ML20204F445

Insp Rept 50-213/86-17 on 860616-20.Deviation Noted:Failure to Lock Open Breakers for Valves RC-MOV-510,RC-MOV-515, RC-MOV-528 & RC-MOV-577,per 850916 Commitment.List of Licensee Commitments by Fire Area Encl

ML20204F445
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	07/24/1986
From:	Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20204F431	List: ML20204F426 ML20204F438 ML20204F445
References
50-213-86-17, NUDOCS 8608040190
Download: ML20204F445 (30)

See also: IR 05000213/1986017

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 86-17

Docket No. 50-213

License No. DPR-61 Category C

Licensee: Connecticut Yankee

P.O. Box 270

Hartford, Connecticut 06101

Facility Name: Haddam Neck

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Inspection At: Haddam, Connecticut

Inspection Conducted: June 16-20, 1986

Inspectors: jl'/ 86

'A. Krasopoulos, Reactsf' Engineer ' datV

Also Participating and Contributing to the Report were:  ;

D. Kubicki, Fire Protection Engineer, NRR

J. Taylor, Electrical Systems Specialist, BNL

A. Cop ola ec anical Systems Specialist, BNL /

Approved by: 77/

C. Anderson, Chief, Plant Systems Section, DRS date

! Inspection Summary: Inspection on June 16-20, 1986 (Inspection Report No.

50-213/86-17)

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

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

0, concerning fire protection features that ensure the ability to achieve and

maintain safe shutdown in the event of a fire.

Results: Four (4) violations were identified, one (1) deviation was identified

and three (3) items remained unresolved.

B608040190 860801

PDR ADOCK 05000213

G PDR

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! Details

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$ 1.0 Persons Contacted

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l 1.1 Connecticut Yankee Atomic Power Company (CYAPCO)

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< *W. Bartron, Maintenance

• G. Bouchard, Station Services Superintendent

• L. Blomberg, Engineer

l *T. Bransfield, Engineer

J. Clark, Staff Engineer

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• E. DeBarba, Generation Engineering

*J. DeLawrence, Engineer

j *J. Ferraro, Electrical Engineer

3 *J. Ferguson, Unit Superintendent

l *R. Graves, Station Superintendent

i *G. Johnson, Director, Generation Engineering and Design

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• T. Kazukynas, Fire Protection Engineer

• C. Koubik, I and C Engineer

• R. Laudenat, Manager, Licensing

• W. Lepper, Electrical Engineer

j *P. L'Heureux, Engineer

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• J. Mazzie, I and C Engineer

• E. Mroczka, Vice President Nuclear Operations

l *J. Naylor, Fire Protection Engineer

• W. O' Hare, Reactor Engineer

• A. Patrizz, Fire Protection Engineer

• G. Pitman, Electrical Engineer

• B. Pokora, Mechanical Engineer

• A. Roby, Electrical Engineer

• J. Roncaioli, Fire Protection Engineer

• R. Tournble, Operations Assistant

• B. Tuthill, Supervisor, Generation Electrical Engineering

• G. Tylir. ski, Engineer

• R. Werner, Vice President, Engineering & Construction

• B. Woodsby, Fire Protection Engineer

• D. Vail, Electrical Engineer

• G. VanNoordennen, Licensing Engineer

1.2 Nuclear Regulatory Commission (NRC)

F. Akstulewicz, Licensing Project Manager, NRR

W. Johnston, Deputy Director, Division of Reactor Safety

E. McCabe, Chief, Reactor Projects Section, DRP

S. Pindale, Resident Inspector

P. Swetland, Senior Resident Inspector

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2.0 Purpose

This team inspection was conducted to ascertain licensee compliance with

10 CFR 50, Appendix R, Section III G, J and O. Because the licensee

obtained exemptions from full compliance from the above requirements, the

team reviewed the licensee's approach to compliance. In plant areas where

schedular relief was granted, or pending, the team reviewed the plans and

schedules for completing the modifications required for these areas.

Where exemptions from the requirements of Appendix R were granted on the

basis of equal protection or other technical justification the team

reviewed the licensee's actions in those areas to determine the adequacy

of the protection afforded.

3.0 Background

10 CFR 50.48 and 10 CFR 50, Appendix R, became effective on February 17,

1981. For Haddam Neck the applicable portions of this regulations are

Sections III.G, " Fire Protection of Safe Shutdown Capability," III.J,

" Emergency Lighting," and III.0, "011 Collection System for Reactor Coolant

Pump."

10 CFR 50.48 sets forth the schedule for the completion of modifications

required for compliance with the above regulations.Section III.G of

Appendix R requires that fire protection features be provided to ensure

that one train of equipment necessary to achieve and maintain safe shutdown

remains available in the event of a fire at any location within a licensed

operating facility. For hot shutdown conditions, one train of the systems

necessary must be free of fire damage (III.G.1.a). For cold shutdown con-

ditions, repair is allowed using in place procedures and materials available

onsite with the provision repair is completed in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (III.G.I.b).

Section III.G.2 lists specific options to provide adequate protection for

redundant trains of equipment located outside of the primary containment.

These options are:

Separation by a fire barrier having a three hour rating (III.G.2.a).

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

vening combustibles and with fire detection and automatic fire suppres-

sion installed in the fire area (III.G.2.b).

Enclosure of one train in a fire barrier having a one hour rating in

addition to having fire detection and automatic suppression installed

in the fire area (III.G.2.c).

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

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

III.G.3 of the rule requires that an alternate or dedicated shutdown capabil-

ity be provided which is independent of the area of concern. Any alternate

or dedicated system requires NRC review and approval prior to implementation.

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

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

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

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

are submitted to the NRC for review and approval and must be justified by

the licensee on a technical basis.

With regard to Item III.G of Appendix R, for certain plant areas, the licensee

was granted permission to deviate from the requirements iterated above,

based on technical justification and commitments made by the licensee and

other factors evaluated by NRR. The areas where exemptions from the require-

ments of Section III.G were granted are as follows:

• Service Buildirg Control Room

• Service Building Switchgear Rcom

• Primary Plant Containment Cable Vault

• Primary Plant Auxiliary Feedwater Pump Room

• Screenwell Pump House Pump Motor Room

• Service Water Pump Cable Duct Bank and

Charging Pump Pits and RHR Pump and Heat Exchanger Areas (various zones)

In addition the licensee on March 7, 1986, submitted to the NRC a reque'st

for a schedular exemption that aff ects the following areas:

• Primary Auxiliary Building - General Area

- Charging Pump Cubicles

- Charging Metering Pump Room

• Containment Cable Vault

• Reactor Containment - Lower Annulus

• Switchgear Room

• Cable Spreading Area

• Turbine Building

This schedular exemption is currently under review by NRR and is herein

referred to as the "switchgear room exemption".

The granting of the exemptions was based on licensee commitments to provide

additional fire protection capability and perform modifications that ensure

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the safe shutdown capability of the plant in the event Of & fire. The liit

of licensee commitments to support the various exemptions requests appears

in Attachment 1 of this report.

The licensee is also required to comply with the requirements of Section

III.J and 0 of Appendix R.

