastic on  ;

the south end. l D29, D30 D32 These are concrete block seals II U A in concrete wall. Rating of ,

these uust be verified. ]

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GAGE BABCOCK & ASSOCIATES C-29 l

dEBBKaihDagEMSMTIMEiiiERTEDElBfAsahdSihAanish1W.t-wemmsm

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- . Copies of the related Saf ety Evaluation and Motice of Issuance are

, '. also enclose.d.

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Thomas , ppolito, Chief Operating Reactors Branch #3 Division of Operating Rr, actors

Enclosures:

'1. k,eninent No. 33 to OPR-63

' 2. Safety Evaluation l 3. Notice cc w/ enclosures:

See next page .

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Mr. Donald P. Dise 4 cc: Eugene 8. Thomas, Jr., Escuire 'i LeBoeuf. Lamb, Leiby & MacRae 1757 N Street, N. 'J.  !

Washington, D. C. a036 Anthony L Roisman Natural Resources Defense Council

• i 917 15th Street, N. W.  ;

Washington, D. C. 20005  !

l T. K. DeBoer. Director  ;

Technological Development Programs ,i State of New York l Energy Office .

1 i Swan Straret Building CORE 1 - Second Floor Empire State Plaza s Albany, New York 12223 r j

Mr. Robert P. Jones, Supervisor Town of Scriba f R. D. f4 '

l Oswego, New York 13126 Niagara lbhawk Power Corporation

. ATIN: Mr. Thomas Perkins t Plant Superintendent e Nine Nile Point Plant ,

300 Erie Boulevard West -

Syracuse, New York 13202 '*'

i' bL Direc. tor Technical Assessment Division i!

Office of Radiation Programs (AW-459) Bl US UA s' !i Crystal Mall f2 rl Arlington, Virginia 20460 ;l

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[:' ' e U. S. Environmental Protect'en Agency e '

Region !! Office

, 1 ig.' ATTN:- EIS COORDINATOR l

' . 26 Federc1 Plaza '

. INew York, New York 10007

. Oswego County Office Building

.. .46 E. . Bridge Street  : 1k1 fh"y:ff... . gy:...-0swego, New13126 York . Sk1 0!?, 'i* *

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. U 13 d)enw  ? Lt m Dr. Thomas E. Mar ley .]

APR 9 019o4 w

i keg *0nal Admi n".tr a tor "

U. N . Nuc lear Regulatory Conrnission u,,c kegien 1 pocestut coktmot toc 2 _

531 Park Avenue  ! ? '"

King of Prussia, PA 19406 ,

Re: Docket No. 50-220

.[R 83-44

Dear Dr. Morley:

Our December 13, 1983 letter submitted Licensee Event Report 83-44 That

~. Licensee Event Report dealt with the discovery of a Reactor Building fire

~ barrier penetration that was improperly sealed. The discovery was made during a periodic surveillance of fire barrier penetrations as required by the plant Technical Specifications. A. fire watch was estabished within one hour of disccvety in compliance with Technical Specification 3.6.10.b. The

., penetration was repaired within four hours.

• '~LicenseeEventRepor6 83-44 stated that an inspection of fire barrier penetrations was to be performed. Upon completion of the inspection, a .

.U ld be submitted to the Nuclear Regulatory Comission.

._ special report wou"Provided in Attachment I are the actions taken by Niagara Mohawk to assess current status of fire barrier penetrations at Nine Mile Point Unit 1 and assure the future integrity of these fire barrier penetrations.

truly yeurs.

T. E. s From T.E. Lempges tes .' Vice President W. M. Bryant i Nuclear Generation 1EL/MTG:djm R. 8. Burtch 'I 4

Attachnent D. p. Dise

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G. h. EnMe  :

pp/%~- J. J. S.:nser M. getterhahn, Esq. s

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'aajIr Monawk nr s temporarily implemented Techniul Specificati.

• Wrveillance rensirement 4.6.10.1.3.1 on a two montn cycle inste4<3 :a per operating cycle. Tnis was done to assure that penetrations

.ir- u s-properly wnile odditiona l od'iiiviistrative contrnis are ettantisnec. l' M1ition, the surveillance procedure is tecieiy revised tu refie. t tw

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resslts of the complete 0 1nspections.

. 3 reach Permit L-..

A creach permit requis ement for penetrations in walls and t lov- nat .

created. Inis creach permit must be signed ey tne Station Snif- j Supervisor and fire Department and Oaality Contrul representatives, i

3. Identification Drawings j

Drawings which denote the Technical Specifications rated walls ano f h rs j have been developed and issued for use. _ These drawings identify those

• walls and floors, and therefore, those penetrations tnat are coveres oy l Technical Specifications 3.6.10.1. Inis infonnation will be used oy Fire  ;

' Department personnel and Operations personnel to assure sdeauate measures are taken when issuing and approving breach permits for penetrations in Technical Specifications rated walif/ floors.

l These same drawings are currently being revised to distinguish between technical specifications rated walls / floors, non-technical specifications

. rated walls / floors and non-rated walls / floors.

4 Inspection A.: inspection of rated walls and floors that are covered by the Technical Specificatur.s has been completed. Fire watches have been estaolisned, where necessary. Repair of the non-runctionai semis has been initiated. i 11 is estimated that repair of the penetrations will take four montns.

An inspection will also be made of non-technical specifications rated walls / floors. When the inspection is completed, repairs, if'ne.:essary.

)

will be made.

y 5. Installation Procedures New installation and repair procedures have been or are being developec for fire barrier penetration seals. These new procedures include definitions of Technical Specification rated walls / floors, specific pleat conditions for opening penetrations in the Reactor Building walls, detailed steps with sign-off requirements-for installing or repairing a.

penetration seal, a data sheet that must be completed for each penetration, acceptance criteria that state the tests required ana bal ts Control / fire Department acceptance of the completed seal. ,

---__-_____m

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6. Penetration Seal Detail Drawings i

Revkseddrawingsshowingtheacceptablemethodsthatcanbeusedtoseal various configurations have been developed and issued for use. These new detail drawings conbine. electrical and mechanical penetrations. Prior to l this, there were separate drawing details for electrical and mechanical . l penetrations. These drawings contained conflicting attatis for sealing simi la r ' penetrations. By combining the two, a concise set of drawings l will be developed that will eliminate conflicting sealing methods. .j l

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• r f ' NIAGARA MOHAWK POWER CORPORATION . j N] NtAGARA MOHAWK i

300 ERIE DOJLEV ARD. WEST ]

e no.cust. u. v. ssnos f October it,1984 4 1

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A Urtited States NacLear Vegt:Latory Consission Document Contret Vesk Washington, DC 20555 RE: Docket No. 50-220 SPECIAL REPORT GerAlenent In accordance with Technical Specification 3.6.10.1, we hereby sutnit the following Special Report concerning a fire larrich pc. neb.ation.

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• Very truly-yoprs,

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Thomas E. Lemps -

Vice Prtsident NacLear Generation TEL/le *

• cct Dr. Thomas E. Ruttey Regional Administrator

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J 4 SPECIAL REPORT

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Title:

Non-Functional Fire Barrier Docket No.: ' 50-220 Penetrations Page ILof.2 Event Date: . September 7,1984 Report Date: October 22, 1984

, ~

Licensee

Contact:

Robert G.'Randall .

Supervisor, Technical Support Telephone No: (315)349-2445 , , . .

ABSTRACT .

On September 7,1984, during normal operation, an . inspection was perfonned on the Smoke Purge Damper D16, elevation 250'. When the retaining angle fron was removed, insufficient Kaowool packing was observed producing e. gap between the damper and the concrete wall. This-penetration was declared ino compliance with Tech. Spec. 3.6.10.1, (Fire Barrier Penetration)perable . This system in was taken out of service and a fire watch patrol was: set up to perform an hourly inspection until this device could be repacked and put in service. Tech. Spec.

3.6.10.1.d requires a special report be submitted to the NRC~ if a fire barrier penetration is non-functional for mori than'14 ' days. This' event does not. -

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constitute an LER per 10 CFR 50.73. -

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TEXT  : .. - '4 u

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- On September 7,1984, during norma 1JopeiFation,.an inspstion was' p'efformed Smoke Purge Damper D16, elevatjon '250!. The preventive maintenance inspection

~

which was followed for this device sr procedure M1-FST-C6, "FTte'-t)aliiper Operation and Inspection of Tech. Spec. Dampers". T.his Smoke-PurgDamper;is a product of Safe Air Inc. Model No. 700-710. When the retaininf angle jronNas removed from around the smoke damper, insufficient Kaowool packing was' observed which produced a gap between the damper and the . concrete, wall. <.This penetration'was declared inoperable in compliance with Techni::a1 Spe.cification-3 6.10;1.d,-which states,

" Restore the non-functional fire barrier. penetrations to fuhetional status within 14 days or prepare and submit a report-in ac.cordance with~-6.9.2.b.". It was noted

. that the fire barrier penetration is adech; Spec. (tam.where the smoke purge ,

system is not. This system was innediately taken out of Service and a ' fire watch patrol was set up to perfom an houtly-inspection until this-device could -

be repacked and placed back in service 15 days;1atW../ This. event does not cons-titute an LER per 10 CFR 50.73.-' .: - . .,. ' % r.v.-

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Title:

Non-Functional Fire Barrier Doc'ket No.:

j 50-220

( Penetration Fage 2 of 2 l

CORRECTIVE ACTION The Smoke Purge Damper D16 was repacked with 7.2 lbs of Knowool, and the retaining angle iron was reinstalled. The staff members that were involved with exceeding i the 14 days limit were reinstructed on the importance of returning equipment to l service within the Technical Specification time limitations.

ASSESSMENT OF SAFETY CONSEQUENCES There were no potential safety consequences arising out of this event becau.se:

1) The fire damper was in the closed position throughout the period; 2) The fire patrol which was set up performed an hourly inspection to guard against a potential' fire.

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NIAGAR/s MOHAWK POWER CORPORATION  ;

J i NIAGARA MOHAWK soo inic eeutevano, west  !

synAcust. N. Y.13 303 j

l December 6,1984 l i

l United States Nuclear Regulatory Commission p i Vocument Control Dcsk **

• poes*'* ..

4 Washington, DC 20S55 . .,- >* 't \

RE: Docket No. S0:220 9 S SPECIAL REPORT U

'7 .

