IR 05000445/1987022

Insp Rept 50-445/87-22 on 871019-23.No Violations Noted. Major Areas Inspected:Implementation of Fire Protection Program & Compliance W/Branch Technical Position CMEB-9.5-1, Fire Protection for Nuclear Power Plants

ML20195J046
Person / Time
Site:	Comanche Peak
Issue date:	01/11/1988
From:	Kelley D, Mckee P, Singh A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20195J034	List: IR 05000445/1987022 ML20195J029 ML20195J046
References
50-445-87-22, NUDOCS 8801200459
Preceding documents:	ML20245B810 (14 April 1989)
Download: ML20195J046 (31)

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-U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS NRC Inspection Report: 50-445/87-22 Construction Permit: CPR-126 Docket No: 50-445 Applicant: TU Electric Skyway Tower-400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES),

Unit 1 Inspection At: Comanche Peak Site, Glen Rose, Texas Inspection Conducted: October 19-23, 1987 Inspectors: W"I Y '4 b\

Amarjit Singhi, Reactor Operation Engineer

//G/N Date 0ffice of Spec'al Project htsnt -7 ~

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Den'nis Kelley, Senior' Resider}t / inspector Comanche Peak Steam Electric Mation Also participating and contributing to the report were:

Harvey Thomas, Brookhaven National Laboratory (BNL)

Anthony Fresco, BNL Thomas Storey, Science Application International Reviewed by: !-- .

Phillip F.6McKee, Deputy Director l/h/E

'Da te Comanche Peak Project Division Office of Special Projects Inspection Summary Inspection Conducted October 19-23, 1987 (Report 50-445/87-22)

Areas inspected: Special announced inspection of the implementation of fire protection program and compliance with Branch Technical Position (BTP)

CMEB 9.5-1, Fire Protection for Nuclear Power Plants," (formerly Appendix A to BTP APCSB 9.5-1); per FSAR commitments and SER evaluatio Results: Within the areas inspected, no violations were identifie >

8801200459 880111 PDR ADOCK 05000445 g PDR

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DETAILS 1.0 Persons Contacted TV Electric R. Bab, Fire Protection Engineer J. Barker,10 Electric H. Beck, CPE/FP C. Becket, CPE/FP M. Blevins, TU Electric J. Boothroyd, TU OPS B. Browning, Startup F. Cobb, Pro C. Creamer, Project ISE Engineer P. Desar, CPE/ISC J. Disewwright, TV Electric T. Evans, CPE/EE D. Fuller, TU Electric W. Grace, TV Electric (Nuc Ops) '

R. Howe, EPM /FP J. Jamer, CPE/ MECH J. Kelly, TV Electric J. LaMarca, CPE/EE B. Lancaster, TV-Electric 0. Lowe, TV Electric R. Laytun, Fire Protection Coordinator F. Madden, CPE-MECH S. Popek, CPE/FP J. Reywerson, TV Electric W. Rowe, CPE/ civil E. Scott, TV Electric Smith, TU Electric Terrel, TV Electric hoodlen, TV Electric IMPELL John Echternacht Steven Einbinder Kevin C. Warapius John Wawreeniak SWEC J. T. Conly Thomas G. Persurer D

Enrique Margalejo

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2.0 Background and Inspection Approach This report documents findings during an inspection conoucted by Mr. Singh and Mr. D. Kelley of the Office of Special Projects (OSP), Mr. T. Storey of Science Applications Internatinnal Corporation (SAIC) and Messr H. Thomas and A. Fresco of Brookhaven National Laboratory during the period October 19-23, 198 The fire protection program for Comanche Peak Steam Electric Station (CPSES) is described in the applicant's Fire Protection Report (Ref. A.1)

and the FSAR. The applicant is committed to the Fire Prctection Program of Appendix A to APCSB 9.5-1, as modified by applicant correspondence to the

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NRC that docunents additional concitments and deviations from FSAR censni tments . Supplement 12 to the Safety Evaluation Report (NUREG-0797)

issued in October 1985 presents the staff review of the CPSES Fire Protection Program. In Supplen,ent 12 the staff reviewed the applicant's program against branch Technical Position (BTP) CMEB 9.5.1, which superseded Appendix A to BTP APCSB 9. Among other changes, the criteria of Appendix R to 10 CFR Part 50 were factored into GTP CMEB 9. TUEC letter dated October 9, 1987 provided the staff with an advance copy of a change to the FSAR sections relative to the fire protection program.,

TUEC letter dated October 2, 1987 provided the staff with revised deviations to BTP APCSB 9.5-1 Appendix A and 10 CFR 50, Appendix A site inspection of the CPSES fire protection program was conducted during October 29 thrcuch November 2, 198 The inspection was documented in Inspection Report (IR) 50-445/84-44. This inspection (hereafter referred to as 84-44 inspection) included personnel from the Office of Nuclear Reactor Regulation, Regico IV and the Of fice of Inspection and Enforcement and resulted in a number of open item Areas examined during the 84-44 inspection included establishment and implementation of the fire protection program and compliance with the requirements of BTP "Fire Protection for Nuclear Power Plants," per FSAR ccnmitments and SER evaluation. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, ar.d observations by the inspector During this inspection, open items resulting from previous NPC audits and inspections were reviewed. The results of these reviews are included within this repor .0 Fire Protection Program Requirements Fire Protection Program In SSER 12, the staff stated that the fire protection progran meets the guidelines of BTP CMEB 9.5-1 and is therefore, acceptable. During the 84-44 inspection, the inspectors found that the applicant's procram did not specifically designate responsibility for fire brigade training and maintenance of training records. In addition, the inspectorc found that the prcgram dio not identify that a QA program was established for the fire protection program (Unresolved item 445/8444-0-01,1st item).