Section llI.J of Appendix R requires an emergency lighting system with at

least 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery power, to be provided, in all areas needed for operation

of safe shutdown equipment and in access and egress routes thereto.

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Section III.0 of Appendix R requires that a seismically supported oil collec-

tion system be provided to collect any leakage from the reactor coolant pump

lube oil system. The licensee is required to comply with this requirement

except where approved exemptions exist.

4.0 Correspondence

Correspondence between the licensee and the NRC, concerning compliance

with Sections III.G, J and 0 of Appendix R was reviewed by the inspection

team in preparation for the site visit. Attachment 2 to this report is a

listing of the correspondence reviewed.

5.0 Post-Fire Safe Shutdown Capability

To meet the requirements of Appendix R that at least one train of equip-

ment necessary to achieve and maintain safe shutdown is not damaged by

fire, the licensee indicated that the following safety functions are

relied upon:

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Reactivity control and primary system make-up

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Cooldown and depressurization

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Preclusion of, or compensation for, spurious operation of equipment

which could prevent operation er cause maloperation of redundant

trains of systems necessary for safe shutdown

In order to assure availability of these functions the following systems

need protection:

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Main Steam / Auxiliary Feed

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Service Water

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Residual Heat Removal

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Chemical and Volume Control

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Reactor Coolant

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Emergency AC and DC Electrical Distribution Systems

For the specific case of a Control Room fire the following assumption was

made: Fire damage would be limited to either the main control board or the

auxiliary control panels. Further it is assumed that the operators would

be able to return to the Control Room one hour after a fire and resume

shutdown operations with the available equipment. These assumptions were

previously evaluated by NRC and were found to be valid.

For design basis fires, concurrent with loss of offsite power, shutdown

would be initiated from the control room by a manual scram of the control

rods, if an automatic scram has not occurred. Reactor coolant inventory

and reactor shutdown reactivity are maintained by a charging pump or the

metering pump taking suction from the refueling water storage tank.

Primary system pressure is maintained by isolating the Reactor Coolant

System (RCS) and ensuring that unwanted actuation of pressurizer sprays

does not occur. The required subcooling to maintain natural circulation

is maintained by the steam bubble in the pressurizer. To depressurize

the RCS for initiation of Residual Heat Removal System operation, manual

opening of the auxiliary spray line (CH-MOV-298) is utilized.

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For hot shutdown, decay heat removal is accomplished by the turbine driven

auxiliary feedwater pumps supplying water to the steam generators from the

demineralized water storage tank (DWST). The primary water storage tank

(PWST) provides an additional water source. To remove decay heat from the

steam generators, the manual steam generator vents, the auxiliary feed pump

steam turbine, and one of the auxiliary feed pump steam relief valves are

used as required. Other steam removal paths (atmospheric dump valve, steam

jet air ejectors, main condenser) can also be utili:ed if they are available.

For cold shutdown, decay heat removal, is accomplished by the residual

heat removal system in conjunction with the service water system. Cold

shutdown can be achieved in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

A diesel generator and associated electrical distribution equipment supply

essential power. The service water system supplies cooling water to the

diesel generator. The above systems are normally controlled and monitored

from the control room.

Protection from spurious operation of motur operated valves has been provided

by locking out the power to certain valves. These valves include the auxi-

liary pressurizer spray valve (CH-MOV-298), the loop drain header isolation

valve (DH-MOV-310), the firewater / service water isolation valve (SW-MOV-30),

and the loop bypass isolation valves. In addition, cabling and controls for

certain CVCS and RHR components will be transferred to the new switchgear

room to provide the required degree of redundancy for all fire areas.

For control room fires that affect the main control beard the anticipated

damage would be: loss of instrumentation, loss of control for the charging

system, service water pumps, and auxiliary feedwater turbine driven pump and

spurious operation of various valves and equipment. Loss of function of the

entire main control board would result in loss of the following control room

shutdown functions: reactivity control, reactor coolant makeup, reactor heat

removal, process monitoring and supporting functions.

The licensee has a procedure for shutting down the plant from outside the

control room. This is an interim procedure until the new switchgear room

is built, and utilizes manual operator actions at breakers and valves. The

procedure also allows the operators to scram the reactor from the control

room and allows operation of the " kill" switches for the PORV's and MSIV's.

Process monitoring is achieved through monitoring circuits in the cable

vault and the switchgear room.

Isolation from control room circuits is provided for the "B" Diesel Generator

and selected safe shutdown loads, such that local operation from the diesel

generator room can be achieved.

For a control room fire that damages the auxiliary control boards the licen-

see provided electrical isolation of the "B" diesel generator's control and

indication circuits in order to permit local start and operation of the diesel

generator. Also, the breaker closing mechanisms for a diesel generator

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output breaker, a charging pump breaker and a 180 volt load center transformer

feed breaker is modified to include a local electrical closing circuit.

This is needed to provide the shutdown capability in the event of a fire

in the main control board.

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For post-fire conditions where the control roor is accessible, cold shutdown

would be achieved utilizing the control and inscrumentation of the main con-

trol board supplemented by local operator actions. Operator actions in the

diesel generator room would provide isolation and start of a diesel generator

and a charging pump, and isolation of non-shutdown equipment. Operator

actions in the switchgear room would provide stripping of non-essential

loads from electrical buses, isolation and local start of a service water

pump, and isolation of non-shutdown equipment. Also, operator actions

would manually align valves in the service water system.

For post-fire conditions where the control room is inaccessible for an

extended period, the auxiliary feedwater system could be manually initiated

independent of the control room. Additionally, instrumentation is available

for monitoring safe shutdown conditions independent from the control room.

The operating staff would proceed with the actions described above for

local start of a diesel generator, a charging pump, a service water pump

and isolation of non-shutdown equipment. The operators could maintain safe

post-fire conditions independent of the control room for at least one hour

and then re-enter the control room to continue the shutdown.

6.0 Inspection Methodolo,qy

The inspection team examined the licensee's capabilities for separating

and protecting equipment, cabling and associated circuits necessary to

achieve and maintain hot and cold shutdown conditions. This inspection

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

compliance with Section III.G.

The following functional requirements were reviewed for achieving and main-

taining hot and cold shutdown:

• Reactivity control

• Pressure control

Reactor coolant makeup

i * Decay heat removal

• Support systems

• Process monitoring

The inspection team examined the licensee's capability to achieve and main-

tain hot shutdown and the capability to bring the plant to a cold shutdown

condition in the event of a fire in areas containing safe shutdown systems.

The examination included a review of the analysis for the shutdown capability

, and review of the procedures for achieving shutdown from outside the control

j room. Drawings were reviewed to verify the electrical independence of redun-

dant systems. Procedures were reviewed for general content and feasibility.

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Also inspected were fire detection and suppression systems and the degree of

physical separation between redundant trains of Safe Shutdown Systems (SSSs).

The team review included an evaluation of the susceptibility of the SSSs for

damage from fire suppression activities or from the rupture or inadvertent

operation of fire suppression systems.