Gt.ntiemen:

In accordance with Technical Specification 3.6.10.1, we hereby submit i the following Special Report concerning fire barrier penetrations. 1 m Vchy truly yours a vn ad--

Thomas E. Lempges f

f Vice President \

Nacica Gt.ncration l 1

TEL/Lo cc: Dr. Thomas E. Marley Reg 40nat AdministAntive 1

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' 'SPECIAL' REP 0r,T i ., .

Title:

Non-Functional Fire Barrier Docket No.: 50-220 Penetrations Page 1 of 2 Event Dates: Oct. 12, 14, 18, & Nov. 6, 8, Nov. 12, & 19 Report Date: December 5,1984 Licensee

Contact:

Robert G. Randall Supervisor, Technical Support Telephone No.: (315)349-2445 ABSTRACT A number of fire barriers at Nine Mile Point 'Jnit #1 were declared inoperable

.- in compliance with Tech. Spec. 3.6.10.1 (Fire ' Barrier Penetrations). In each instance a fire watch patrol was established in accordance with Tech. Spec.

'"' to perform hourly inspections until the appropriate repairs could be made.

Tech. Spec. 3.6.10.1.d requires that a special report be submitted to the NRC for fire barrier penetrations which are non-functional for more than 14 days.

These events do not constitute an LER per 10 CFR 50.73.

TEXT,

'S Between October 23 and November 5. fYre barrier penetrations T-24. TG-9,

. TG-78, C-120, C-123, DP-6, and W-221 were identified as being inoperable in compliarce with Tech. Spec. 3.6.10.1. These penetrations were discovered during preventive maintenance inspections which are perfonned according to procedure N1-FST-C2, " Fire Barrier Penetration Fire Seals Inspection". They were declared inoperable in compliance with Tech. Spec. 3.6.10.1.d, which states, " Restore the non-functional fire barrier penetrations to functional status within 14 days or prepare and submit a report in accordance with 6.9.2.b".

Work requests followed by engineering repair determinations were generated for each penetration repair. However, the repairs were not completed within 14 days, thus requiring that a special report be submitted in accordance with Tech. Specs.

Fire barrier penetrations OG-3, OGT-32, and T-205 were identified as being I non-functional prior to October 23. These penetrations were also not repaired within 14 days, and in addition the 30 day reporting requirement allowed in Tech. Spec. 6.9.2.b has been exceeded. . {

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Qn Page CORRECTIVE ACTIONS ,e Occurence Reports are now being generated for all work requests involving fire barrier penetrations. This will increase tracking on fire' barrier repair progress, and ensure penetrations are repaired, and reports made within the Tech. Spec requirements. In each case the fire barrier penetration has been repaired and tested in accordance with the work requests and engineering determinations.

ASSESSMENT OF SAFETY CONSE00ENCES Because fire watch patrols were established in accordance with Tech. Spec.

no safety consequences arose as a result of these events. The fire watch patrols performed hourly inspections guarding against potential fires while the penetrations were non-functional. .

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NIAGARA MOHAWK QUALITY ASSURANCE AUDIT REPORT NINE MILE POINT NUCLEAR STATION UNIT #1 i LYCOMING, NEW YORK 12093 DATE: January 14, 1987 ufd k C u.M,d ah AUDIT NUMBER: SY-RG-IN-86020 f6r h o[dM d.,

1 ORGANIZATION AUDITED: Nine Mile Point Nuclear Station Unit il '

Nuclear Generation Department DATE OF AUDIT: December 8-12, 1986 j AUDIT TEAM MEMBERS Independent Consultant James D. Allen, FIREPRO, Inc.

Team Leader Norrel A. Chambers 2 Auditor E. M. Mike McDonnell I Technical Specialist James Sullivan 1.0 AUDIT SCOPE AND

SUMMARY

OF ACTIVITIES AUDITED This audit was performed to comply with Technical Specification Section 6.13.2 which requires an outside consultant to evaluate l

the fire protection systems and quality accurance programs every ,

three years. The audit evaluated the fire protection systems and i

('

program implementation to verify that fire safety commitments to the United States Nuclear Regulatory Commission continue to be '

satisfied.

Fifteen of the fifty-seven Appendix R fire zones were selected at random and toured during the audit. Thirteen fire doors were selected at random and examined for their fire rating and physical condition. Twenty-eight fire barrier penetrations were randomly selected and examined for their integrity and condition.

Randomly selected fire detection and suppression devices were examined for configuration, arrangement, and condition using BTP9.5.1 and appropriate NFPA codes as reference.

The control of transient combustibles and overall implementation of Administrative Procedure AP-3.5 Revision 0, " Station Fire Protection Progre.m", was also evaluated.

Forty-seven fire protection procedures were reviewed, and evidence of the implementation of fifteen procedures was reviewed. The 1983, 1984, and 1985 fire protection audits and associated recommendations were reviewed; thirty open items from three previous audits were reviewed.

A review of the Technical Specifications was performed. A comparison between these specifications and the procedures

( resulted in several questions which were satisfactorily answered during the audit.

FIREPRO File: 57N1782 Page 1 January 14, 1987

I

1. 0 AUDIX _ SCOPE AND

SUMMARY

OF ACTIVITIES AUDITED (CONTINUED)

The following documents were also reviewed during the audit:  !

o Fire Hazards Analysis by Gage ~3abcock Associates,  !

July 1,.1985 o Niagara Mohawk Power Corporation Nuclear Station Unit 1  ;

Appendix R Review Safe Shutdown Analysis Revision 1 l September 1, 1985 i o Gage Babcock and Associates Verification Report 3 covering the period of 1984 to 1986. -

'.0 2 gj32BBY OF AUDIT RESULTS i

Five During this audit, seven audit observations were generated. )

of these observations were resolved during the *udit and the two '

others resulted in issuance of CAR's 86.3096 anu 86.3097. The CARS have been transmitted for action under separate cover; <

l copies are attached to this report.

other suggestions and recommendations which do not constitute violations will be transmitted separately by the Independent j Consultant directly to Station Management. l

)

2.1 Procedure Feview and Innlementation The results of the following procedures were reviewed on site:

o N1-FPM-1 Supervisors Tour Several samples of this procedure were reviewed and

,found satisfactory, o N1-FPM-A2 Fire Protection System Annual Routine, Revision 0 )

It was noted'the Fire Protection Procedure #N1-FPM-A2 dated June 1986, Data Sheets 12 and 15 were not filled out as required. This was addressed on CAR #86.3097.

o N1-FST-A7 Halon System Puff Test, Revision 1 j The September 22, 1986 procedural result was reviewed.

No violations were identified.

o N1-FST-C6 Fire Damper Operation and Inspection, Revision 1 The auditors reviewed forms for several time periods and found no discrepancies.

C FIREPRO File: 57N1782 Page 2 January 14, 1987

2.1 Procedure Review and Implementation (CONTINUED)'

o N1-FST-C10 Fire Pump Flow Verification, Revision 1

( The auditors reviewed procedures for three different time periods and found them to be satisfactorily implemented.

o N1-FST-D1 Fire Door Inspection List of Doors, Revision 9 Ten different dates were reviewed. Procedure appears .

well implemented, although a few doors continue to have maintenance problems, and some doors have been out of la service for three months or more due to lack of parts to repair the self-closing devices.- No violations were iden.tified, o N1-FST-D2 Daily Low Pressure CO Surveillance 2

Inspection, Revision 3 The auditors checked September 19 to September 30, 1986 I procedural results and found them to be satisfactory. j The CARDOX tank and equipment was physically checked and found to be in satisfactory condition.

o N1-FST-sal Ionization, Photoelectric, Infra-red and Thermal Detection Test, Revision 4 The auditors reviewed July 30, 1986 results and found

( the procedure to be properly implemented. Each detector is checked by remote electronic verification I

from the control panel using a UL listed device.

Detector sensitivity is measured and recorded. The results are within the range of manufacturer's  !

requirements . )

I o N1-FST-SA8 Puff Test of CO 2 Hazards Semi-annual, Revision 1 The auditors reviewed the May 22, 1986 results and i found the test to be properly implemented.

o N1-FSR-W1 Weekly Fire System Valve Check-off, Revision 9 Six different weekly procedure forms were reviewed.

Valves that were documented as closed were addressed by issuance of a work request. (Documentation for follow-up of the shut valve condition through its resolution was not reviewed during the audit).

o AP-8.5 Housekeeping and Cleanliness Control, Revision 1 A site tour indicated that all arens had good to excellent housekeeping in the fifteen Appendix R zones

~

toured.

FIREPRO File: 57N1782 Page 3 January 14, 1987

2.1 Proc-6cro Review and Innlementation (CONTINUED)' j o N1-FPM-C5 Ionization, photoelectric and Thermal Detection in High Radiation Areas, Revision 2 The results of one semi-annual test procedure were reviewed by looking at the results of device tests. No violations were identified.

o N1-FPM-M1 Revision 10 Fire Protection System Fire Department Monthly Routine 4 January and February 1986 results were reviewed and were satisfactory. The procedute is being properly implemented.

o M1-FPM-SA2 Maintenance and Inspection of High Pressure CO Halon Revision 2 2 l 1

The auditors reviewed one set of documents and found l the procedures to appear properly implemented. J

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o NTP5 Fire Brigade Drill Training and Member Records, '

i Revision 1 The auditors reviewed training procedures and found them to be thorough; requirements of BTP9.5.1 were met.

2.2 Fire Zones The following fifteen Appendix R fire zones were toured and examined to verify compliance to the requirements of Appendix R:

R1A, R2A, R>B, R1B, T2B, D2A, D2B, D1A, D2D, R6A, D2C, C1, R4A, C2 and R3A.

. I Fire Break zones that were surveyed during this audit were found '

to be free of combustibles. The exception is the presence of one or two IEEE 383 insulated cables which may have passed through the Fire Break zone. These cables are not considered to be a significant fire loading or hazard.

No violations were identified.

2.3 Fire Doors The following thirteen fire doors were observed and examined for compliance with Appendix R requirements and BTP9.5.1:

' 132, 184, 243, 117, 56, 84, 149, 111, 108, 277, 110, 262, and 265.

Fire doors that were observed were in good condition except for two, which had problems with their closure devices. A work

(, request for repairs had baen written and the NRC was reportedly notified. 90 other problems were noted.