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During this inspecticn the applicant prasented procedure FIR-101, "Fire Protection Program" which had been revised to address the staff concerns stated above. The revisions were found to adequately address the assignment of fire brigade training and records maintenance responsibilities and clearly established that a QA program would te provided for fire protection. Open Item 445/8444-0-01, 1st item, is therefore close .2 Fire Hazards Analysis In SSER 12, the staff concluded that the fire hazards analysis (FHA)

met the guidelines of BTP CMEB 9.5- The applicant has since revised the FHA and has incluced it in the Fire Protection Report dated September 22, 1987. Revisions to the FHA reflect changes in p bnt design or changes in the Fire Safe Shutdown Analysis report. As a result of this revision, a new deviatien relating to the RHR isolation valves was identified. Also, a number of changes to previous deviations were n.ade. Where these changes may have affected previous staff evalua-tions, they are discussed in this inspection repor The new deviation is discussed in Section 4.2 of this repor .3 Administrative Ccr,trols The staff concluded in SSER 12 that the administrative controls identified by the applicant met the guidelines of BTF CMEB 9.5- During the 84-44 inspection, four items were identified where ac'ministrative procedures were inaaequate. The items were as follows:

Failure to designate who is respcnsible for obtaining a fire permit for controlling ignition source (0 pen Item 445/0444-0-01, 4th itea)

Failure to delete a temporary instruction for protection of the new fuel area af ter the permanent procedure was in plac (0 pen Itera 445/8444-0-01, 5th item)

Discrepancies between the proposed Technical Specifications and the fire protection surveillance procedure (0 pen Item 445/8444-0-02)

Failure to include a fire pump performance curve in the preoperational test procedure. (0 pen Item 445/8444-0-03)

L;uring this inspection the applicant demonstrated that all of the above aentioned discrepancies had been addressed in revisions to prc:edure These procedures weta, reviewed during the inspection ard found acceptabl The above listed open items are therefore close .4 Fire Brigade and Fire Brioade Training In SSER 12, the staff stated that the fire brigade and fire brigade training program meet the guidelines of BTP CMEB 9.5- During the 84-44 inspection, the definition of the fire brigade compositicn was

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found to be in conflict with several plant procedures (0 pen Item 445/84-44-0-01, 3rd item). Also, the applicant's fire protection training procedure did not adequately address the tracking of the continuing qualification-of fire brigade ren.ber During this inspection, the team reveiwed the fire brigrade training records and the revised fire protection training procedures and found them acceptable. Therefore, these issues are considered resolved and Open Item 445/844-0-01, 3rd item, is close .5 Reactor Coolant Pump (RCP) Oil Collecticn System An inspector reviewed the installation of the RCP oil collection syste The inspector luoked at two of the four RCPs and verified that all external potential leakage areas were adequately covered and would drain oil into a separate collection tan The design drawings were reviewed and the inspector confirmed that each collection tank was desigred to hold all of the oil inventory from its associated pump. During the inspection the applicant stated that seismic analysis for the RCPs had not been conpleted to verify that the system was seismically qualifie This item is considered open pending completion of the analysis by TV .

Electric (445/8722-0-01).

4.0 General Plant Guidelines 4.1 Building Design Section D.1.j of Appendix A to BTP APCSB 9.5-1 states that floors, walls and ceilings enclosing separate fire areas should have a minimum fire rating of three hours, including penetration seals, fire coors and damper The staff stated in SSER 12 that all fire rated assemblies are tested for three hours in accordance with American Society for Test t.g and Materials (ASTM) E 119, are designed in accordance with three-hour-rated fire barrier designs obtaineo f rom the fire Resistance Directory published by Underwriters Laboratories (UL), or are constructed of 8-inch-thick reinforced concrete in accordance with the "Uniform Building Code" (International Conference of Building Code Officials)

for a minimum fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The staff concluded in SSER 12 that the fire-rated walls and floor / ceiling assemblies are provided in accordance with the guidelines of BTP CMEB 9.5-1 fection C.5.a and are therefore acceptabl During this inspection several barriers separating redundant trair.s of safe shutdown equipment were identified by the inspector as not being three-hcur-rated. Specifically, unrated steel hatches were located in fire area bouncaries. The applicant presented an analysis which stated that cue to low combustible loacing on either side of the hatches, automatic suppression on at least one side of the hatch and a one hour fire resistive coating on both sides cf the hatch, it was not likely that a fire would propagate through the hatch. The inspector reviewed the analysis and found it acceptable. However, it was identified that this was a deviation from Section 0.1.j of Appendix A to BTP APCSB 9.5-1 and must be identified as such in the FSAR. The applicant comitted to

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identify these unrated steel hatches in a future FSAR amendment. This item is considered open penaing submittal by the applicant of an FSAR amendment addressing this oeviation (445/8722-0-02).