The inspection team examined the licensee's fire protection features pro-

vided to maintain one train of equipment needed for safe shutdown free of

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

such as walls, floors and ceilings, and fire protection of openings such

as fire doors, fire dampers, and penetration seals.

The team also reviewed the licensee commitments to NRC supporting exemption

requests. These commitments are listed in Attachment 1. This review was

limited to those commitments required to be implemented at the time of the

inspection. This included the review of the following items as listed in

Attachment 1:

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Service Building Control Room Fire Area (S-1) Items Numbered 2 Thru

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Service Building Switchgear Room Item No. 9

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Primary Plant Auxiliary Feedwater Pump Room Item No. 1

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Screenwell Pumphouse Pump Motor Room Items Nos. I thru 6

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Charging Pump Pit Fire Area A-1 Item No. 3

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Fire Zone A-ID Item No. 3 and

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Fire Zone A-1E and A-1F Items 1 and 2.

The inspection identified two deficiencies in the implementation of these

commitments. One related to the licensee's failure to properly test the control

room Halon system and the other related to the licensee's failure to lock open

the MCC breakers for the RCS by pass valves. The details for these deficiencies

are contained in section 7.1 and 7.3.2 of this report.

7.0 Inspection of Protection Provided for Safe Shutdowns Systr.ms

7.1 Protection in Various Fire Areas

The team reviewed the protection provided to SSSs in selected fire

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

The following fire areas were inspected:

Fire Area No. Description

A-1 Primary Auxiliary Building (PAB)

(Zone A-1A includes entire 1st Floor of PAB

excluding Zones A-1B through A-1F)

Zone A-1B Charging Pump "A" Cubicle

Zone A-1C Charging Pump "B" Cubicle

Zone A-ID Charging Metering Pump Cubicle

Zone A-IN PAB, Second Floor

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Fire Area No~. Description

A-2 Health Physics Building

D-1 East Diesel Generating Room DG-2A

D-2 West Diesel Generating Room DG-2B

H-1 Manhole #5

P-1 Screenwell Building

R-1 Cable Vault

R-2 Auxiliary Feedwater Pump Room

S-1 Control Room, Zones A, B, C and D

S-2 Switchgear Room

S-3 Zone S-3A - Cable Spreading Area

Zone S-3B - Locker Rooms and Chemical Labs

S-4 Instrument Shop Area and Mechanical Equipment

Room

T-1 Turbine Building

W' Stairwell between PAB and Waste Disposal

Building

In areas such as those affected by the switchgear room exemption, the

licensee, has established fire watches as an interim compensatory

measure. The team observed that these fire watches did not have

hands on training with fire extinguishers as specified in NFPA 518.

The licensee agreed to provide such training to the fire watches. On

July 21, 1986, the licensee informed NRC Region I that all training

in this area was completed. Additionally the following unacceptable

conditions were identified:

Control Room Halon Suppression System Test Failed to Meet the Design

Parameters

The licensee on March 1, 1982 requested an exemption from the require-

ment of Appendix R Section III.G.2 and 3 for the control room.

To support the exemption request the licensee committed to install an

automatic Halon 1301 system in the control room. In the original pro-

posal the licensee committed to provide 10% Halon concentration in t!e

Control boards. This proposal however was subsequently changed and

the licensee committed to provide 7% concentration for 10 minutes for

the entire Control Room.

A subsequent T.S. change request identified the design concentration

as being 6%.

A review of the licensee's test results disclosed that the Halon System

test was performed for the first 13 minutes without the control room

recirculation fans running. Subsequently, the fans were started and

the Halon concentrations fell from 7% or greater,to less than 5% in less

than 10 minutes. Unless there is a concurrent loss of offsite power

with a fire in the control room, these fans will be operating; therefore,

, the test data representing the period when the fans are running depict

the actual conditions. NFPA specifies a 5% agent concentration to

extinguish a fire of the type that might occur in the control room.

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10 CFR 50, Appendix R, III.G requires protection of safe shutdown systems

from fire damage. In order to comply with this requirement, the licen-

see requested an exemption from the rule by providing alternate methods,

one of which was the installation of a control room Halon system.

Because this system was demonstrated to be inadequate, the licensee

has not complied with the exemption of 10 CFR 50, Appendix R, III.G.

This is a violation (50-213/86-17-01).

Subsequently, CYAPC0 committed to make a modification to the Control

Room HVAC system such that the Control Room HVAC exhaust fan will be

automatically shut down in the event of a control room fire and activa-

tion of the control room Halon system. The purpose of this modification

is to prevent dilution of the Halon concentration in the control room

via control room HVAC exhaust fan. This modification will be complete

by January 1, 1987.

Additional Interim Fire Protection for Cable Tray Outside the Charging

Pump Cubicles

The team observed that redundant safe shutdown charging pump cables

are in the same cable tray outside of the cnarging pump cubicles and

therefore subject to damage by a single fire.

The licensee explained that this condition will change once the new

switchgear modifications are implemented. These modifications are

the subject of the switchgear room exemption. In the interim CYAPCO

committed to install approximately two additional sprinkler heads in

the PAB outside of the charging pump cubicle to provide protection from

a floor based fire. This modification will be completed by January

1,1987. The additional sprinklers will supplement the existing cable

tray sprinkler system and smoke detection system. .

Halon System in Existing Switchgear Room

The Halon system in the existing switchgear room had been declared

inoperable by the licensee, because the licensee review of the

acceptance test data revealed that the acceptance test criteria do

not meet the current NFPA code requirements for Halon concentration.

In order to restore this system to operable status CYAPCO committed

to make the following modifications to the switchgear room Halon

system.

a. Install new supervised electric circuits and release mechanisms.

b. Modify the Halon system to achieve a 5% concentration of Halon for

at least 10 minute duration. These modifications may include

(1) installation of additional piping and/or Halon storage cylin-

ders; and (2) modifications of the smoke detection system.

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CiAPC0 will conduct a full discharge test with documentation to confirm

that the system can achieve and maintain the design concentration in

(b) above. The modifications in (a) and (b) above will be completed

by January 1, 1987. The full discharge test will be conducted during

the first refueling outage commencing after January 1,1987 or (2) the

first unscheduled or planned outage of greater than one week duration

commencing af ter January 1,1987.

The above is an unresolved item pending implementation of the

modifications and completion of the discharge test (50-213/86-17-02).

It was noted that the licensee had instituted a fire watch in this

area as required by the Technical Specification.

7.2 Safe Shutdown Procedures

7.2.1 Procedure Review

The team reviewed the following interim safe shutdown procedure:

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Plant operation outside control room, procedure A0P3.2-8 Rev 10

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

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

iculty involved in operating equipment, and to verify that there was no

dependence on repairs for achieving hot shutdown. For review purposes,

a repair would include installing electric or pneumatic jumpers, wires

or fuses to perform an action required for hot shutdown. Since some of

the modifications planned for safe shutdown have not been completed,

the licensee's procedures allow some minor repairs in the interim.

For cold shutdown, repairs are allowed using in place procedures and

material available onsite with the provision that cold shutdown be

achievable with 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with or without offsite power.