FIREPRO File: 57N1782 Page 4 January 14, 1987

2.4 Fire Barrier P+netrati,ns l The following twenty-eight fire barrier penetrations were observed to verify their integrity and condition:

OG20, P-7, P-27, P-28, P-29, P-11, P-22, D131, I1482, I1295, I1289, I1279, I1280, I1075, I1076, 11074, Il067, D30, D28, D85, D22, R60, C23, C20, C19, R154, R215, and R216.

No violations were identified.

l 2.5 Efre Drill and Fire Bricade ]

A fire drill was witnessed on 12/12/86 using Scenario (17. The drill was well executed and all requirements were met. j

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The plant fire brigade program, training ready drill report and l fire incident reports were reviewed. The training records of i five randomly selected fire brigade members were reviewed. The records indicated that the five members reviewed had been trained in accordance with the procedure. No problems were noted.

2.6 Ouality Assurance Program for Fire Protection The Fire Protection Qualit.y Assurance Program dated October 28, 1983 was reviewed for conformance to USNRC BTP9.5.1. The program tracks the requirements very closely and appears to be adequate.

The Program and implementing procedures are vagus, however, with

. regard to responsibility and procedure identification. This

( concern was brought to the attention of QA Department management during the audit, and appropriate steps were initiated to review and revise the Program and implementing procedures as necessary.

In addition it was noted that NMPC Purchase Requisition #86001136 was submitted to the NMPC Purchasing Department with attached acceptable Attest Form and later changed without the use of the Attest Form. It was determined, however, that thu ultimate contractor used was on the QA Department Qualified Contractors i List, thus assuring vendor adequacy. Procurement controls will also be reassessed during the review of the Fire Protection QA Program, as discussed above.

The Nuclear Quality Assurance Operations Section performed fifteen (15) fire protection surveillance during 1986, resulting in two (2) NCR's (Nonconformance Reports) and six (6) CAR's (Corrective Action Requests). This surveillance coverage was felt by the auditors to be adequate and effective.

2.7 Previous Audit Findinas There are no NMPC QA Department audit findings open from previous audits.

The outstanding recommendations from the internal NMPC 1985 audit (5RAB Audit I) were reviewed. None of the recommendations

(. resulting from this audit have been addressed to date. Many are administrative in nature and none appear to be safety related.

FIREPRO File: 57N1782 Page 5 January 14, 1987

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2.7 Previous Audit Findinca (CONTINUED)-

The 1984 audit (Gage Babcock Report) identified 169 open items.

' Five items remain open, and these have been identified as CAR l{

\ #86.3096.

The 1983 outside audit consultant recommendations were reviewed.

One recommendation remains open. This recommendation discusses the application of fire retardant material to new cables that are added to existing cable trays. This issue will be carried l forward internally by the Niagara Mohawk Engineering Department.

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3 .0 EFFECTIVENESS -

Niagara Mohawk Power Corporation Nine Mile Point Unit 1 appears to be meeting.USNRC requirements and agreements, and has properly.

implemented the fire protection program procedures. The plant has a good level of fire safety commensurate with the hazards.-

The NMPC Quality Assurance Department is doing a satisfactory job of monitoring the fire protection systems, and is meeting or in some cases exceeding Fire Protection QA Program requirements.

The Fire Protection Quality Assurance Program is being addressed internally and will.be improved as previously discussed. J Housekeeping and control of transient combustibles was very good throughout the plant. The fire loads have not changed nor do l they present any greater exposure than those that previously existed. The review of procedural results and a physical plant tour indicates that the fire protection program and the* quality

( assurance activities meet or exceed United States Nuclear Regulatory Commission requirements.

2 4.0 PERSONNEL CONTACR Q NAME OF PERSON CODE TITLE K. Shea 2' Quality Assurance 1 M. DeMassi 2 Stores l S. Queen 2 Stores K. Daniels 2 Quality Assurance N. Donohue 2 Quality Assurance J. Pavel 3 Asst. to VP Nuclear Generation T. Roman 3 Station Supt. Unit 1 W. Connolly 3 Quality Assurance Program Manager Unit 1 J. Buckley 3 Supervisor Quality Control D. Kehoe 1,2,3 Fire Training Specialist J. Corcoran 3 System Fire Protection Engr.

W. Hansen ~

2 Quality Assurance M. Kammer 1,2,3 Supv. Fire Protection Unit 1 i A. Psaros 1,2,3 Fire Protection Engr.

D. McNally 1,2,3 Unit Fire Protection l J. Oxford 3 Fire Training Specialist l l l FIREPRO File: 57N1782 Page 6 January 14, 1987 j l

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4.0 PERSONNEL COQ 7 ACTE) 3 CONTINUED)

' NAME OF PERSOl{ -

$QQE' TITLE f ,

s .T. Perkins. 1,2,3 Asst. Supv. Fire Protection Unit 1 i J. Woodruff 3' Shift Supv. NMP2 I W. Drews 1 Tech. Supt. . Site

! J. Dillon 1 Senior Supv.-QA Audits CODE 1 - Attended Pre-Audit Confer 4:nce 2 Contacted during the Audit 3 - Attended t.he Post-Audit Conference

• l Prepared By: j N4 h L J. D. '/dlen q Censultant i FIREPRO Incorporate )

/ I Reviewed By: / l

' /T.A.ChambQs' Lead Auditor Reviewed By: we( Ma  !

A . L. Dillon i

/ Senior Supervisor  !

QA Audits  !

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9 k .l FIREPRO File: 57N1782 Page 7 January 14, 1997

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M.C. Ka==er Acting Site Supervisor aryttst :;30;;;*s: (semrementre:clationi 3 Fire Protection Qua.lity Assurance Program date 10/28/83, section 2.2 - Ceteral purpose, state in part, "The progran provides that, as early as possible, ,

discrepancies (defects and program deficiencies) shall; be discovered and i corrective action taken.

. Contrary to the above, a review of discrepancies which were identified in the 1984 Fire Protection Audit (Gage Babcock & Associates Inc. Report) revealed that I no corrective action was taken on the following itens:

/mv~mw sN17;A*~A:20,6 483104'" it:3 sr, A'e -- a t o s -% .:.5 sten / ' c' 6te/L-U+@ sign _ %C.d. j, , f 1/g[g a[vtru r:a @ / V 5 ya Q at;:ntasgLITY: tts C e Ct atttttxt w stt: _

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! 8E58CNis: (Incluce cf.eckec items in ycur res:cnse: O ccrrec:tve action O action taken 0 to assure cuality of items affectec price to discovery, cause and action te )

prevent recurrence.)

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3 W. Bryant, B. Madison, J. Dille.. ~. A*'.*:.

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PCR EACH ENTRY Indicate block atnaber bal.ng conricued, sign And date entry.

.azDc4 ENTRT.SicxATt?RE. s Dart 9

1. 044 . ( Bldg. Elv 298 Csble trays w/o detection (a)

(b) #056 - Rx Bldg. Elv 261' 281' Additional cables in trays ovat P3's not sprayed.

(c) #095 - Turb. Bldg. - E1. 277' Safety related cable trays v/o detection I e

l (d) #129 - Rx Bldg. - El 261 Bus duct penetrates stair enclosure & not sealed l Col. L-11 I (e) #133 '- Turb. Bldg.-E1 250' Plastic pipes penetrating floors & valls (rated) and act sealed.

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n:t:A;:n s :st.Amt:A;;:n: r Syracuse Corp. Audie veta: CAR-36.2097 ,

L::n::w: Syracuse. F-2  !

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sas t;,c.ta. a ra;g class di'iiini

@1TCPscaKORCER CA SOURCE OCC2 [Nis et.atts 00 0 Dr!!! ' F..-

( .ts c'T *e cx F49 N/A @ S e e Sk . 9 '!! C '*C E 50. -" 'g Audit #SY-RC-TN-36020 at3;;hsih! C80AaliA*1C" e i"Ci'li'#';

I Fire Protecticu Progra= NMP-1 -

M.C. Kat:ner. Acting Site Supervisor acvtAst C;m0!!I;M: (R* m r'4*atn '*ldt28"8 2 NMP-1 Fire Protection Procedure N1-FPM-A2 data sheet 12 & 15 requires test data to be entered on the data sheets during the System Annual Fire Department Routine Test. *

~ Contrary to the above. Procedure fN1-FPM-A2 dated June 1986, data sheets 12 & 15 i i

section 7.3.4. 7.4.2 - Torque switch setpoints were not co=pletely filled out as required.

NOTE: See Attachnent for Engineering ipput on torque switches. O (str;a:;a: 5 '

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,... Noriel Chambers g,,,, - ., ,, a. n .fg g,,, ym c_Q . ., j7 (t,(g ,

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(Incluce cr.eckec items irt your rescense: O correctiv 8 ction C action tanen l

@ to assure cuality cf items affected price to cisc:very, cause and action to  !

prevent recurrence.)

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,,,,, :s $11y isolt eates:

AC'I7?AaCI:g IMFLi %1 tai!OM COMPLETE: @

ate $fgn !a*e

(,. Site iui;I: r 3 .usts at: g stea *a:e  !!:n . 78 "

a t.-as si : .q,  ::sta tssi;;N: W. F.ansen

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B. Madison J :) m an J. Allen (Firepto)., .

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SUBJECT lE Inf ormat ion .%t ice 3!..gg 741-7/47 - m

.wa t.. , n n..ra c c a v..t w r n eq u e ,

f Swit claus Belv.# PLinu t .act u re r 's -

Recommended Value Ple..se review the above b'ulletin and provide torque switch setpointa

, for all operated valves. .

In addition to reviewing valves for torque switch settinas. plenne review gar the following datat (1) Thrust Torce ; , ,, ,

i (2) t.init Switch Setpoints j n e thrust force data vov1d be used to e.ompare to actual data obtained during mvA:s testing. The limit switch setpoint would be used to . I verify actual setpoints. ne - following 'dif ferences have been noted:

. (1) cs certsin containment isolation valves, the open torque' rwitch has been bypassed by a limit switch until the valve is a.laset hlly . closed. Norma.1.ly, this switch .is hypassed only for the first IC: of' valve streke.

(2) On t.se dryvall and torus vent & purge IV's . the opes limit

(. switch is set to be &C* cf full open as indicated in an NRC bullecin (ex. Valrc 20107).