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Section D.4 (f) of Appendix A to BTP APCSB 9.5-1 states that "Stairwells, elevators and chutes should be enclosed in casonry towers with minitrum fire rating of three hours...." In Acenament 65 to the FSAR, the applicant identified as a ceviation that stairwells providing access and egress rcutes to areas containing safe shutdown equipment were provided with two hour rated barriers. Due to the negligible combustible leading inside stairwells and the lack of safe shutdown equipment being separated by the stairwell walls, the inspector founo nc major issues with applicant's stairwell boundaries. Acceptance of the deviatio1 frcm Section D.4(f) of Appendix A to BTP APCSB 9.5-1 will be addressed ,y the staff in their review of Amendment 65 to the FSA A number of stairwell walls were identified during the inspection where the inspector considered the justification was not adequate to support two hcur rated construction. The applicant presented an evaluation which was cenducted to determine the rating of fire area and stairwell tcundaries. This evaluation was used to justify the fire rating of those, boundaries which were not built specifically to the specifications cf an indepencent testing organization. Where specific installation criteria of a recognized approval E.gency was not followed, the evaluation was used to determine if criteria were cet or exceeded in such items as wall thickness and material type. The inspector identified six stairwell walls that could not be directly related to the installation criteria established by a recognized approval agency. The applicant has comitted to take actions to resolve this issue. Pending actions taken by the applicant to resolve this issue and NRC review ct those actions, this item is considered unresolved (445/8722-u-01).

Appendix A to APCSB 9.5-1 Section D.1.(j) states that "Penetrations in fire barriers, including conduits and piping, should be sealed or closed to provide a fire resistive rating at least equal to that of the fire barrier itsel Door openings should be protected with equivalent ratea coor frcmes and hardware that have been tested ano approved by a nationally recognized laboratory." During the inspection, the inspector expressed concern that the method of sealing conduits four inches in diameter and smaller was not in accordar.ce with rated configurations and had not been identified as a deviation from staff guidance. The applicant stated that conduits with either suppression or aetection on both sides of the penetration would only be sealed on one siae while conduits with no detection or suppression en at least one side would be sealed on both s1ces at the first opening. The inspector was ccncerned that this plan would allow for only one seal outside of the barrier in locations where their was only detection en both sides of the barrier with no suppression on either side. The applicant agreed to revise their

! position and committed to seal conduits four inches and smaller on both i sides at the first opening regardless of the presence of detection or l suppression. This item is considered open pending the completion of the seal installaticn (445/8722-0-03).

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In NRC Inspection Report 50-445/85-16; 446/85-13 concerns were raised that certain BISCO seals used at the plant may not have adequate documentattun to justify the rating of tha sea Specifically, American Nuclear Insurers (ANI) had identified a seal being used by BISCO which had failed a fire test. During this inspection the inspector reviewed dccumentation presented by the applicant which demonstrated that the BISCO seals being installed at the plant were acccmpanied by documentation which demonstrated that the seals had passed fire tests. The inspector found the uocumentation acceptable and therefore Unresolved Items 445/8516-U-06, 446/8513-U-06 and 445/8516-U-07, 446/8513-U-07 are therefore close During this inspection a nunber of modifications to fire doors, primarily for security hardware, were observed. Although the doors and frames contained labels which demonstrated compliance with testing criteria of Underwriter's Laboratory, the inspector was concerned that these modifications would degrade the perfurmance of the door under fire conditions. The applicant presanted documentation from Underwriter's Laboratory concerning how security modifications could be made without jeopardizing the ratina of the door. Hcwever, these guidelines may not have been implemented during modification of the plant fire doors. The applicant committed to review all fire donrs presently installed to determine if .

modifications comply with guidance provided by Underwriter's Laborator Where compliance cannot be established, the applicant committed to bring the dcor into compliance or replace the door with one that conforms to the guidelines. The applicant also committed to ensure that all future modifications will conform to the guidance established by Underwriter's Labora tory. This item is considered open pending the completicn of applicant's review of this issue (445/8722-0-04).

SSER 12 addressed a number of ceviaticns dealinn with heating, ventilation and air conditioning (HVAC) penetrations of fire rated barriers. Due to demonstrated difficulties in the operation of these dampers under air flow concitions, the applicant has instituted a prograra to completely change out the campers with the exception of those dampers remaining in stairwells. The previously approved deviation associated with the remaining dampers still applies since they cannot be mounted completely inside the barrier due to interference with tornado pressure relief damper The fire dampers protrude approximately two inches and are l

covered with a one hour rated fire resistive materia Combustible

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icading on both sides of the stairwell dampers is lo The inspector l confirmed there is reasonable assurance that these dampers would prevent i the propagatien of fire from cne side of the barrier to the other since the dampers are essentially in the barrier anc would function normall .2 Fire Protection of the Safe Shutdown Capability l During the 84-44 inspection, the redundant pressurizer transfctmers l located in the Safeguards Building were found not to be in compliance

! with the separation criteria of Section III.G.2 of Appenoix R to l to 10 CFR 50. The applicant stated durina this inspection that, based l on Fire Separation Calculation 152, Rev. 3, and Westinghouse's Thermal Hydraulic Analysis (WCAP #11331), the pressurizer transformers are no