The following unacceptable conditions were identified:

Inadequate Cooldown Analysis for Steam Relief Using the Steam Generator

(SG) Vents

In fire scenarios resulting in a loss of the Atmospheric Dump Valves

(ADV) or other steam relief paths, the licensee plans to use four (4)

1" diameter vent valves located on the main steam lines from the steam

generators and the terry turbine steam discharge, for cooldown purposes.

The licensee's cooldown analysis specified the need for approximately

130,000 gallons of condensate for the Auxiliary Feedwater System over

a period of about 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />. This was determined in calculation No.

C2-517-692-RE, Rev. 1, titled "CY Appendix R cooldown without feed and

bleed". The licensee arrived at this conclusion, based on a steam flow

rate of 162,700 lbm/h (pound mass per hour) for the (4) 1" vents.

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The licensee used this flow rate in the cooldown calculations without

adequate consideration for the piping configuration and frictional

losses that occur in the installed piping system. The team indicated

to the licensee that the "as built" configuration should be used in

the calculation to determine the steam flow rate. The licensee agreed

and performed a preliminary calculation which determined that under the

existfog conditions, more than 160,000 gallons of condensate would be

needed over a period of approximately 25-27 hours. This amount is

more than the minimum available water inventory in the demineralized

water storage tank and the primary water storage tank which are the

specified sources of water in the " Fire Protection Evaluation Shutdown

System Availability," analysis.

Appendix R to 10 CFR 50 Section III.G requires that one train of systems

necessary to achieve and maintain hot shutdown conditions shall be free

of fire damage. Using the analysis identified above the licensee could

not demonstrate that shutdown could be accomplished if use of the ADV

was lost. This is a violation of Appendix R, 10 CFR 50, III.G.I.a.

(50-213/86-17-03).

CYAPCO committed to provide a vent line/cooldown rate calculation which

incorporates actual vent line configuration. Temporary procedures to

address the existing results have already been implemented. The results

of the recalculation will be forwarded to the NRC by August 19, 1986.

Control Room Environment

The licensee's shutdown procedure allows the control room operators

to reenter the control room one hour after a fire occurs in the con-

trol room. Assuming a loss of the HVAC system as a result of a loss

of offsite power, the team requested an estimate of the maximum tempera-

ture of the control room for habitability purposes and equipment oper-

ability. The licensee provided the results of analyses that indicated

the control room temperature could reach 140 F. However, the analysis

did not specify the time to reach this temperature. In addition, the

analysis conservatively ignored potential heat losses. The inspectors

questioned the acceptability of this temperature for habitability and

control room equipment operability purposes. CYAPCO committed to

reanalyze the effect of temperature on operating personnel should ven-

tilation to the control room be lost during a fire. If necessary

emergency procedures will be reviewed to reflect actions that could

be taken to reduce control room temperatures during a fire to that

consistent with operator action. This reanalysis and any resulting

modified procedures will be forwarded to the NRC by August 19, 1986.

This is an unresolved item (50-213/86-17-04).

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Temporary Process Monitoring Instrumentation

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The team observed that for a fire in the main control room panel the

process monitoring instrumentation capability for steam generator (SG)

level, SG pressure and in-core thermocouples (T hot and T cold) would

likely be lost. As a result of an exemption request, the licensee is

not currently required to have this monitoring instrumentation capabil-

ity. However, since full compliance with Appendix R is not scheduled

until 1989, CYAPC0 committed to provide NRC with an evaluation of

the temporary arrangement for monitoring certain plant parameters

(i.e., steam generator level, steam generator pressure and T hot /T

cold) following a control room fire. This evaluation will include

(1) reviewing the temporary instrumentation cabling connection to

determine if a method less prone to operator error and inadvertent

disconnection is practical and (2) improving emergency lighting which

would support the connection and reading of these instruments. The

results of this evaluation, and a schedule outlining any results

modifications will be provided by August 19, 1986. All modifications

will be complete by January 1, 1987.

Component Cooling Water (CCW) System Not Included in the Fire Protec-

t1on Evaluation Report (FPER)

The inspection team observed that the licensee is using the CCW system

for the reactor coolant pump (RCP) seal cooling. The CCW system is not

included in the FPER, and an associated circuit analysis for that system

had not been performed. CYAPC0 committed to provide an analysis of

the component cooling requirements which support the safe shutdown

analysis. This analysis will be forwarded to the NRC by August 19,

1986.

This is an unresolved item (50-213/86-17-05).

7.2.2 Procedure Walk-Through

The team walked through selected portions of the procedure to determine

if shutdown could be attained in an orderly and timely fashion.

A scenario for a Control Room fire and evacuation was established and

i the operators proceeded to simulate the steps described in the proce-

dure. The steps were simulated in order to demonstrate feasibility,

timely response to the emergency and ability to communicate. The

simulated actions to achieve hot shutdown were completed in about one

hour.

7.3 Protection for Associated Circuits

Appendix R,Section III.G, requires that protection be provided for

associated circuits that could prevent operation or cause maloperation

j of redundant trains of systems necessary for safe shutdown. The cir-

! cuits of concern are generally associated with safe shutdown circuits

in one of three ways:

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14

Common bus concern

• Spurious signals concern

Common enclosure concern

The associated circuits were evaluated by the team for common bus,

spurious signal, and common enclosure concerns. Power, control, and

instrumentation circuits were examined for potential problems. A sam-

pling basis was used in making the examination.

7.3.1 Common Bus Concern

The common bus concern is found in circuits, either safety related or

nonsafety related, where there is a common power source with shutdown

equipment and the power source is not electrically protected from the

circuit of concern.

The team examined on a sampling basis the 4160V AC, 480V AC, 120V AC,

and 125V DC bus protective coordination. The team also examined, on

a sampling basis, the protection for controls and power circuits in-

cluding the coordination of fuses and circuit breakers. The licensee

has been testing relay settings at approximately 12 month intervals.

The time current curves for the following breakers were examined for

coordination:

480V bus 4 - all loads

a

480V bus 5 - tie breaker to bus 4

4160V bus 8 - feeder breakers to bus 4

• Offsite power feeder breaker to bus 8

Emergency diesel generator breaker to bus 8

All breaker settings were found to be properly coordinated. The licen-

see has an ongoing coordination program as defined in their procedure

D-PM-9.5-5, " Protective Relaying Calibration Program". This procedure

requires that all breakers for safe shutdown be calibrated every refuel-

ing interval. The most recent calibration tests were reviewed for

[ two breakers: 1) the highside 4KV feeder breaker from 4160V bus 8 to

l 480V bus 5, and 2) the 480V breaker from 480V bus 5 to the metering

charging pump P-11-1A.

l The following deficiency was identified:

Inadequate Breaker Coordination Setting Procedures

The team reviewed the licensee's breaker trip setting procedures and

test results to verify the adequacy of the breaker coordination program.

A review of the test results for the 480V breaker from bus 5 to the

metering charging pump P-11-1A identified the following deficiencies:

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15

DB-25 Breaker Test Procedure, PMP 9.5-17, revision 10, issued

by Generation Engineering does not require a comparison between

the actual test results with the desired trip setting required

by engineering. In practice the licensee calibrates the 480V

breakers in the "as found" position setting. If the as found

setting is wrong, the calibration for tripping the breaker will

also be wrong.