The folleving is also requested to be reviewed:

~~'(1) om buttarfYvalves with limitorque EBC operators, the

.' '.-' ' " ' ' - ~

c strol' ciresit clases the valve on torque against a ,

sechanical stop in the KBC operator. Limitorque reco:m= ends-thac they close on limit, which requires a control ciregic '

chs a ge. This may also apply en other valves.*

, (2) na Fire Departzent raquested that che open torque .

switches for foam / vater and vatar spray Limitorque operators be set on saximum value. ,

J ne setpoints should be included na a controlled doc.:nent. preferrably, the elementary diagrame. Aceval valve settings and NOVATS sign.stures are available for your use on most safety related valves.

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3 NIAGARAN0NARPOWERCORPORAIl0N FIREBARRIERPENETRkil0N PRESENTATION JULY 11,1988 1

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s AGENDA Introduction-J.M.Endries Background.ofFireProtectionProgras-G.J.Gresock StatusofCurrentProgram-P.J.Finnerty SafetySignificance-G.J.Gresock RootCauseEvaluations-P.J.Finnerty CorrectiveActions-P.J.Finnerty OverallRootCauses-0.D. Terry

' i EvaluationofOther.Prograss-G.J.Gresock ConcludingRemarks-C.D. Terry l

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FIREBARRIERPENETRATIONREVIEWPROGRAM l EventDescription  !

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On March 26,1988, six nonconforming fire barrier .i penetrationswerediscoveredandreartedviaLER88-09, 4

Basedonthisdiscovery,additionalinspectionswere arforwJwhichidentifiedadditionalnonconformingfire .

barrieranetrations,leadingtoa100% walk-downofall l requiredbarriers.

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FIRE BARP.IER PENETRATION REVIEW PROGRAM CURRENT PROGRAM DESCRIPTION O PERFORM A VISUAL (NONDESTRUCTIVE EXAMINATION) 0F 100% ,

OF THE PENETRATIONS THROUGH REQUIRED BARRIERS AND ,

REWORK PENETRATIONS CONSISTENT WITH DESIGN l REQUIREMENTS.

O PERFORM A DESTRUCTIVE EXAMINATION AND REWORK OF f PENETRATIONS, WHICH'THROUGH DRAWING'RESEARCH, ARE CONSIDERED QUESTIONABLE.

O VIA A STATISTICAL SAMPLING PLAN, PERFORM A DESTRUCTIVE EXAMINATION AND REWORK OF THE REMAINING PENETRATIONS. .l l

i l

?

1 FIRE BARRIER PENETRATION REVIEW PROGRAM l

TYPE OF PENETRATIONS WITH A QUESTIONABLE FIRE RATING O PENETRATIONS CONTAINING WOOD PLUGS l 0 PENETRATIONS WITH MORTAR DEFICIENCIES 0 PENETRATIONS CONTAINING PLASTIC PIPEE ,

l l

0 OPEN PENETRATIONS 0 PENETRATIONS CONTAINING ONLY Duct SEAL / PUTTY 0 OVERSIZED PENETRATIONS O PENETRATIONS WITH KA0 WOOL DEFICIENCIES i

l

MUHI AH DEFICIENCIES (6 1/2') . (6 1/2')

Y? X-Y? Y? X-'Y?

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. SAFETY SIGNIFICANCE 0 -

CRITERIA 0F 3 HOUR BARRIER CONSERVATIVE HAVE NOT TAKEN CREDIT FOR DETECTORS AND SUPPRESSION IN MANY AREAS LIKELY JUSTIFY LOWER RATING 0 FIRE HAZARDS ANALYSIS O SAFE SHUTDOWN ANALYSIS

@ BARRIER PENETRATIONS PROVIDED A LEVEL OF PROTECTION O BARRIERS NOT THE .ONLY PP'JTECTION DETECTORS DEDICATED FIRE BRIGADE WITH MANUAL SUPPRESSION IN MOST AREAS, AUTOMATICALLY INITIALLY SUPPRESSION O REDUNDANT TRAINS SAFE SHUTDOWN CAPABILITIES 0 2 SHUTDOWN PANELS 0 4 CORE SPRAY SYSTEMS R 0 2 EMERGENCY CONDENSER TRAINS l l

0 2 SHUTDOWN SUPERVISORY CONTROL SYSTEMS' j i .  ;

O CONCLUSION TO DATE SAFE SHUTDOWN CAPABILITIES NOT JEOPARDIZED

- APPENDIX R, SECTION III.G COMPLIANCE i

i

o a

~

FIRE BARRIER PENETRATIQH SPECIFIC CAUSES' O INCOMPLETE DRAWING RESEARCH O PREVIOUS WALK-DOWN TEAMS LACKED AN INDOCTRINATION  !

WITH THE UNIT-1 DESIGN DATA BASE

~

O THE FIRE DEPARTMENT SURVEILLANCE PROCEDURE ONLY REQUIRED INSPECTION BY PENETRATION DETAIL 0 ADEQUATE INSTRUCTIONS WERE NOT'PROVIDED BY o ENGINEERING TO INVESTIGATE POTENTIAL DEVIATIONS  !

DURING THE 1985 - 1986 TIME FRAME '{

)

O LACK OF A FOLLOW-UP TO THE INITIAL IDENTIFICATION OF A WOOD PLUG (JUNE 1981) AND LACK OF A FOLLOW-UP-TO THE GAGE-BABCOCK AUDIT (1984 - 1986) l l

0 LACK OF A PROPER UNDERSTANDING BY DESIGN AND STATION PERSONNEL OF WHAT CONSTITUTES A DEGRADATION OF A FIRE BARRIER O PRESENT AND PAST PENETRATION SEALING DETAIL DRAWINGS DO NOT PROVIDE ADEQUATE INSTRUCTIONS 1

l i

i I

4

ROOTCAUSEPROCESS SpecificCausesofPenetrationDeviations Keyer-TregoeSystematicEvaluation Programmatic Causes of Penetration Deviations HPES OverallRootCauses l

i i

FIREBARRIERPENETRA!!0N PrgraaticCauses Niagara Mohawk did not recognize the scope, impact and  :

implementation requirements of the comitment 4

l Lack of an integrated program plan and definition of .

~

)

resznsibilities Penetration design data base not maintained Assumed the UL test program / Engineering evaluations  ;

encompassed all existing penetration configurations l

l

FIRE BARRIER PENETRATTAN 0VERALL' ROOT CAUSE

@ LACK OF MANAGEMENT ATTENTION AND DIRECTION-IN:

IMPLEMENTING COMMITMENTS RELATING TO FIRE BARRIER PENETRATIONS LACK OF ADEQUATE PROCEDURES AND DOCUMENTATION RELATING TO CONTROL OF FIRE BARRIERS-

- LACK OF INDIVIDUALS' APPRECIATION AND UNDER, STANDING OF FIRE BARRIER COf94ITMENTS 9

FIRE BARRIER PENETRATION REVIEW PROGRAM

_ CORRECTIVE ACIl0E SCHEDULE INITIATION OF COMPENSATORY MEASURES COMPLETED-ASSIGNMENT-0F A TASK NANAGER COMPLETED REVIEW OF PLANT SPECIFIC NRC COMMITMENTS COMPLETED REVISION OF. DRAWING CONTROL PROCEDURES COMPLETED PERFORMANCE OF ROOT CAUSE EVALUATIONS ' COMPLETED.

PERFORMANCE OF WALK-DOWNS OF REQUIRED COMPLETED REWORK OF REQUIRED BARRIER PENETRATIONS PRIOR TO STARTUP REWRITING OF SURVEILLANCE PROCEDURE PRIOR TO USE UPGRADING OF PENETRATION DESIGN DATA BASE ' PRIOR TO STARTUP REVIEW, REVISE AND ISSUE EXISTING FIRE PROTECTION PROGRAM PLANS AND PROCEDURES ONGOING PERFORMANCE Or TRAINING ONGOING l

l

CONTRIBUTINGFACTORSTOOVERALLROOTCAUSES Malor E" fort Plantedifications Fieldwalk-downs Analysis Severe Tim 00nstraints leasedoverday-to-dayoxrations Inariodsofheavyworkload EvolvingCriteria Interpretation NR0 direction

~

i 1

. i l

FIRE BARRIER PENETRATION REVIEW PROGRAM i

RgsuLTS or WALx-downs 1 o PERCENTAGE'0F REQUIRED BARRIER PENETRATIONS OBSERVED 100%

~

o ESTIMATED PERCENTAGE OF PENETRATIONS WITH

~

10 DISCREPANCIES 42.1%

o ESTIMATED PERCENTAGE OF PENETRATIONS WITH -

ONLY FLAMEMASTIC (COSMETIC) DEFICIENCIES 35.2%  ;

o ESTIMATED PERCENTAGE OF PENETRATIONS THAT REQUIRE FURTHER ANALYSIS 22.7%

o ESTIMATED PERCENTAGE OF PENETRATIONS THAT i WILL NOT BE CAPABLE OF MAINTAINING THE FIRE BARRIER'S RATING < 1%

l l

l 4

- R00r'~t usis IN THE FUTURE 1

'O UNDERSTANDING COMMITMENT INITIAL ASSESSMENT OF SEVERITY OF' ISSUE ANYTHING QUESTIONABLE - EVALUATED FURTHER BY NUCLEAR DIVISION MANAGEMENT

- TASK MANAGER ASSIGNED TO DEFINE SCOPE, RESPONSIBILITIES, RESOURCES AND SCHEDULE PRIOR TO COMMITMENT i

O CLEAR ROLES AND ACCOUNTABILITY NUCLEAR DIVISION REORGANIZATION .

NUCLEAR COMMITMENT TRACKING

@ DESIGN DATA BASE DESIGN DATA BASE RECONSTITUTION i

DEVELOP FYSTEM DESIGN BASIS DOCUMENTS INCLUDES RECOVERY OF EXISTING DESIGN DOCUMENTS ~

IMPROVEMENTS TO THE CONFIGURATION MANAGEMENT SYSTEM i l

c PROCEDURES j LONG-TERM PROGRAM TO IMPROVE j 0 ADMINISTRATIVE PROCEDURE l O NUCLEAR ENGINEERING & LICENSING O RADIATION PROTECTION i

DESIGN DATA BASE RE23 TIT liTl0N  !