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longer required to achieve safe plant shutdown. The inspector reviewed the analysis ano found it acceptable. Therefore, open item 445/3444-0-05 is considered close By letter of October 2. 1987 the applicant identified an additional deviation to Section III.G.2.d of Appendix R for the Residual Heat Removal inlet isolation valves because the redundant valves are within the same fire area and are not protected with automatic suppressio One set of redundant valves are within 20 feet of each other. Valves 1-8701A and 1-87018 are located in the corridor outside of the steam g2nerator compartment, fire zone 1018. Valves 1-8702A and 1-87028 are located within the steam generator compartment, fire zone 101C. The valves in the corridor are separated by approximately 40 fee t. Irtervening combustibles consist of three cable trays which do not run directly between the valves. The valves inside the compartment are separated by approximately six feet; however, a partial height concrete wall extends from just below the valve bonnet up several elevaticns. Thermistor strip heat detection is provided in both zones containing the valves. Combustible loading inside the containment is 34,200 BTU / square feet, comprised mainly of reactor coolant pump lubrication oil. All four pumps are provided with oil ,

collection system The inspector was concerned that a tire in containment could spread between redundant RHR inlet isolation valves and effect the ability of the plant to safely shutdown. However, the combustible loading inside the containment is low. Due to the large volurte, any fires that were to occur, would develop slowly and dissipate its heat due to the large air volume. In addition, detection is provided in both zones containing the redundant valves. The detection which alarms in the control room would elert the operators to a fire in the area of the valves who in turn could have the plant fire brigade respond. Also, since access to the containment is restricted during plant operaticn, it is unlikely that transient combustibles or ignition scurces would be introduced into the area. Based on the above, the inspector determineo it would be unlikely that a fire cculd occur in the containtrent that would disable the redundant valves in both sets of RHR inlet isolation valves. Acceptance of the deviation frcm Section Ill.G.2.d of Appendix R to 10 CFR 50 will be addressed by the staff in their review of the applicant's October 2,1987 lette During the inspection, two adjacent manholes were found which provided eccess to service water purrp power and control ccbles. At the time of the inspection, both manhole covers were removea for maintenance reason The inspector was concerned that a flamable liquia spill and subsequent fire et the same time both covers were retcoved could jeopardize redundant trains of safe shutdown cables. The concern was heightened when it was observed that the manholes were approximately 40 feet from the unloading area for erwrgency diesel fuel oil and could be cirectly adjacent to the path that tanker trucks would travel to the unloading station. It was also observed that a minimal grarie existed that would direct the flow of flammable liquios away from the manhole The manhole covers were of substantial steel construction and when in

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place, provided an environmentally tight cover. The applicant had performed an evaluation to demonstrate that the manhole covers would provide a barrier equivalent to three hours. Hcwever, the applicant did not address the flamable liquids issue. During the inspection, the applicant committaa to administratively control the manhole covers to ensure that only one cover is removed at any time during plant cperatio In addition, a procecure change was presented to the inspection team which called from the operations department to ensure that the manhole covers were in place during diesel fuel unloading operations, lhis resulution is found to be satisfactory to ensure the integrity of both trains of service water pump cable In SSER 12 the staff approved a deviation from Section III.G.2 of Appendix R to 10 CFR 50 for lack of one hour separation between redundant service water pumps. By letter dated October 2, 1967 the applicant requested that this deviation request be expanded to include the service water isolation valves, service water recirculation valves, branch circuits, exhaust fans and branch circuit MCCs. The previous deviation was granted based on negligible combustible loading, and the presence of early warning smoke detection and area wide auton.atic suppression. Based on inspection of the area in question, the .

inspector determined that previous ccnclusions for granting the deviation appear to remain valid. Acceptance of the deviation from Section III. of Appendix R to 10 CFR 50 will be addressed by the staff in their review of the applicant's October 2, 1987 lette .3 Lightino and Communication SSER 12 stated that "emergency lighting will be installed in all areas of the plant that may have to be manned for safe shutdown operations and at access and egress routes to and from all areas." During the 84-44 inspection, a number of lights, were found misaligned and some areas requiring safe shutdown operations were found not to have emergency lights (445/8444-0-04). During the inspection, the applicant presented procedures that were designed to ensure the proper alignment of emergency lights. While a number of lights were observed to be niisaligned, the applicant stated that due to the present ccnstruction status of the plant, it was difficult to maintain the lights in alignment. However, the applicant stated that a complete alignment of lights would be performed prior to operation and then routinely thereafter. The applicant also presented a procedure for identifying locations requiring emergency light The areas icentified in the 84-44 inspection as lacking lights had been provided with lights and therefore open item 4A5/8444-6 44 is considered close New areas requiring lights haa been identified by the applicant resulting from changes in the safe shutdown analyses. As noted in Section 6.1.2 of this report, areas were identified by inspectors where additional emergency lights may be required. Pending completion of TV Electric's evalu6 tion identifying locations reauiring additional lights, l including resolution of the emergency lighting issues discussed in Section 6.1.2 of this report, this item is considered open (455/8722-0-05).

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"Gaitronics" page system 6s the method for notifying fire bricade and other emergency respcnse personnel. The inspection teen was concerned that a control room fire would disable the page thereby leaving no emergency communications system (0 pen Item 445/8444-0-01, item 2). During this inspection the applicant provided details of a recently installed raoio system that would provide communications independent of the control room. Therefore, the concerns raised during the 84-44 inspection have been resolved and Open Item 8444-0-01, item 2, is considered close During a review of the raoio system, it was noted that the radio system may be disabled by a fire in certain plant areas. Additienally, a fire in the same area may require nianual operator actions in the ficid; therefore, leaving the plant page as the only method for operator-control roon connunications. The inspector was concerned that since some of these manual operatiens involved regulating flows, the proximity of plant pages did not lend this system for adequate communications for this type of operation. In order to adcress the inspector's ccncerns, the applicant simulated these manual operations utilizing the page as the method of communications from the control recm to the operator in the field. Even with the assumption that the pages nearest the valves were inoperable, the applicant den'onstrated that the page would provide an adequate means of conynunication fcr these manual operations in the event the radio system was disable .4 Fire Detection and Suppression 4. Fire Detection Section E.1 of Appendix A to APCSB 9.5-1 provides the minimum require-ments for fire detection systems. Detection systems should comply with flFPA 72D, "Standard for the Installation, Maintenance and Use of Proprietary Protective Signaling Systems." tiFPA 72D requires that fire alarm control panels be listed or approved for the purpose for which they are intended. During the 84-44 inspection, it was observed that the fire alarm panels used in the plant were not listed or approved in accordance with NFPA 720 (0 pen Item 445/8444-0-06). To address this issue, an alarm panel, originally designated for training, was provided by the applicant to Factory Mutual for testing. Factory Mutual performed the same series of tests cn this panel that are used to approve coninercial system During this inspection the applicant presented a report from Factory Mutual to the inspectiun team which documented approval of the plant fire alarm panels. The report was reviewed and fcund acceptabl lherefore, Open Iten 445/8444-0-06 is considered close NFPA 72D indicates that detector placerrent should be in accordance with NFPA 72E which provides guidance on the location and spacing of detectors. During the inspection the inspector was concerned that early warning smoke detectors may not be located in accordance with flFPA 72 lhe applicant presented an evaluation in which each plant area was reviewed for compliance with t1FPA 72E. As a result of this review, a number of plant Ueas had been identified where additieral detectors were required. Although many of these areas had not yet had the new