For the same breaker, a set point change request No. 7 issued by

Generation Engineering and an accompanying safety evaluation

dated 4/22/85 were never implemented by the plant. This change

request called for a reduction in the breaker relay setting

because the licensee realized that the original setting was for

the wrong horsepower, i.e., 60 HP rather than 50 HP.

The as found setting for this breaker provided adequate protection

even though the wrong horsepower was utilized since the horsepower

utilized was close to the actual horsepower.

The above is collectively categorized as a violation of Technical

Specification 6.8.1 which requires that the test program will

contain the requirements and acceptance limits of the applicable

design documents (50-213/86-17-6).

CYAPC0 committed to review the procedures used in the coordination

study. If the review results in reanalysis such reanalysis will

be undertaken. This review will be completed by August 19, 1986.

High Impedance Fault Procedure

The team reviewed draft procedure No. A0P 3.2-45, High Impedance

Fault Procedure. No unacceptable conditions were identified.

Since this procedure is in draft, CYAPC0 committed to formally

approve the operating procedure governing multiple high impedence

fault problems. Formal approval of this procedure will be made

by August 19, 1986.

7.3.2 Spurious Signals Concerns

The spurious signal concern is made up of 2 items:

• False motor, control, and instrument indications can occur such

as those encountered during 1975 Brown's Ferry fire. These could

be caused by fire initiated grounds, short or open circuits.

Spurious operation of safety related or non-safety related compo-

nents can occur that would aversely affect shutdown capability

(e.g., RHR/RCS isolation valves).

In reviewing current transformer secondaries, high low pressure inter-

faces and general fire instigated spurious signals the following

unacceptable condition was identified:

_ _ _ _ _ _

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RCS Loop Bypass Valve MCC Breakers Not Locked

By letter dated September 16, 1985 the licensee committed to have the

breakers for the following valves locked open at the motor control

center (MCC) by August 14, 1985:

• RC-MOV-510

• RC-MOV-515

• RC-MOV-528

• RC-MOV-577

The inspection team observed that the breakers for these valves were

not locked. The licensee took immediate action to correct this deft-

ciency. This represents a deviation from the commitment described

i above (50-213/86-17-07).

7.3.3 Common Enclosure Concern

The common enclosure concern is found when redundant circuits are routed

together in a raceway or enclosure and they are not electrically pro-

tected or when fire can destroy both circuits due to inadequate fire

barrier penetrations.

The team did not identify any unacceptable conditions in this area

that were not covered by the switchgear exemption.

8.0 Emergency Lighting

,

10 CFR 50,' Appendix R,Section III.J., requires that emergency lighting units

with at least an 8-hour battery power supply shall be provided in all areas

needed for operation of safe shutdown equipment and in access and egress

routes thereto. The team examined the plant emergency lighting system to

ascertain the licensee's compliance with the above requirements. The team

identified the following unacceptable condition:

Inadequate Emergency Lighting

During the safe shutdown procedure walkthrough, described in section 7.2.2

of this report the team observed that the operators had to climb down into

.. the charging pump cubicles to operate valves No. BA-MOV-32, BA-M03-373 and

'

CH-M0\'-257. The team observed that there were no emergency lights in either

I

of the charging pump cubicles. The team also observed that the operators

.

'

would have to use portable lights to make instrument connections and take

readings in the cable vault room.

The lack of emergency lights in the two charging pump cubicles and

adequate permanent lights in the cable vault constitutes a violation of 10

CFR 50 Appendix R, section III.J. (50-213/86-17-08) ,

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CYAPC0 committed to provide eight hour battery powered emergency lighting

in fire area A-1B and A-1C (charging pump area) trained on BA-MOV-32,

BA-M03-373 and CH-M0V-257 and assure that illumination to access / egress

routes to these valves is available. This lighting will be installed by

January 1, 1987.

9.0 Oil Collection System for Reactor Coolant Pumps

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

shall be equipped with an oil collection system if the containment is not

inerted during normal operation. The oil collection system of the reactor

coolant pumps for Haddam Neck were inaccessible for inspection.

10.0 Unresolved Items

Unresolved items are matters for which more information is required in order

to ascertain whether they are acceptable, violations, or deviations.

11.0 Conclusions

The licensee did not meet the requirements of 10 CFR 50, Appendix R,

Section III.G in at least 2 instances where violations against these

requirements were identified. The licensee also does not meet the III.G

redundant train separation requirements in the plant areas listed in

Section 3. A schedular exemption for meeting these requirements is

pending with NRC.

The NRC plans to conduct a reinspection of the areas affected by this

schedular exemption. The licensee did not meet the Appendix R, Section

III.J requirements in at least 3 instances where a violation for missing

emergency lights was identified.

Because of the plant status the team could not enter containment to per-

form an inspection of the Reactor Coolant Pump oil collection system.

A summary of the findings appears as Attachment 3 to this report. In all

four (4) potential violations; one (1) deviation and three (3) unresolved

items were identified.

12.0 Exit Interview

The inspection team met with the licensee representatives, denoted in Section

1.0, at the conclusion of the inspection on June 20, 1986, and the team

leader summarized the scope and findings of the inspection at that time.

The team leader also confirmed with the licensee that the report will not

contain any proprietary information. The licensee agreed that the inspection

report may be placed in the Public Document Room without prior licensee

review for proprietary information (10 CFR 2.790).

At no time during the inspection was written material provided to the licen-

see by the team.

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Attachment 1

List of Licensee Commitments By Fire Area

to Support Exemption Requests

Service Building Control Room Fire Area S-1

i

1. Perform a human factors review demonstrating that operators can perform

the necessary safe shutdown actions outside the control room in a timely

and effective manner.

2. Perform one inspection per shift to limit transient combustible materials.

3. Implement administrative controls to limit transient combustible materials.

4. Install ramps around the auxiliary control panels and one section of the main

control board to channel away any flammable liquids and seal all openings

between the cabinets and the floor.

5. Install a Halon suppression system in the control room with detection con-

sisting of both ionization and photoelectric sensors which initiate the

suppression system automatically.

6. Develop alternate operator procedures that demonstrate:

• Operability to safe shutdown with loss of the main control board or

auxiliary control cabinets.

Spurious operation of affected equipment can be compensated for using

either a system's approach or a loss of adjacent panel section analysis.

• Actions being taken outside the control room are achievable considering

a fire in the control room, time needed to accomplish the function and

manpower required.

Provisions will be included which direct the plant operators to verify water

levels in the tanks credited in the safe shutdown concept for the Haddam Neck

,

'

plant. Included will be the Demineralized Water Storage Tank (DWST), the

Primary Water Storage Tank (PWST) and the Refueling Water Storage Tank

(RWST).

7. Provide a safety system lock-out panel which contains circuitry to override

spurious operation of PORVs and MSIVs in the control room.