' I Preliminary Plan Designcriteriadoceentstobedeveload i

InterpretLicensingBasis ]

Designcodes Designin)uts Loaddefinitionsandcombinations Acce)tancecriteria Deveio) System Design Basis Documents Describe Design 0xration Maintenance

' Reiabilityfeatures includes  ;

i RecoveryofexistingDesigndocaents EnhancementofexistingConfigurationManagment Systm l

~

]

/

EVALUATION OF OTHER PROGRAMS METHODOLOGY l- Identify Other Major' Programs / Projects 1977-1986 (Selection Process) l Does a Program / Project Do Not.

Satisfy Two or More of Consider the Contributing Factors NO Further (Screening process)

YES Evaluate Programmatic Causes-i Are there Indications Do Not That Programmatic Causes Consider May Have Been Present NO - . Further (Evaluation Process)

YES 1

Ao!ress Program / Project.  !'

'(Verification Process) i Conclusion l l

1 l

l 1

- j

~

l i,

CONCLUSIONS O WITH THE FOLLOWING EXCEPTIONS, HAVE NOT IDENTIFIED  !

SIMILAR SITUATION IN OTHER PROGRAMS I O UNERIC LETTER 83-28 NEEDs FURTHER EVALUATION )

o BTP 9.5-1 NEEDS FURTHER EVALUATION I o ISI l

1

SUMMARY

0 EXTENSIVE FIRE PROTECTION PROGRAM AT NINE MILE POINT UNIT 1 0 NMPC IDENTIFIED BARRIER PROBLEMS - INITIATED THOROUGH REVIEW WITH MANAGEMENT OVERSIGHT 0 PLANT SAFETY NOT JEOPARDIZED MULTIPLE PROTECTION FEATURES MOST PENETRATIONS FULLY OPERABLE - OTHERS PROVIDE A MEASURE OF PROTECTION O THOROUGH ROOT CAUSE AND CORRECTIVE ACTION REVIEW EVOLVING PROGRAM AFFECTING MULTIPLE

. DISCIPLINES PENETRATIONS AET REQUIREMENTS AT TIME OF INSTALLATION INFORMATION NOTICE 8-04 o PENETRATIONS WILL BE CONSISTENT WITu DESIGN REQUIREMENTS BEFORE RESTART l

E5;G4 FEATURES .-

t

~n e north, east and west boundsries on both elevations consist of B" thick block walls (2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> interior fire cut-off). A portion of the south boundary consists of a 115/8" CMU block wall adjoining zone F1 (3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire cut-off).

The south wall-is 8" thick insulated precast concrete wall panels (3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire cut-off).

The floor on elevations 261' is reinforced concrete approximately l' 1/2" feet thick (3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire cut-off)

The ceiling, approximately 9' - 4" high, is reinforced concrete approximately 7" thick (1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> fire cut-off).

Cables which penetrate the floor are sealed with 3-hour rated seals.

Class "A" fire' door are installed between fire zones T3B.

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DE.5 }G'i FE AT J:tE S The zor,e is bounced on the east side by a 2' reinforced concrete wall with I' square blocked up operings; on the west side by a 3' reinforced concrete wall with l' square blocked up openings; and on the south side by a 2' reinforced j concrete wall with blocked up openings (3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire cut-off).

The north boundary is provided by a 2' reinforced concrete wall of the diesel generator room and a 115/8" haydite concrete block wall (3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire cet-off).

The ceiling is 9' - 41/2" high and is compcsed of reinforced concrete l' - 7 1/2" thick. Cable penetrations through the ceiling are sealed with a 3-hour rated seal (3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire cut-off).

Cables and pipes which breach the wall boundaries are sealed with a 3-hour ,

rated seal.

Class A fire dccrs are installed between fire zcne T2B and T20.

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DES'Gfi FEATURES The north, south, east and west boundaries consist of 12" thick block walls (3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire cut-off).

The floor consists of l'-6" thick reinforced concrete (3' hour fire cut-off).

The ceiling is approximately 15'-5" high and consists of 3-1/2" thick reinforced concrete supported on exposed steel (non-rated).

Two Class A fire doors are located at the south wall between Zone C2 and T3B.

A Class A fire door is located at the north wall between Zone C2 and T3A.

Located in the northwest corner of this zone is an enclosed stairway (2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> fire cut-off) with a Class 5 raitd fire door separating zone C2 from C3. ,

Cabics and pipes which breech the walls of this zone are scaled with 3-hour rated seals.

Ca61:s ed pipes which penetrate the floor of this zcne are sealed with 3-hour I rated scals.

Cables Srd pipes nhich penetrate the ceiling are previded with fire stops.

Sep5r6te socke reecval capability is prcvided for this zor.e via a rated fire * '

damper ar.d an emergency exhaust f an.

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L- _ -------------_ I

DE5;GN FEATURES i i

ihe north and south boundaries consist of l' - 0" thick block walls and 8" thick precast wall panels (3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire cut-off).

The west beundary consists of a 2'-0" thick concrete shield wall up to elevation 277'-0" then a l'-6" block wall (3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire cut-off).

The east boundary consists of insulated metal wall panels (no exposure). ,

The floor consists of a l'-6" thick concrete slab.

The roof is 35' high and consists of reinforced metal roofing on protected ,

supporting steel.

Alorg the west boundary, approximately 10' above elevation 261' is zone D3 which runs the entire length of the west boundary of zcne D2A.  ;

Cable ar,d pipe penetrations that breach the walls are sealed with 3-hur r*.ted icels.

l Cliss A fire doors are installed between fire zones 02A-D2B and D2A i3A.  !

The ficcr is opan to E'1. 250'-0" fire zone 01 A via the generator fct.ncation stile spice and blockout for ger,erator leads.

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• e.newessa = M wasI3mmanswees y

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OTTTI D2A , [

J]dTTil DIESEL GENERATOR AR5A, FL. EL. 261'-O" ,

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• INST. (  ;

ISHOP ' [}

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. 9 t&te : (F >

APPENDIX EA BB-IR

, s Documentation Quality control Checklist Where located' lInsp Information JRept

!i Conf Rept l l Draft l Draft lCoverl .I i Nov l Ltr- IMemo 10ther  !

I I I l l l l 4

-B.I. What was the requirement and, l l- l l l l l 1

If the requirement was l~ l l .l l l l conditional, how were the l l l l l l l conditions satisfied which made' l l l l l j. l the requirement applicable? J J [ l J l l 1 B.2. How the requirement was violated? .I l l l / l l

l l /#'[.UJ l l 3 I I I I I  !

B.3. When the requirement was l l l

violated and what was the duration of the violation?

l j

l l

l l

l l-l lpfg l

l l [ .I l- l l I /t .I ;I l l l il B.4. Who caused the violation? J V l 1 l l l l B.S. How and by whom (be specific) was the violation discovered? l

]I l l l l l -j  ;

I I I I B.6. Was the violation required to I i l

.l /l l [ .) l be reported and, if so, what l  ;

/ ll l l l l was the applicable reporting l. l l l l l l requirement? l J , l l l l l B.7. Was the violation reported and, is so, when and by whom was it l l l l _l l l l l l )

reported? l l l l  ;

l l l I I I I I l B.B. If the violation was reported, I I l

but the report was late, why was the report late?

J l /)l l l

l l

l l

l l l_

l l

l l g l ,

l l 1 1 I I i B.9. Was the report complete and l l  ;

l l l l l l  !

accurate? l J l l l l l l

~l

/t I i l i B.10. Were there multiple examples l /l l l l

l cf the violation? I l l l l l

l l

l l

' Place an "X" in the appropriate column (s) or N/A if the issue is applicable to the case. When an issue is N/A'd, the supporting documentation will support the conclusion that the issue is not applicable.

,)

Od"

Where Located * ,.

. lInsp l Conf l Draft l Draft lCoverl l Information JRept i Rept i Nov I Ltr IMemo 10ther  !

l l l l l l >

l B.11. What was the apparent root  ! l l l l l l cause and contributing casual l l l l l l l factors for the violation? l I I l l ~l l l l l l l l l  !

B.12. Describe any facts and l l l l l l/ l j circumstances that address the l l l l l l/V l ( ;

aspects of negligence, careless l disregard, willfulness and l l

l l

l l

l l l

ll g,p/ l

)

l management involvement. 1 I I I l l l l B.13. Was there economic or other l l l l l  !

personal or corportte gain l l l l l lA j associated with the violation? I' l l l l l 'T-[. j l - l l l l l l B.14. What were the opportunities l l l l [ / [ l and when did they exist for l /,/j licensee staff and management l l l l l

l l

7l/ l l

l l

1 l

to be aware of the violation? l I l l l l l  !

l l l l l l - l B.15. What were the circumstances l l l l l l l 4 surrounding the violation, such l l l l l /l l i as system configuration and l l l l l l l '/ l ,

operational conditions for l l l l l l l reactor cases, which effect the l l l l l l l significance of the violation? l I l l l l l  ;

I l l l l l  ;

B.16. Is the violation indicative of programmatic problems or is it an isola ted case?