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detectors installed, the applicant prest.nted documentation which was established to track the new installations. Some areas were identified by the applicant that were not in strict compliance to NFPA 72E. For these areas, TV Electric presented evaluations allowing for deviations from NFPA due to low combustible loading and the lack of safe shutdcwn requirement The inspector reviewed these evaluations and found no issue . Fire Protection Water Supply System As a result of problems with microbiological induced corrosion (MIC) fr the fire water piping, the applicant is planning to replace the current lake fire water supply with dedicated fire water tank This n.odificatien will include adding redundant 504,000 gallons storage tanks and three 50 percent capacity fire pumps (2000 gpm, 160 psi).

Two of the pumps will.be diesel driven and the third will be electri The new design was reviewed during the inspection and found to comply with the guidance as outlined in Section E.2 of Appendix A to BTP APCSB o.5-1 "Fire Protection Vater Supply Systems."

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Section E.3.(c) of Appendix A to BTP APCSB 9.5-1 states that "Automatic sprinkler systems should as a minimum conform to requirements of appropriate standards such as NFPA 13 Standard for the Installation of Sprinkler Systems." During the 84-44 inspection, a number of sprinkler systems in the plant were found that did not conform to the requirements of NFPA 13 (0 pen Item 445/8444-0-07). Specifically, sprinkler spacina exceeded the maximum requirements for distance from the ceiling. As a result of this open item, the applicant perforu d a review of all of the installed sprinkler systems against the requirements of NFPA 13. This review identified a numt'er of areas where sprinkler installation was in conflict with the code. These areas were then tddressed by a major retrofit program to bring all sprinkler systems in compliance with NFPA 13. During this inspection the sprinkler installations were reviewed for compliance with NFPA 13. All areas reviewed were found to be in compliance with NFPA 1 Therefore, Open Item 445/8444-0-07 is considered close NRC IE Information Netice 83-41 discusses cases in which inadvertent actuations of fire suppression systems had adversely affected the operability of safety related equipment. The inspector was concerned during the inspection whether the applicant had adequately addressed this issue. The applicant presented an evaluation in which safety related equipment had been walked down to ensure that the placerent of fire suppression systems would not effect the operation of the safety systems in the event the fire protection systems were to operat The inspector reviewed the evaluation and determined that it adequately addressed the issue of fire protection systems adversely affecting safety related systems, i

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4. Halon Suppression Systems Section E.4 of Appendix A to BTP APCSB 9.5-1 states that "The use of Halon fire extinauishing agents should as a minimum con. ply with the requirements of NFPA 12A and 128, Halogenated Fire Extinguishing Agent Systems - Halen 1301 ano halen 1211." During this inspection, the inspector was concerned that the Palon system provided in the Cable Spreading Room may not be in compliance with NFPA 12A. It'e applicant indicated that the review of the system against the requirements of NFPA 12A had not been performed. Therefore, the applicant needs to perform a review of the Cable Spreading Room Halon system against the requiren,ents of NFPA 12A. Any deviations identified in this review will be required to be submitted to the stafi for evaluetion. The NRC considers this item open pending applicant completion of the eveluation and NRC review of the results (445/8722-0-06).

5.0 POST FIRE SAFE SHUTC0WN CAPABILITY During the 84-44 inspection, numerous apparent inconsistencies were noted in the applicant's ar,alysis and assumptions concerning the protection of fire safe shutdown equipn.ent for areas outside of the control room and ,

cable spreading room where alternative safe shutdown is not require Since the 84-44 inspection, the applicant has provided a more ccmprehensive methcdology and analysis in two docurrents, the Fire Safe Shutdewn Design Basis Document (DBD), DBD-ME-020, and the Fire Protection Report (FPR).

The Fire Hazards Arelysis Report (FHAR) [Ref. Appendix A, A.1(b)] which is contained within the FPR, describes each fire area and its associated fire protection features. The fire safe shutdown equipment lccated within an area is listed in the Fire Safe Shutdown Analysis Repcrt (FSSAR) [Re Appendix A, A.1(c)] also contained within the FPR. For each fire area which contains safe shutdown components, the reference to the components protected to achieve safe shutdown is typically a ceneral statement:

"One train of the required redundant equiptrent and components within the 4rea is protected by one of the means provided in Section II.4.5."