8. Position the following valves in their proper positions and lock the assoc-

iated valve breakers open at the motor control center:

. _ . , _ . _ _ __ __

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Attachment 1 2

RC-MOV-510 RCS Loop 1 Bypass Valve

RC-M0V-515 RCS Loop 2 Bypass Valve

RC-M0V-528 RCS Loop 3 Bypass Valve

RC-MOV-577 RCS Loop 4 Bypass Valve

DH-MOV-310 Reactor Coolant Drain

Header Throttle Valve

SW-MOV-30 Service Water to Turbine

Oil Cooler Isolation Valve

MOV-298 Auxiliary Pressurizer Spray

Valve

9. Modify a 4,160 volt emergency diesel generator output breaker, a charging

pump breaker and a 480 volt load center transformer feedbreaker to facilitate

manual operation.

10. Submit proposed Technical Specification for administrative controls of

flammable liquids in the control room.

11. Protect four valves (two loops) of the following valve control circuits

from fire induced hot shorts:

MOV-538 RCS Loop 1 Hot Leg Isolation

MOV-546 RCS Loop 1 Cold Leg Isolation

MOV-526 RCS Loop 2 Hot Leg Isolation

MOV-537 RCS Loop 2 Cold Leg Isolation

MOV-513 RCS Loop 3 Hot Leg Isolation

MOV-524 RCS Loop 3 Cold Leg Isolation

M0V-501 RCS Loop 4 Hot Leg Isolation

MOV-512 RCS Loop 4 Cold Leg Isolation

Service Building Switchgear Room (Fire Area S-8)

l

1. Install a new safety-related 480 volt load center.

l

l

As a minimum the following components and their associated cables should

be protected from a switchgear room fire:

a. Power supplied from Bus 9

b. The feedwater to new MCC 6

c. Component Cooling Pump P-13-1B

d. Service Water Pump C

e. RHR Pump 1B

f. Charging Metering Pump (P-11-1A)

2. Install a new safety related 480 volt motor control center.

As a minimum the following components and their associated cable should

be protected:

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4

Attachment 1 3

a. Supply to Battery Charger IB.

b. Main Lube Oil Pump for Charging Pump A

c. Diesel Generator 2B, AC

Distribution Cab ECP-2B

d. Valve CH-MOV-290 (Valve presently locked close)

e. Valve CH-MOV-257

f. Valve CH-A0V-278

g. Valve BA-M0V-373 or BA-MOV-32

h. Valve SW-MOV-1

1. Valve SW-MOV-4

j. Fuel Oil Transfer Pump B

k. Primary Water Transfer Pump P-29-1B

1. RCS Loop Isolation Valves (2 loops)

3. Relocate one of the station batteries to the south end of the switchgear room.

4. Relocate all four static inverter vital bus power supplied to two diverse

locations.

5. Relocate one battery charger and DC bus to the south end of the switchgear

room.

6. Reroute two channels (one battery-related division) of instrumentation cable

identified for safe shutdown for Appendix R. The cable to be rerouted origi-

nates in the control room and terminates in the containment cable vault.

7. One division of required cables not in compliance with the 20' separation

requirements will be enclosed in a one-hour fire rated barrier.

8. Provide a safe shutdown instrumentation panel remote from the control room

including indication for:

Pressurizer Level

Pressurizer Pressure

• Steam Generator Level

• Steam Generator Pressure

Reactor Coolant System Temperature (hot leg or in-core thermocouples

and cold leg)

• Source Range Neutron Monitor

9. Upgrade the metal wall section of the barrier between the Switchgear Room

and the Turbine Building to a 3-hour rating.

Primary Plant Containment Cable Vault (Fire Area R-1)

1. Two channels of safe shutdown instrumentation will be rerouted to provide

physical separation as required by Appendix R,Section III.G.2.b with an

exemption from the requirement for no intervening combustibles. The instru-

mentation circuits involved are pressurizer level, pressurizer pressure,

steam generator level, steam generator pressure, reactor coolant system temp-

erature, and source range nuclear instrumentation.

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Attachment 1 4

2. Redundant cables (conduit runs) that have a physical separation of less

than 20' will be separated by a one-hour fire barrier in conformance with

Section III.G.2.c of Appendix R.

3. Redundant cables (conduit runs) that have a physical separation of less than

20' will be separated by a noncombustible radiant energy shield in accordance

with Section III.G.2.f of Appendix R.

Primary Plant Auxiliary Feedwater Pump Room (Fire Area R-2)

Install an early warning fire detection system for this area.

Screenwell Pumphouse Pump Motor Room (Fire Area P-1)

1. Provide an automatic water curtain around the four service water pumps

designed to separate Pumps A and B from Pumps C and D.

2. Provide curbing / diking to separate service Pumps A and B from Pumps C and D.

3. Provide a one-hour rated fire barrier for cable runs for service water Pumps

A and D at elevation 8'0".

4. Provide sprinkle. protection around the electric fire pump and upgrade the

wall which separates the pump area from the diesel fuel storage tank.

5. Provide a one-hour barrier or wrap for the electric fire pump power cables.

6. Reroute the electric fire pump control cables.

Service Water Pump Cable Duct Bank (Fire Area H-1)

1. Provide a one-hour rated wrap for one set of redundant service water pump

cables within the manhole.

I 2. Reroute the electric fire pump cables in the manhole.

!

Charging Pump Pits and RHR Pump and Heat Exchanger Areas (Fire Area A-1)

I

i 1. Reroute RHR pump 1B cable outside this fire zone.

I

2. Reroute cable for BA-MOV--32 outside this fire zone.

l

l

3. Replace door (S-3/A-1) with a three-hour door at the respirator fit area.

( 2 )

l

In Fire Zones A-1B and A-IC

,

1. Valve (BA-MOV-32) and its associated cable (s) will be protected from the

effects of a fire in the charging Pump A pit, by a one-hour wrap.

In Fire Zone A-10

i

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1. Bottled air will be supplied to the charging metering pump (P-11-1A) and

the charging metering pump suction valve (CH-A0V-278).

l

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. _ .

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t a o

i,

i

Attachment 1 5

2. The cable to these components will be rerouted outside of Fire Zone (A-1A)

or wrapped.

3. Install a three-hour rated damper in the HVAC duct at the common wall between

charging Pump A and the charging metering pump.

In Fire Zone A-1E and A-1F

1. Install curbing to access of the RHR pump room.

2. Seal the access hatchways from the operating floor (elevation 21'6").

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Attachment 2

Correspondence List

Haddam Neck, Fire Protection

January 13, 1981 W. G. Counsil letter to D. G. Eisenhut.

Status of open items 3.1.18, 3.2.'., and 6.0 in response to

11/25/80 letter from D. G. Eise.aut.

February 20, 1981 D.G.EisenbutlettertoAllPowerReactorLicenseeswith

Plants Licensed prior to January 1, 1979.

Generic Letter 81-12, Fire Protection Rule 45 FR 76602.

Request for information concerning alternative safe shutdown

capability.

February 20, 1981 W. G. Counsil letter to R. T. Carlson.

Response to 2/4/81 deviation report from Inspection

50-213/81-01, relating to Item 3.1.1.