I l

I I l

l l l l l flj l l l

I l l l l l l l l l l l B.17. What short term corrective and l l l l l l l remedial action was taken and l / l l l l l l when was it taken? I l l l l l l 1 l l l l l l B.18. Did NRC have to intervene to l l l .) l l l accomplish satisfactory short l l l l l l l term correction and remedial l l l l l l l action? l I I I I l j l l l l l 1 l S.19. Were there previous similar NRC l l l l l l inspection or licensee audit l l l l l findings and, if so, should the l l l l l l l corrective actions from those l l l l l l l findings have prevented this l l l , l l l l violation? J l l l l l l 2

i l

I Where Located * ,  ;

!!nsp l Conf I Draft l Draft l Cover l l I

_Information j R_ep_t i Rept i Nov i Ltr IMemo 10ther l_ i l l l l C.). List the enforcement conference l l l l attendees from the NRC and l l l l l

l l P.1/ 4 '

lp/

Itcensee.  ! 1 l l l l g/44 '

I l i I l l l C.2. Describe additions or l l l l l ll hl / // fe l

corrections to the factual l l l l l information in the inspection l l l l l l report. 1 I l l 1 1 l l l l l l l C.3. If the Itcensee takes issue with l l l l l lJ4t/f(l the violations, de, scribe the l l l l l l fpiM F licensee position. 1 l l l l fl 1 1 I I I l 1 l

C.4. Describe any additional information which effects the regulatory or safety significance of each violation.

l l

I l

l l

l l

l l

l l

l l

((l/ l l

l l

lt l l

l l l l l l l i I I I I I 1 C.S. Describe any additional l l l l l l  !

l information on correction and l l l l .l lt t l

j remedial action the licensee l l l l l l l has implemented has committed l l l l l l l to implement. 1 I l l l l l 1 1 I I I I l D.3. A concise, clear statement of l l l /l l l l the requirement appropriately referenced, paraphrased or l l l / l l l g ll l l l l l l l quoted. . l l l l l l l l 1 i i i l I i D.2. A brief statement of the l l l l l g g circumstances of the. violation l l l l l including the dates of the l l l l /ll l l violation and the facts necessaryl l l l v/ j l l to demonstrate that one or more l l , l- l l l l elements of the requirements werel l l l l l l not met. I i l l l l  !

l D.3 The severity level proposed for l the violation. I 1 l

l l

l vl / l l l l

l l

1 l l l l l l D.4. The civil penalty proposed for l l l l J lg; the violation. 1 l l l l l l I l I i /l l l l E.1. When, where, and by whom an inspection was conducted.

l I

l l

l l /l l l l l l l l l

1 3

l

I

~

Where Located *' ,

l lInsp l Conf l Draft l Draft l Cover l l Information ,l R_ejLt i Rept i Nov i Ltr IMemo 10ther I I l .I l l l E.2. When and where an enforcement l l l l. /l l l conference was conducted and l l l l /l l l who wera the lead NRC and l l l l l l- ~l licensee representatives. 1 1 1 I l l l 1 I I I l l E.3 When reports of the inspection and enforcement conference l

l l

l l l /ll l l l l v' l l l results were provided to the l l l -l l l l licensee. I I I I I I l 1 1 I I l l l .

E.4. A description of the violations, I l l l l l l including who identified the l l l l l violations, and the apparent l l_ l l l l -l root cause of the violations, I l l j l l l and any other major attributes ofl l l l l -l. [

the violations necessary to l l l l l l. l support the safety and regulatory l l l l l- l l significance of the violations. I l l l l l l l 1 I l l- l E.5. A statement of the results l l l l l l which we expect to achieve through issuance of the l

l l

l l l' l l

l l

/l l 1 l l proposed enforcement action l l l l l l l focusing on correction of the l l l l l l l underlying problems disclosed l l l l l l l by the violation. I i l l l l l ,

I I I i l l l E.6. A description of the proposed l l l l l l l enforcement sanctions including severity level and civil penalty l l l l l l

l l l l

/ll l l

l valve. I _1 1 I I l l l 1 1 I I I l 1 E.7. An analysis of any factors whien l l l l l l  !

caused the severity level to be l different from the normal severity level-for the type of l

l l

l l

l l

/l l l l

[  :

involved violations, for example )

l l l

l l

l l

/ llg l l

l l

j programmatic aspects, or l l l l l l l willfulness. 1 I I I I ,

l 4

l l l l l  !

E.8. An analysis of any factors which l l F l l l l caused the civil penalty valve l l l l l l l to be different than the base l l l l l l l valve for that severity level l l l l l l l violation. 1 I I ~1 1 1 l 4

Where located *  %

lInsp l Conf l Draft l Draft l Cover l l pformation JRept i Rept i Nov,I Ltr 1 Memo 10ther F.1. The Enforcement Action (EA) l l /l l l number. I l l I /l l l l l l l / l l l F.2. The referenced inspection m l l l l Jl l l report numbers. I I I I I i l F.3. A summary of the nature of l l l l the violation (s). I l I l I l l l l 1 l l l I F.4. A summary of the root l l l l /l l l -

cause(s)/ problem area (s) l l l l l l represented by the violation (s). j i i l V ll l l l 1 l l 1 I l F.5. A description of the regulatory l l l l l l l and Technical Safety significance l l l l j l of the violation (s)/ problem l l l l / /ll l area (s), including l l l l l considerations such as l l j l /ll_/ ll l operational configuration, l l l l l l l supervision / management l l l l l l l invohement and willfulne,s. l l _l 1 l l  !

! l l l l l I F.6. A description of the purpose of l l l l l l l the enforcement action and the l l l l l l l message we intend to send to the l l l l l l l licensee and industry. l l l l l l l l 1 1 I l l 1 F.7. A description of the rationale l l l for the rece: amended severity l

l l

l l

l l l /ll l 1evel and grouping of the violations including reference l l l l lJl l l .l l l l l l to the relevant sections of the l l l l l l l Enforcement Policy and OE l l l l l l l guidance and prior EA's. I I I I  ! 1 l 1 1 I l l l l F.8 A description of the rationale l l l l l for the recommended civil l l l l'.

l l l penalty addressing all five l l l l l l l Enforcement Policy escalation l l l l / l l l and mitigation factors as well as] l l l l l l l

duration, willfulness, ability tol l l l l l l pay, and prior EA's which are l l l l l l l similar. I i l l l l l l 1 l l l l l 5

Where Located * ,,

lInsp l Conf l Draft l Draft l Cover l l '

.- Information h l Rept i Nov i Ltr IMemo 10ther l l I l l l l F.9 An analysis of the licensee's l l l l l g l 1

position on any aspect of the l l l l l l l violations or application of l l l g j l l l the Enforcement Policy to l l l l l l l l those violations which is in l l l l l l l 1

substantial disagreement with the regional proposal.

l 1

l I

l l l l l v/ l l l l l 1 l i I I i l F.10 The Regional Counsel's view of l l l l l l l the legal aspects and l l l l l l risk associated with the proposed action and the l l l l

l l l l l[k,Ap l l l

advisability of OGC review of l l l l l pN j l the proposed action. 1 I l l l y l 1 l I I i l l F.11 Any othar regulatory framework l l l l l l l factors that need to be l l l l l l l t

considered in review of the l l l l l l j case; such as, pending licensing l l l l l l l issuance or renewal action, and l l l l l l l commission meetings. l l l l l l I

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. 475 ALLENoALE CAD .

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• ,* KINO CF P".USslA, PENN6YLVANIA 19406

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07 JUN 1988 j EA No.88-152  !

Docket No. 50-220 Docket No. 50-410 l Niagara Mohawk Power Corporation  !

l ATTN: Mr. Charles V. Mangan 1

Senior Vice President - Nuclear 301 Plainfield Road Syracuse, New York 13212 i l

Gentlemen:

Subject:

Inspection Peport No. 50-220/88-15 and 50-410/88-15 1 This letter transmits the results of the routine inspection conducted by l Messrs. W. Cook, W. Schmidt and A. Krasopoulos of this of fice on May 6,1988 through May 24, 1988 at Nine Mile Point Units 1 and 2, Scriba, New York. A summary of the findings was presented to Mr. J. Willis and other members of 1 your staf f at the conclusion of the inspection. , f Based upon cur review of your staff's discovery of improperly sealed fire barrier penetrations, we have concerns about the implementation of your Fire i Protection Program at Unit One. We intend to schedule an enforcement conference to discuss the apparent Appendix R violation discussed in the attached inspection report (Section 10). We will contact you to arrange a time and date for this conference.

NRC , enforcement actions relating to the apparent violation will be deferred I pending .he outcome of this meeting.

i Your cooperation is appreciated. -

S1ncerely, Wi 11am F. ne, Director Division of Reactor Projects

Enclosure:

NRC Region I, Inspection Report No. 50-220/88-15 and 50-410/S8-15 h[

Od Sla

Ni6gara Mohawk Power Corporation i 07 JUN 1988 /

cc w/ enc 1- I l

' Co'nnor & Wetterhahn l

John W. Keib, Esquire i

! T. Perk' ins, Vice Pre;ident, Nuclear Generation

~

l J. Willis, General Superintendent 1 T. Roman, Station Superintendent, Unit 1-R. Abbott, Station Superintendent, Unit 2 R. Randall, Unit 1 Superintendent of Operations R. Smith, Unit 2 Superintendent of Operations J. Perry, Vice President, Quality Assurance  !

A. Pinter, NMPC Site Licensing C. Beckham, Manager Nuclear Quality Assurance Operations {

1 W. Hansen, Manager Corporate Quality Assurance Troy B. Conner, Jr., L; quire i Director, Power Division Department of Public Service, State of New York Public Document Room (PDR) local Public Document Room (LPOR) {

1 Nuclear Safety Information Center (NSIC) i NRC P.esident Inspector State of New York

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bec w/ enc 1:

Region I Docket Room (with concurrences)  ;

Management Assistant, DRMA (w/o encis) ]

J. Johnson, Section Chief, DRP R. Benedict, Licensing Project Manager, Unit 1 M. Haughey, Licensing Project Manager, Unit 2 ]{

State Liaison Officer (SLO) j

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B. Clayton, EDO, Regional I Coordinator R. Laura, Reactor Engineer, DRP P. Koltay, SRI, IP3 A. Luptak, SRI, FitzPatrick J. Durr, DRS 4 C. Anderson, DRS l

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UNITED STATts i'

• t - , .. NUCCEAR REGULATORY COMMISSION

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nAseuwatow.n.c.nosas 3 July 26,1979 Socket No. 50-220 l

Mr. Donald P. Dise '

Vice President - Engineering Niagara Mohawk Power Corporation 300 Erie Boulevard West. -

Syracuse, New York 13202

=

Dear Mr. Dise:

f The Commission has issued the enclosed Amendment No. 33 to Facility Opertting License No. DPR-63 for the Nine Mile Point Nuclear Station, Unit No.1. This amendment adds licensa conditions relating to the completion of facility i modifications for fire protection in response to you.- letters of April 10,1978, l l

October 6, IS78, January 2,1979 and January 31,1979.

We have discussed the contents and conditions of this license amendment with members of your staff and we understand that you have agreed to this licen e amendment. Nevertheless, you understand that by the provisions of 10 CFR Part 2 1

pargraph 2.204, you may demand a hearing with respect to all or any part of the .

amendaent within twenty (20) days from the date of this letter. If you do not demand a hearing, this amendment will become effective on the expiration of  :

thattwenty(20)daype,riod. ,

)

You are requested to propose revised Technical Specifications related to i facility modifications described herein and submit them for our review no later O than 90 days before the modifications are implemented.: Certain items listed in Section 3.1 of the enclosed Safety Evaluation are marked with an asterisk or '

otherwise stated to require additional information in the fom of design or acceptance criteria to assure that the design is parameters, acceptable prior to actua implementation of these modifications. We request test results,l i

that you submit this infomation to meet the schedule provided in Table 3.1. .