Section II.4.5 contains only a listing of all of the potend al means of complying with CMEB 9.5.1 C.S.b separation requirements. Therefore, the FHAR does not identify specifically what components are protected for a postulated fire in that area, except in certain circumstances such as for Fire Area AA where the protection of CCW isolation valves 1HV4512, 1HV4513,1HV4514, and 1HV4515 and their associated circuits is describe The listing of protected components for each fire area is provided in three volume docurrent collectively referred to as Calculation No.152, Revision 3 [Ref. Appendix A. A.3]. Calculation No. 152 is predoninently a computer printout for each fire area of the raceways, the safe shutdewn cables, the cables which mu;t be thermolagged in the area, the corresponoing safe shutdown o? vices and associated equipnent locaticn (fire zones of the devices), tea electrical nodes (junction boxes) and the raceaay length. A discussion of protection of associated circuits is provided in Section 7 of this repcr .

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From the perspective of mechanical systems operability, Calculation No. 152 provides two tables in Attachment 16 of Volume 3: Table 1

"Fire Area Compliance Table" and Table 2 "Operator Actions for Fire Areas." Table 1 summarizes the compliance trethod for separation for each fire arca, but in the inspectors opinion does not provice a clear path for determining equipment to be protected. Table ? is a listing of safe shutdown devices and location by fire zone which require certain operator actions including repairs, the location of the action, and the affected fire areas where a fire in those areas tray create a requirement for the manual action. Also the actions are classified acccrding to whether they are required for hot shutdown (hot standby) or cold shutdow The inspection team noted that Table 2 is a key document in the applicant's justification for compliance with separation requirements for those areas nct requiring alternative shutdown. The basis of the applicant's analysis ano protection methodology for these areas is a combination of protecting certain components in a given fire area, in n.any instances of either redundant train, plus reliance on the local operator actions describeo in Table The following procedures [Refs. App. A, B1 to 8] in addition to ,

Procedure No. ABh-803A, "Response to a Fire in the Control Room or Cable Spredding Room," have been prepared by the applicant to address manual actions:

ABN-804A "Response to Fire in the Safeguards Building"

ABN-805A "Response to Fire in the Auxiliary Building or the Fuel Building" ABN-806A "Response to Fire in the Electrical and Cont J Building"

ABN-807A "Response to Fire in the Containment Building" AbH-808A "Respense to Fire in Service Water Intake Structure"

ABN-809A "Response to Fire in the Turbine Building" In view of the tranual actioris required to ensure compliance with separation requiren,ents, the team considers the above procedures to be an integral part of the applicant's fire hazards analysis and fire safe shut-down analysis report The team considered it of considerable importance that the feasibility of the manual actions be properly analyzed with respect to the postulated fires and the protected components within each fire area. As a minirrum, the manu61 actions should be sorted so that those which neeo to be perfortred in the same fire area or zone in response to a postulated fire in that area or zcne are identified and the time after reactor trip when the action must be perfonned cerrpared to the area acces-sibility and corrponent operability after the postulated fir During the inspection, the team noted that the information in Table 2 concerning the manual actions was not adequately sor"d to identify actions which must be taken in the sarre fire area as L,2 postulated fir Furthermore, the teasibility of each action with respect to the postulated fire was not presented. The applicant presented a revised listing of the manual actions with justifications for each acticn just prior to the exit r.ceting. The list indicated that some revisions to

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Table 2 were necessary and that some actions had been delete The new listing of actions would be presented in a previously planned Revision 4 of Calculation No. 15 The issue of the adequacy of manual actions which must be taken in the san;e area as the postulated to Calculation ho.152 andfire remains NRC reviewunresolved pending(TV of the document Electric's revision 445/8722-U-02).

6.0 ALTERNATE SHUTDOWN 6.1 Procedures During the 84-44 inspection, the inspection team noted that procedures for alternate shutdcwn were preliminary and incomplete. During this inspection, the inspectors found that procedures for alternate shutdown had been prepared. The inspection team's evaluation concentrated en Procedure ABN-803A, "Response to a Fire in the Control Rocm or Cable Spreading Recm,"

Revisicn 0 dated June 16, 1987, with Procedure Change Notices ABN-603A-R0-1 dated July 30, 1987 and ABN-803A-R0-2 dated October 9, 1987. Procedure ABN-bO3A is based primarily on the previously referenced Calculation N , Revision 3, and a Westinghouse document, WCAP-11331 * Comanche Peak Steam Electric Station Thermal / Hydraulic Analysis of Fire Safe Shutdown Scenario" dated October 30,1986 (Ref. Appendix A, A-5) which was prepared tc deironstrate the ability to achieve safe shutdown conditions following a Control Room or Cable Spreading Poem fire. WCAP-11331 ccapares baseline assumptions for the Appendix R,Section III.L conditions against the effects of single spurious sincles on safe shutdown capability. The results of the review and walkdown of procedure ABN-803A are as follow . Procedure Review The procedure is organized into a main text with four (4) major attachn:cnts to achieve hot shutdcw The main text is implemented primarily by the Shift Supervisor in the hot shutdown phas Attachment 1 is entitled, "Reactor Operator Actions to Achieve Hot Shutcown," Attachment 2 "Relief Reacter Operator Actions to Achieve Hot Shutdewn," Attachment 3 "Auxiliary Operator No. 1 Actions to Achieve Hot Shutdown" and Attachment 4 "Auxiliary Operator No. 2 Actions to Achieve Hot Shutdown." Thus, there are five (5) operating staff members requireo to implement the hot shutdown phas Attachment 13