March 19, 1981 W. G. Counsil letter to J. Hendrie.

Requested schedular exemption for providing plans, and schedule

for review of safe shutdown against III.G.2 of Appendix R.

4 Committed to compliance to III.J of Appendix R.Section III.0,

oil collection system requirements, exemption requested.

May 5, 1981 D. G. Eisenhut letter to All Licensees of Operating Water

Nuclear Power Reactors and Applicants for Operating Licenses

May 11, 1981 W. G. Counsil letter to D. G. Eisenhut.

Summary of the provisions of 10 CFR 170, with payment for

one (c) class III and one (1) Class II Amendment request.

Submitted fee for oil collection system exemption request.

May 12, 1981 H. R. Denton letter to W. G. Counsil.

The 3/19/81 request for exemption from 10 CFR 50.48(c)(5)

regarding compliance with 10 CFR 50 Appendix R, Items III.G

and III.L is under review.

May 13, 1981 W. G. Counsil letter to D. G. Eisenhut.

Response to 2/20/81 letter from D. G. Eisenhut, Generic Letter 81-12. Lists bases for not responding to the Generic Letter

information request at this time.

June 2, 1981 W. G. Counsil letter to D.M. Crutchfield.

Proposed amendment to operating license DPR-61, incorporating

proposed revisions to Technical Specifications. These changes

identify the limiting conditions for operation, surveillance

requirements appropriate for the systems, and design features

implemented in accordance with the 10/3/78 NRC SER.

.

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Attachment 2  ?

l

June 23, 1981 W. G. Counsil letter to D. G. Eisenhut.

Amplification of status and position regarding implementation

of outstanding Appendix R requirements. Request for exemption

from 50.48(c)(5) until 2/1/82.

November 6, 1981 W. G.Counsil letter to D. G. Eisenhut.

Documents NU belief that an exemption from 50.48(c)(2) and

(c)(3) is needed, and requests this exemption.

November 11, 1981 H. R. Denton letter to W. G. Counsil.

Exemption from certain requirements of Section 50.48 and

Appendix R to 10 CFR Part 50 (in regards to reactor coolant

pump oil collection system), in response to W. G. Counsil

letter dated 3/19/81.

November 20, 1981 D. M. Crutchfield letter to W.G. Counsil.

Amendment No. 45 to Facility Operating License No. DPR-61,

adding operability and surveillance requirements for fire

protection equipment.

January 15, 1982 W. G. Counsil letter to D. G. Eisenhut.

Request exemption until 3/1/82 concerning 10 CFR 50.48(c)(2),

(c)(3) and (c)(5).

March 1, 1982 W. G. Counsil letter to D. G. Eisenhut.

Haddam Neck Plant Fire Protection Appendix R Review. Plans

and schedules to comply with III.L and III.G, Alternate and

Safe Shutdown Capabilities.

May 10, 1982 H. R. Denton letter to W. G. Counsil.

Grants schedular exemption until 3/1/82 for submitting plans

and schedules for demonstrating conformance to Appendix R as

requested in W. G. Counsil letters to D. G. Eisenhut, dated

1/15/82, 6/2/381, and Hendrie dated 3/19/81. Requested addi-

tional specific information on exemption requests filed on

March 1, 1982.

June 3, 1982 C. G. Tropf letter to CYAPCO.

Summary of 5/13/82 meeting of the joint staffs concerning

Appendix R fire protection for the Haddam Neck Plant.

June 22,.1982 D. M. Crutchfield letter to W. G. Counsil.

SEP Topic IX-6, Fire Protection, is considered complete

for the purpose of conducting the integrated assessment.

• The B-41 generic review will be conducted independent

of SEP.

July 16, 1982 W. G. Counsil letter to D. G. Eisenhut.

Provided supplemental information to that in 3/1/82 letter,

to justify the requested technical exemptions.

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Attachment 2 3

July 30, 1982 W. G. Counsil letter to R. A. Clark and D. M. Crutchfield.

Clarifications of Appendix R reviews concerning fire barriers

and partial suppression.

October 6, 1982 D. G. Eisenhut letter to Licensees and Applicants of fluclear

Power Reactors.

Generic Letter 82-21, Technical Specifications for Fire Pro-

tection audits.

December 9, 1982 P. B. Erickson letter to CYAPCO.

Summary of the 12/1/82 fire protection meeting: CYAPC0 pro-

posed several revisions to their Appendix R exemption request,

and will submit a formal revision to their exemption request

by 12/15/82.

December 15, 1982 W. G. Counsil letter to D. G. Eisenhut.

Provides information intended for presentation at, and agree-

ments reached during, the 12/1/82 Bethesda meeting (to aid

staff in finalizing the F.P. SER)

January 31, 1983 W. G. Counsil letter to D. G. Eisenhut.

,

Fire Protection program probabilistic risk assessment.

January 31, 1983 W. G. Counsil letter to D. G. Eisenhut.

Additional information regarding CYAPCO's control room exemp-

tion request. Evaluation of control room panel fires.

March 30, 1983 W. G. Counsil letter to D. G. Eisenhut.

Responses to information requested in Generic Letter 81-12

regarding alternate shutdown, as additional information con-

cerning the Control Room Fire Review.

April 22, 1983 W. G. Counsil letter to D. G. Eisenhut.

Responses to information requested in Generic Letter 81-12

regarding alternate shutdown, as additional information con-

cerning the Control Room Fire Review.

April 22, 1983 W. G. Counsil letter to D. G. Eisenhut.

Additional clarification concerning the design of the control

room auxiliary panels, specifically the enclosures, in regards

to their ability to prevent the spread of fire.

May 10, 1983 W. G. Counsil letter to D. G. Eisenhut.

Documents agreements reached during the 5/5/83 conference

call regarding provisions for alternate control room instru-

mantation (T cold and S.G. pressure).

June 22, 1983 E. L. Jordan letter to all OLs and cps.

IE Information Notice 83-41: Actuation of fire suppression

l

system has, in some cases, caused inoperability of safety-

l

related equipment.

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Attachment 2 4

October 19, 1983 D. G. Eisenhut letter to all Licensees and Applicants

of Nuclear Power Reactors.

NRC positions on certain requirements of Appendix R

(Gen. Letter 83-33)

October 21, 1983 E. L. Jordan letter to all Nuclear OLs and cps.

IE Information Notice 83-69: Improperly installed

fire dampers at nuclear plants.

November 4, 1983 W. G. Counsil letter to D. G. Eisenhut.

Control Room Fire Review supporting exemption from

10 CFR 50 Appendix R. Documents information on control

room evacuation presented at the 10/13/83 meeting with

the NRC.

December 21, 1983 W. G. Counsil letter to D. G. Eisenhut.

Clarification of Control Room Fire Review supporting

exemption from 10 CFR 50 Appendix R. Documents CYAPCO's

position on evacuation of the control room and the

ability to safely shutdown the plant.

February 13, 1984 E. L. Jordan letter to all OLs and CP Holders.

IE Information Notice 84-09: Lessons learned from

Apoendix R audits, including " fire areas" definition,

barrier testing, intervening combustibles, partial

detection and suppression, safe shutdown equipment,

oil collection system requirements.