1 We have determined that no Itcense amendment fee is required to accompany

.your response to the aforementioned request. This detennination is 1tmited to those. applications or requests to incorporate our recommended Technical .J Specifications and those to add surveillance and other requirements for y i

operable systems that have been added at our request. Any other unrelated 7 changes or requests' that you might choose to include in the fire protection

• requests would be subject to amendment fees in accordance with section 170.22 '

of 10 CFR Part 170.

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NUCt. TAR Rs00LATORY COMnatssl0N j".s mAsHueGTON D.C.40688 ,L '..

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MAGARA MORAWK POWER CORPORATION f.'

DOCKET N0. 50-220 ,

NINE MILE P0 INT NUCLEAR STATION. UNIT N0. 1 6. 1 AMENDMENT TO FACILITY OPERATING LICENSE y.

Ainendmentio. 33 c.

. License No. DPR-63 p'-

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1. 'The fluclear Regulatory Comission (the Comission) has found that:

c.

A. The facility will operate in confomity with the provisions C l of the Atomic Energy Act of 1954, as amended, and the rules F 1 and regulations of the Comission; ) l c-  :

B. There is reasonable assurance (1) that the activities authorized [,  !

by this amendment can be conducted without endangering the c.- l health and safety of the public, and (11) that such activities F l will be conducted in coup 11ance with the Comission's Q. .

. regulations; -

4.{ j C. The issuance of this amendment will not be inimical to the E.~ I comon defense and security or to the health and safety of the public; and @Q, ,

D. The issuance of this amendment is in accohlance with'10 CFR k Part 51 of the Ccanission's regulations and all applicable requirement.s have been satisfied.

kk Accordingly, the license is amended by adding paragraph 2.D(4) to

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2.

read as follows: Q,.

2.D(4) Fire Protectio,n, The licensee may proceed with and is required to complete the mod-N.3'

-I (fications identified in Table 3.1 of the NRC's Nine Mile Point b*2 l Unit 1 Safety Evaluation Report (SER). Fire Protection Review, r#

1 dated July 26,1979.' These modifications shall be completed ff in accordance with~ the schedule in Table 3.1 of the SERor supple- d ments thereto. '

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0FFICE OF WetgAghg.0R Umm

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l NIACARA MOMAW Poeta eggg NINE Mit.E Poix7. UNIT 1 k i

DOCKET MO. 50 220 e .

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. Further, Niagara Nhawk Power Corporation shall, prior to

i. implementation, prov'de for Comirsion review and obtain Q

Y- - Comission approval of the final t! sign of modifications as

b. indicated in section 3.1 of the 'iafety Evaluation Report.

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J. Except for the modifications des ribed in the approved fire protection plan and approved as a result of Comission review

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of the Nine Nile Point Unit 1 Nucletr Plant Fire Protection Program, Niagara Whawk Power Corporation is authorized to

)/ make changes to the Program without prior Comission approval provided that such changes do not result in a decrease in

. the effectiveness of the Program. .

ic .

- The Itcensee is required to imphoent the administrative

, entrols identified in Section 5 of the SE. The administrative controls shall be in effect by September 1,1979.

3. This license amend.unt becomes effective as of August 15, 1979 *

FOR THE NUCLEAR REGULATORY COP. MISSION wh Thomas olito, Chief l

Operating Reactors Branch #3 Division of Operating Reactors Date o'f Issuance: July 26,1979

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'Provided no hearing is requested under 10 CFR Part 2 paragraph 2.204.

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. ? ...y s . . .. 3,9 <. C TABLE OF CONTENTS '

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1

. g. 1.0 Introduction ... 1.................................................

3

. 4 2.0 Fi re Protection Gui delines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I 3

2.1. General Design Criterion 3 " Fire Protection" . ....... . . .. .. . 3 2.2 SupP.ementary l Guidance .......................................

1 . .

5

3. 0 S umary of Ho difi cati ons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

5 3.1.1 FirfDetectEnSystems(4.2)............................... 5 l 3.1.2 Sprinkle r Sys tems (4. 3.1. 5) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

6 3.1.3 Fire Stops and Penetration Sea 1s . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 l 3.1.4 Fire and Heat Barri ers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

- 3.1. 5 F i re Doo rs ( 4.9.1 ) . . . . . . . . . . . . . .~ . . . . . . . . . . . . . . . . . . . . . . . . . 7. .

3.1. 6 Reactor Building Modi fications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3.1.7 Control Building Modi fi cations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 ,

3.1.8 Diesel Generator Building Modifications .. ... . ... .... . ..... . 8 i

3.1.9 Turbine Building Modifications ............................. 8 I 3.1.10 Waste Building Modi fi cations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 J 3.1.11 General Modifications / Administrative Changes ............... 9  !

3.1.12 F i re P ump (4. 3.1. 2 ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ,

11 l 4.0 Eval uation of Pl ant Fe at'ure s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . l 11 4.1 S a fe S hu td own .5y s t ems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 ..  !

4.2 Fire Detection and Signaling Systtms . . . . . . . . . . . . . .,. . . . . . . . . . 12 4.3 Fire Control Systems ........................................ 13 4 . 3 .1 W a t e r Sy s t ems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 ,

4. 3.2 Gas Fi re-S upp re s sion Sys tems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 l 4.3.2 Portable Fire Extinguishers ................................. 20  :

4.4 Ventilation Systems and Breathing Equipment ... ..... .. . ... .. . 20  :

4.4.1 Smoke Removal ............................................... 21 4.4.2Filtes...............,................................... 21 )

4. 4. 3 Breathi ng Equi pment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 l 4.4.4 Batte ry Room Ventil a tion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 4.5 Floor Drains ................................................ 22 4.6 Lighting Systems ............................................ 22 4.7 Comuni c a tion Sys tems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 4.8 Electrical Cables ........................................... 23 4.9 Fi re Barri er Penetrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 4.9.1 Doorways .................................................... 25 4.9.2 Ventil ation Duct Penetrations . . . . . . . . . . . . . . .. . . . . . . .. . .. . . . . 25 4.9.3 Electrical Cable Penetrations . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . 26 4.9.4 Piping Penetrations ....................... ................. 26 .,

4.10 Sepa rati on Criteri a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

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. 4.11 Fire Barriers ................c.............................. 27-

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- 4.12 Ac c e s s and Eg r e s s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 4.13 . Toxic and Corrosive Combustion Products .. ... . . ... ... . . ... . .. 28 4.14 Nonsafety-Relited Areas .....................................

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5.0 Uv'al'ua tion of Specific Plant Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

29 30

". 5.1 Re actor E u ll di ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

' 30 i:1 s  :.

31 5.1.2 Floor Elevation 237 Feet ................................

5.1.lu 5.1.3 Floor Elevation 261 Feet)) Floor. (((Elevati on 198 Fee t) . . . 32 33 5.1.4 Floor' (Elevation 281 Feet 5.1.5 Floor Elevation 298 Feet n

))................................

I:................................

34 35 5.'1.6 'T1oor ((El evation 7l8 Te et 5.1.7 Floor Elevation 340 Feeth ................................

5.2 Control Building ..........................................

36 37 37

. , 5.2.1 Cable Room (Elevation 250 Feet) . .. . . . . . . . . . . . . . . . . . . . . . . . . 38 5.2.2 Auxiliary Control Room and Computer F.com (Elev 250 ft) ....

39 5.2.3 Control Room (Elevation 277 Feet) . . . . . . . . . . . . . . . . . . . . . . . . . 40 5.3 Diesel Generator Building . . . . . . . . . . .. . . .. . . . . . . . . . . . . . . . . .

5.3.1 Floor (Elevation 250 Ft: Under Powerboard Rooms 40 and Diesel Generators? .................................. 42 f 5.3.2 Diesel Generator Rooms (Elevation 261 Feet) ... . ... . ... .. . .

5.3.3 PaerboardRooms(Elevation 261 feet).....................

45 Turbin Building .......................................... 47 5.4 47 5.4.1 Floor (Elevation 250 Feet)................................

- 5.4.2 BatteryBoardRooms(Elevation 261 Feet).................. 49 50 5.4.3 Remainder of Floor (Elevation 261 feet) .. . . . .... .. .. ... . . . 53 5.4.4 Turbine Oil Reservoir (Eelvation 251 Feet) ................ 53 5.4.5 Lube Oil Storage Room (Elevation 251 Feet) ................

54 5.4.6 Modifications ............................................. 56 5.4.7 Remainder of Floor (Elevation 277 feet) . .. ... ... .. . ... .. . . 57 5.4.8 ' Floor (El evation 291 Fee t) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 5.4.9 Floor (El evati on 300 Fee t) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61 5.4.10 Lube Oil Room (Elevation 305 Feet) . .. . . . .. . . . . . . . . . . . . . . . .

5.411 Floor (Elevations 321,332,350,and359 feet)............ 61 Screen and Pump House ..................................... 62 5.5 63 5.6 W s t e B ui l di ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

5.6.1 Floors (Elevations 225,247,261and281 Feet)............ 63 65 5.7 O f f-G a s B u t i d i ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

5.7.1. Floors (Elevations 229, 232, 247 and 261 feet) . . . . . . . . . . . . 65

. Admi ni s tra ti on Buil di ng . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . 66 5.8 5.8.1. Floors (Elevations 250,261and277 Feet)................. 66 '

67

,7 ' .

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5.9.... Yard Area ................................................. 67

- 5 .' 9.1 . Safe ty.Rel ate d Equi pment. . . . . . . . . . . . a . . . . . . . . . . . . . . . . . . . . . .

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5.9.2 67 67

., Consequences If No, Fire Suppression .... ... .... ........... .

QlMl;fW, X' 'd'e. Fire5. 9. 3.y Combus ti bl e s . . . . . . . . . . . . . . .

5.9.4? Protection System 67 g .P;i g? 5.9.5 Adequacy 3

..........n........................

of. Fire Protection . . . . . i. . . . . . . . . . . . . . . . . . . . . . . . .

67 68 g,Eq7 .qs .

3, k .. g '5.9.6' 'y- Modifications .............~............................ 69 c:9 h .; : N% tF 6.0: Admini'strative Controls _.! ....................................... .