"Operator Action Timeliness," provides a summary of the key operator actions and the required completion tirres for attachments 1 thrcugh The WCAP previously referenced is intended to ensure that given any spurious signal, the completion times are such that safe shutdown can be acccmplishe The following items were noteo during the procedural review. Most of these concerns were resolved through the issuance of Procedural Change Notice (PCN) ABN-803A-R0-3 dated October 21, 1987:

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1. There was no provision for termination of spurious pressurizer (PZR) heater operation. PCN ABN-803A-R0-3 contained a change to the procedure that resolved this concer . Upon a spurious safety injection signal, the WCAP indicates that the rupture disk on the PZR relief tank (PRT) would burst after 52 minutes even though all operator actions would be completed normally as required by the procedur This concern is made n: ore serious considering that multiple operator actions may be or are required inside containment during the hot shutdown phase, i.e., manually opening 1-HV-8112, the seal water return isolation valve, and to manually close accumulator injection isolaticn valves 1-8808A, 1-88088, 1-8808C, and 1-88080. These actions, steps 2.4(d) and 2.4(t), would take place after 2-hour maintenance of hot stanoby conditions. This ccncern is further discussed in Section 6.1.3 below ano is identified there as an unresolved ite . An alternative step to manually cpening 1-HV-8112 as mentioned in (2) above (by observing that seal water return flow is available from outside the containment) was not provided. This ccncern was resolved by PCN ABN-803A-R0-3 which directs the operator to check that the seal water return filter delta pressure is greater than 0 psi by observing the difference between 1-PI-175 and 1-PI-176. The applicant agreed to consider the use of a portable delta pressure gauge which could be installed if required by oscillation of the gauge needle . The procedure did not specifically address restoration of offsite power at any time during the procedure impien.entation. The applicant indicated that this action was handled by Procedure No. ABN-601A,

"Response to a 138/345 KV System Malfunction."

5. The prccedure did r.ot detail the steps required to manually operate the steam generator atrrespheric PORVs. By means of PCN ABN-603A-R0-3, caution statements were added concerning the safety actions for the operators to follow such as wearing eye and hearing protection and donning a steam sui . Step 2.3.e calls for the reactor operator to perform several operator actions prior to evacuating the control room, one of which is to place both RHR punips in the PULL-TO-LOCK position. All of the actions are verified by the reactor operator in attachment 1 except for the step involving the RHR pump This concern was resolved by FCN ABN-803A-R0- . There was no reference in the main test of the procedure to Attachments 7 and 8 which list the controls and instrumentation available at the remote shutdown pane By means of PCN ABN-803A-R0-3, such a reference was included in step 2. _

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. There was no provision in Attachment 1 for the reactor operator to notify the relief reactor operator, who is starting diesel generator A in attachment 2, in case of failure of service water flow to the diesel. PCN ABN-803A-R0-3 calls for an additicnal note in attachment I to cover this situatien. Tne applicant also provided an entry from the operators log book (App. A, A 5) showing thst the same diesel had been run unloaded for over 60 minutes without service water flo The:a were other items which were substantially eoitorial in rature to reonce the probability of operator error which were also resolved by the PCN ABN-803A-R0-3, 6. Procedure Walkdown A procedural walkdown of ABN-803A was conducted with one NRC representative each following an assigned applicant operating staff member. There are five operators requirea to implement the procedure: the Shift Supervisor,

' Reactor Operator, Relief Reactor Operator, Auxiliary Operator No.1, and Auxiliary Operdtor No. 2. The walkdchn was conoucted wit:1 the additional condition that the fire brigade would be called out simul- .

taneously to simulate a control room fire. The walkown ended once hot standby conditions had been achieve The team was generally impressed with the organization of the procedure and the operators' ability to carry it cut. However, one minor concern was identified by the inspectors. The procedure did not direct the shift supervisor to assist the reactor operator in tracking the progress of the other operators in accomplishing their tasks within the time linits shown in the Operator Action Timeliness in attachnent 13 of ABN-603A. By means of the previously referenced PCl, on appropriate note was added to the procedure, so that thi: item .s considered resolve The portions of the precedure applying to the time after hot standby conditions have been acnieved, which involved either manual actions inside containment or repairs to achieve cold shutdown, were separately walked dow For the actions inside containment, the scenario of coincident loss of offsite power with evacuation of the control room results in the inability to monitor the conditions insioe the containment. Therefore, the operators must wear full respiratory gear including Scott air packs, 4 A:h can limit the optrator's mobility and access in certain

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2ru T +v ob: > '. hat Step 2.a.d of APN-803A, which required the ct , ,

s ..en 1-hV-81:2, the seal water return isolation ye 1s . + ~ -

r, nted reascelably well with the airpacks mounte h.,ie . . " x~w, to be no 8-hour battery pack emergency lighting i r. P -~. ,dr step inside containment, step 2.4.t. to manually close D1 .... v alator isolation valves 1-8608A,1-ESCCB,1-8808C, Jd 1-88080, t r.ae censuming since it may require as much as 20

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minutes per valv It was noted that access to valve 1-880GD was difficult, but not impossible, with the full respiratory gear on. Also there did not appear to be any 8-hour e-~rgency lighting in area rear accun.ulator No. 4 The need for TV Electric to complete their as!,esscent of locations where en.ergency lighting is needed is addressed in f,ection 4.3 of this repor Regarding the section in the procedure invc1ving repairs, attachment 6 for the emergency air supply hookup to RHR valves 1-FCV-618 and 1-HCV-606 referenced actions to close instrument air valves 101-650 and 101-651 which were difficult to focate and poorly labeled. There also did not appear to be 8-hour emergency lights in the area. The need for TUEC to complete their assessment of locations where emergency lighting u needed is adoressed in Section 4.3 of this report. The issue of the poorly labeled valves is considered an open item pending further revie~v by the staff (445/8722-0-07).