March 13, 1984 T. E. Murley letter to W. G. Counsil .

Notification of Appendix R workshop to be held in PA

on 4/18/84. Workshop to address topics in 2/13/84 IE

Information Notice 84-09, and topics relating to the

safe shutdown inspections that have been made.

May 17, 1984 W. G. Counsil letter to T. E. Murley.

• In the three year interval from the effective date

of the license condition until 12/31/81, a fire

brigade drill critiqued by an independent individual

was not documentea.

In accordance with item 3.d of Section I of

Appendix R, CYAPC0 has conducted a tri-annual fire

brigade drill critiqued by individuals independent

of the licensee's staff in the period since 12/31/81.

June 18, 1984 W. G. Counsil letter to R. H. Vollmer.

Informational letter concerning the Appendix R

evaluation status.

CYAPC0 intends to conduct a revalidation and veri-

fication of the completeness and accuracy of their

previous submittals on Appendix R, the review

being currently scheduled for completion at the

end of 1984.

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Attachment 2 5

July 20, 1984 R. W. Starostecki letter to W. G. Cou1sil. '

Inspection Report No. 50-213/84-07. This includes some

follow-ups on previous findings:

Closed the item concerning revision of the fire protec-

tion program to reflect the current practice of having

audits conducted by off-site personnel.

Closed the item concerning a previous violation relating

to licensee failure to perform fire damper inspections.

October 15, 1984 W. A. Paulson letter to W. G. Counsil.

" Notice of Environmental Assessment and Finding of No Signi-

ficant Impact" regarding the Haddam Neck plant's requests for

exemption from the requirements of Appendix R to 10 CFR 50.

November 1984 10 CFR 50 Appendix "R" Review, prepared by CYGNA Energy

Services.

November 14, 1984 J. A. Zwolinski letter to W. G. Counsil.

Exemptions in seven fire areas from the requirements

of Item III.G.2.

Exemptions in one fire area from the requirements of

Item III.G.2 and III.G.3.

December 17, 1984 IE Information Notice No. 84-92: Cracking of Flywheels on

Cummins Fire Pump Diesel Engines

January 9, 1985 D. G. Eisenhut letter to All Power Reactors Licensees and

All Applicants for Power Reactor Licenses.

NRC Fire Protection Policy Steering Committee Report,

dated 10/26/84 (Generic Letter 85-01)

January 31, 1985 E. L. Jordan letter to all Nuclear Power Reactor Facilities

Holding an OL or a CP.

IE Information Notice No. 85-09: " Isolation Transfer Switches

and Post-Fire Shutdown Capability." The notice alerts of

potential deficiencies in the electrical design of isolation

transfer switches installed cutside the control room.

February 14, 1985 W. G. Counsil letter to J. A. Zwolinski.

'

, In order to comply with an NRC basis for granting an exemption

l from certain Appendix R requirements for the CY control room,

! CYAPC0 reaffirms its earlier commitment to install a ramp

to divert spilled flammable liquid away from the auxiliary

control panels and the back of the main control console

(and defines the word " ramp.")

July 1,1985 J. F. Opeka letter to J. A. Zwolinski. (B11581) ,

Human factors review for fire protection.

August 15, 1985 J. F. Opeka letter to J. A. Zwolinski .

Status of Appendix R modifications.

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.

s .

.

Attachment 2 6

August 16, 1985 J. F. Opeka letter to J. A. Zwolinski.

Control Room Halon Fire Suppression System

August 30, 1985 J. F. Opeka letter to T. E. Murley.

Combustible Gas Detectors

.

September 16, 1985 J. F. Opeka letter to H. L. Thompson.

Additional information and clarification for Appendix R.

October 31, 1985 E. L. Jordan letter to J. F. Opeka.

IE Information Notice 85-85 - System Interaction Event

resulting in Reactor System Safety Valve opening following

fire protection Deluge System malfunction.

January 13, 1986 C. I. Grimes letter to J. F. Opeka concluding that concerns

raised in IPSAR Section 4.24.2 have been resolved.

January 14, 1986 E. Z. Wenzinger letter to J. F. Opeka forwarding results

of Inspection 50-213/85-21.

February 6, 1986 J. F. Opeka letter to C. I. Grimes.

Apnendix R Exemption Request #4 Fire Door #1 between the

control room and turbine building will be replaced during

present outage.

February 21, 1986 J. F. Opeka letter to C. I. Grimes.

Proposed revision to technical specification fire

detection and spray system.

March 7, 1986 J. F. Opeka letter to C. I. Grimes.

Fire Protection - Schedular Exemption Request Appendix R

Modifications.

March 24, 1986 E. L. Jordan letter to All Nuclear Power Reactor

Facilities.

IE Information Notice No. 86-17 update of failure of

automatic sprinkler system valves to operate.

April 28, 1986 C. I. Grimes letter to J. F. Opeka.

Notice of environmental assessment and finding of no

significant impact regarding September 16, 1985 appli-

!

cation for Appendix R exemptions.

April 30, 1986 J. F. Opeka letter to C. I. Grimes.

Fire Protection - Deletion of Charging Pump Low Suction

_

Pressure Trip.

May 13, 1986 J. F. Opeka letter to C. I, Grimes,

t Fire Protection - Lab test results discussing the physical

properties of concrete masonry blocks credited as fire

,

barriers.

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Attachment 2 7

l May 21, 1986 J. F. Opeka letter to C. I. Grimes

'

Status of Appendix R modifications

May 28, 1986 J. J. Shea letter to Northeast Nuclear Energy Company

(NNECO). ,s

Summary of May 14, 1986 meeting to discuss the status'

of outstanding fire protection review issues.

May 29, 1986 S. D. Ebneter letter to J. F. Opeka.

Fire protection safe shutdown inspection.

May 30, 1986 J. F. Opeka letter to C. I. Grimes.

Proposed revision to technical specifications - control

room fire detectors.

May 30, 1986 J. F. Opeka letter to C. I. Grimes, A. C. Thadant ,

V. S. Noonan.

Proposed revision to technical specifications - fire

protection audits.

June 10, 1986 J. F. Opeka letter to C. I. Grimes.

Comments on the Appendix R Safety Evaluation Report.

F.

. .. . .

'.

Attachment 3

Summary of Findings

Item Finding Subject

86-17-01 Violation of Control Room Halon Suppression System Test

Appendix R III.G Fail to meet the Commitment made to NRC

86-17-02 Unresolved Halon System in Existing Switchgear Room

86-17-03 Violation of Inadequate Cooldown Analysis for Steam

Appendix R III.G Relief Using S.G Vents

86-17-04 Unresolved Control Room Habitability

86-17-05 Unresolved Component Cooling Water System Not Included

in the FPER

86-17-06 Violation of Inadequate Breaker Coordination Setting

T.S. 6.8.1 Procedures

86-17-07 Deviation RCS Loop Bypass Valves MCC Breaker Not Locked

86-17-08 Violation of Inadequate Emergency Lighting-

Appendix R.III.J

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