70 fe 7.0 ? Technical' Specifications ........................................

% ' 47

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9.0 Consultant's Report ............................................. 74  ;

AppendixA............................................................ 77 l

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(3) Oissel Generator Building (5.3.1). Elevation 250 (4) Turbine Building (5.4) Elevation 250 (east and west ba serer.t s ) .

261 (where saf ety-related equa. ment is installed). 277 and 300 j i

l (5) Waste Building (5.6)

I (6) Off-Gas Building (5.7) q (7) Administration Building (5.6) 3.1. 3 fire Stops and T;enetration Seals (4,9.3) (4,9.4)

Suitable fire stops and/or penetration seals will be provided for electrical cable runs in the following areas:

(1) neactor Building (5.1) All Elevations (2) Control Building (5.2), Elevation 250 (3) Diesel Generator Building (5.3), All Elevations (4) Turbine Building Floor, Elevation 250 (5.4.1); floor, elevation 261 (5.4.4): elevation 277; and elevation 291  ;

i 3.1.4 Fire ,and Heat Barriers (4.11)(5.4.7.6)(5.4.9.6)

Fire or heat barriers vill be provided in the following areas:

i (1) Reacter Building, Elevations 282 (5.1.4) and 298 (5.1.5)

(2) DieselGeneradorBuilding, Elevation 250: the area under the diesels vill be separat;d from cable runs (5.3.1)

(3) Turbine building (5.4), Elevat$on 250 and 261 (turbine oil '

reservoir and turbine oil storage room), 277, 291 and 300 (4) Waste l'hild1nt (5.6.1), At elevation 251 (5) Venti 11stion duct penetrations and fire dampers (4.9.2)

Y3 \$

Table 3.1 pmpletion Dates for Proposed Modifications Hodiftestions Completion Date 3.1.1 Tire Detection Systems 1981 Refueling.

3.1.2 Sprinkler Systems January 1, 1981-3.1.3 Tire Stops Septer.ber 1, 1980 Penetration Seals 1981 Refueling 3.1. l. Tire and Heat Barriers January 1, 1981 3.1.5 Fire Doors January 1, 1981 3.1.6 Reactor Building Modifications 1981 Refueling 3.1. 7 Control BuildinE Modifications 1981 Refuel ~ing Safe Shutdown Panel 1921 Refueling 3.1.8 Building Modifications June 1981 Diessi Generator 1981 Refueling-3.1.9 Turbine Building Modifications 1981 Refueling 3.1.10 k'aste Building Modifications January 1, 1981 3.1.11 Ceneral Modifications June 1081

. Administrative Changes Septer.ber 1, 1979 3.1.12 Diesel Fire Pump September 1, 1979 l

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~25-4.9.2 Ventilation Duct Penetrations Fire dampers are installed in selected ventilation system pene-tr& ions of the fire barriers in varieus parts of the plant. The major known exceptions are penetrations of the perimeters of the turbine building basement, the vaste disposal building, and the control room. The licenses will verify that labelled fire dampers are installed in all ventilating system penetrations of all fire barriers which separate cefety-related areas from each other or from areas presenting a significant fire hazard. In ventilation l ducts that pass through rated fire barriers,' the licensee will

! provide fire dampers with established fire ratings suf ficient to deter fires with the combustible loading in the given area. The fire dampers will be actuated by fusible links or emeke detectors.

All fire dampers will have ratings of three hours, unless the licensea justifies a rating of 1-1/2 hours.

During the site visit, the staff observed that the fire dampers installed in the auxiliary control reom ventilation system ducts were inside the room. Tire dampers are required to be installed at the point where the ducts in which they are provided pass throut the fire barrier. The licenses will install fire danpers in the ventilating system ducts for the auxiliary control room. and any other areas where fira dampers are required or provided, in the duct at the point where the duct passes through the fire barrier.

We find that, subj ect to implementation of the above described modifications, protection of ventilation duct penetrations satis ' .

fies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.9.3 Electrical Cable Penetrations Electrical cable panstrations in fire barriers are generally sealed with a variety of materials and designs, the fire resistance rating,

,of which have not been determined by any test method acceptable to

' the staf f.: The liqenses vill determine the ratings of axisting designs in accordance~vTe~hTIEEE-$tandard 634-1978. ..Thislest mathe; eestYThestaffmquirements for tests of electrical cable penetra-l tions; except that it does not provide a pressure differential acros the barrier equivalent to the maximum expected in the plant. There may be cable penetrations through fire barriers in the plant, acros, which pressure differentials exist. The fire resistance ratings of these penetrations will be determined with such pressure differentials applied during the fire test, if practical.

The licenses plans te provide rated seals en all cable penetrations in the plant coneensurate with the barrier rating.

We find that, subject to implementation of the above described '

modifications, protection for electrical cable penetrations of fire barriers satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.9.4 Piping Penetration Piping penetrations through fire barriers, except for those in the reactor building, are generally not sealed. The licenses has not indicated the fire resistance rating of those penetrations which are saaled.

The ite.:. ee .'ill tgproposed piping penetrations in accordance with ./. .e ar seccions of IEEE Standard 634-1978, " Cable Pene-tratio Tira S'op Quali*'.cu ion "est", although this test aethod is not - @ ,d for piping penetrations. . The licensee vill in-stall ,*..n, penetrations with fire resistance ratings equal..to the bsr w s thay. penetrate. The licensee plans to seal all piping penetrations between safety-related areas, and between safety-related and nonsafety-related areas.

We find that, subject to implementation of tha above described modifications, protection for piping penetrations pf fire barriers. j satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.

4.10 Separation Criteria Separation criteria are not based upon Regulatory Guide 1.75" However, in most instances cable separation meets or exceeds the guidelines of that document for the Turbine and Reac'sr Buildings.

Sepai at".on of redundant circuits is achieved in the Turbine Building by routing cables on the East or Vest side of the building. Turther l separation is provided bp locating trays above or below floor el,evation l 261 feet. Any one of the following groups of Turbine Building cable trays ensures safe shutdown of the plant.

1. Cable Trays above Elevation 261 feet, or

2. Cable Trays belov Elevation 261 feet, or l 3. Cable Trays above and belov Elevation 261 feet on the East side, or~

l 4 Cable Trays above and belov Elevation 261 feet on the West side, t

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6.0 ADMINISTMTIVE Coh7R01.$

The administrative' controls for fire protection consist of the fire prote-organization, the qualifications and training for fire p and procedures for fighting fires in the various. plant areas..and The licensee thea.qua-has provided de -

assurance provisions for fire protection.

tailed description of proposed administrative controls. . Plans and proced stipulating the management and staf f organization and its qualifications; fire brigade training progras; controls over combustibles and ignition se and the prefire plans for fighting fires are being developed and implemer The program and its implementing procedures as provided licensee dated February 28 1977, October'6, 1978; January 2, 197! I 1977; December 13.-1977; March 22, 1978; and January 31, 1979, are found acceptable by the staf f using items refe; in Sections 1.0(e) and 1.0(f).

1 to determine the c ;-

L'e have evaluated the areas at Nine Kile Point l' nit required fire brigade size to cope with fires This that may occur, requirement andinha is being I cined that a five man brigade is required.

porated into the Technical Specifications with implementation 90 days a issuance of this report.  !

All five of the brigade members receive the sa=e instruction and practic i.cluding familiarization with the content of the prefire plans with the ception that two members will not receive fire fighting strategy trainin iThese because they are under.the direction of a trained brigade leader. their l two signedmembers tasks. do receive an acceptable level of training includes decision factors, direction of brigade, problem sessions and cc i ordination of various pieces of equipment.

k's find that, subject to implementation of the above described prograr:4 changes, the fire protection program satisfies the objectives identifici-!!

Section 2.2 of this report and is, therefore, acceptable.

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APPENDIX A CHRON01.0CY_

In Tebruary 1976 the report by the NRC Special Review Group was issued as NTREC-3050, "Reco emendations Related to the Browns Terry Tire."

to On May 3, 1976, Standard Review Flan 9.5.1 " Fire Protection" was sent Niagara Mohauk Power Company (:.MFC ) incorporat ing t he va rious r ec o : coda t t.: ..

contained in STRIC-0050.

Bv letter dated May 11,, 1976. Niagara Mohawk Power Ccmpanv (.0CPC) was.

recuested to compare tne existing fire protection previsions at their fa:111 ties with new NRC guidelines as set forth in Standard Review Plan i.5.1 " Fire Protection" and to describe (1) the implementation of the the

. guidelines met. (2) the modifications or changes underway to meet -

guidelines that will be met in the near future, and (3) the guidelines that will not be met and the basis therefore.

Sv letter dated September 27, 1976 NMPC was requested to ;ro. ride the results of a fire hazards analysis and prepose Technical Specifications rertaining to fire protection. NVPC was also provided a copy of Appendix A to BTP 9.5-1 which includes acceptable alternatives to the guidelines of SRP 9.5-1.

By letters dated December 2, and December 16, 1976 we previded model Technical Specifications and further guidance, and we requested submittal of fire protection Technical Specifications by the licensee By letter dated Feoruary 28, 1977 SMPC provided report titled "Nine Mile Point t' nit 1 Fire Protection Program" in response to cur letters o:

May 11. September 27. December: and December 16, 1976 By 'etter dated June 17 1977, we provided additional guidance re. ftre protection Technical Specifications. NMPC responded July 13, 1977

• 4e issued the Technical Specifications to SHPC on November 23. and SMPC accepted them by their letter of December 13, 1977.

On July 10, 1978, we requested additional inf ornation to supplement the NMPC fire hazards analysis, which was forwarded by SMPC letter of October 6, 1978.

1.etters describing administrative controls for fire trotection were forwarded to N"/.PC on August S. 1977 and February 3, 19'd.

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Appendix A i

l On October 17-20, 1978, the NRC fire protection review team visited the ,

Nine Mile Point Unit I facility. We issued a letter, dated November 27 j 1978 requesting additional information and itemining certain staff l concerns and positions. NMPC provided additional information in response  !

to the site visit and this letter, via their letters dated November 17 1978: January 2, 1979; and January 31, 1979.

On March 6,1979, the NRC fire protection review team met with NMFC in Syracuss N.Y. to discuss the *MPC responses prior to issuing this 'l Safety Evaluation Report.

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