Attachnent 5 of ABN-803A does not involve repairs but rather manual closure of valves IPS-100, 1PS-100, 1PS-113, IPS-126, and 1PS-139 for steam generators 1 throta;h 4 sample line isolation. These valvas were extremely difficult to locate amongst all of the other valves in the *

safeguards 810 primary sample room. It was also difficult to locate CVCS valves 1 CS-8453, 105-6455, 1CS-8430, and ICS-E444 in the Auxiliary Buildino 822 Blender Room. All of these locations were acceptably clarified by the PCN previously reference . WCAP-11331 "CPSES Thermal / Hydraulic Analysis of Fire Safe Shutcown Scenar.o" As previously mentioned, WCAP *1331 was prepared to analyze the plant's ability to achieve safe shutdcwn following a cont.ol roor or cable spreading room fire by evaluating certain spuriots operation cases as scositivity studies to a t,aseline scenario. The '.hermal/ hydraulic analysis described in kCAP-11331 was generateo using the TREAT (Transient Real Tice Engineering Analysis Tool) computer code. Use of this code was approved by the MRC staff for the South Texas Plant in NUREG-0781, Supplement No. 3, May 1987, for small-break LOCA analp es, but not for Comanche Pea The spurious operation scenarios analyzed in WCAP-11331 ware:

1 Stuck Open Presm rizer PORV 2 Stuck Open Stedm Generator PORV(s)

3 Spurious Hecd Vent Operation 4) Auxiliary Feeowster System Misalignment 5) Spuricus SI System Operation 6) Main Feedwater and Turbine Do Not Trip at Reactor Trip 7) Bac.up Heaters fail On All of the above cases were corpared to the operator actions described in Procedure ABN-S03A. The only concerns noted were for case (5), the spurious SI system operation. The WCAP re#ers on page 6 to calculaticns that were performed to datermine whether or not the PRT

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rupture aisk would rupture. The calculations are stated to show that rupture woula occur approximately 52 minutes following transient initiation, with the release of approxirrately 11400 lbm of steam priur to initiation of normal seal injection return flow at 90 minutes in operational guidelines. It should be noted that these calculations are not actually provided in the WCA The rupture at 52 minutes would occur well before the operator actions could be taken inside containment to n.anually open the seal water return isolation valve 1HV-8112 and to rr.anually close the accurculator isolation valves 1-8808 A/8/C/D (see discussion in Section 6.1.2 of this report).

The applicant attempted to adoress-the cencern raisto by the tearr regarding the feasibility of the ruanual actions inside containment by preparing, during the inspection, a calculation (ref. Appendix A, A.6)

intended to show that tirne for rupture of the FRT rupture was overly censervative ano that the rupture disk would not burst at all. The team did not bavt time to review this calculatien as it was presented on the esening prior to the exit meeting and because the actual Westinghouse c61culations are not proviaed in the WCAP. This it'm remains unresolved pending the NRC review of the calculation (445/d72<-U-03). , _ Alternative Shntdewn Instrunientation 10 CFR 50, Appendix R, Ill.G.3 and III.L states, that, if the licensee elects tc ntablish alternative safe shutdown capability, provisions need to be providea for direct readings of process variables necesf ary to perforni and control the reactor shutdown function. NRC Information Notice 84-09 states that instrumentation be supplied to provide the fol-lowing information:

. Pressurizer Pressu.e and Level

. Reactor Coolant Hot Leg Temperature -T hat

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F.eactor Ccolaat Cold Leg Temperature - Teold or T,y

. Steam Generator Pressure and Level (wide ranga)

. Source Range Flux Monitor

. Level Indication for All Tanks Used During the Shutdown Process

. Diagnostic !rstrumentation for Shutdown Systems TV flectric has installed a remate shutdown panel which is located in the Electrical Eauipment Area, Fire Zone SE16, Safeguards Building on Ele ,

831'-6". The inspector found that the panel provices the capebility to bring the plant to cold shutdown utilizing either Train A or Train B equipmen .-

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The followinc instrumentation is available on the hot shutduwn panel:

. Steam Generator 1 Wide Range Level - 1LIS01A

. Steam Generato,' 2 Wid: Range Level - 1LI502A

. Steam Generator i Pressure - ILI5148

. Ste m Generatur 2 Pressure - 1LI5245

. Pressurizer Level - lL14598

. Pressurizer Pressure (liR) - 1P!455B

. Source Range Detector - INI31F

. RCS Loop 1 Het Leg TemperMure - 11R413F

. RCS Loop 1 Cold Leg Temperature _ ITR410F

. RCS Loop 2 Hot leg Temperature - IT!423F

. RCS Loop 2 Cold Leg Temperature - 1Tla20F

. RCS Loop 3 Hot Leg Temperature - 1TI433F

. RCS Loop 3 Cold Leg Tamerperature - ITE430F

. RCS Loop 4 Hot Leg Temperature - ITR443F

. RCS Loop 4 Cold Leg Temperature - ITR440F

. Condensate Storage Tank Level - 1LI2478B The refueling water storage tank level indicaticn will be available locally at the tan ,

The above instrumentation is dedi. :ed to the Train A hot shutdcwn panel and which is installed in areas outside of the control room, where it is not subject to damage as the result of a control room fir The instrun.ents are serviced by oedicated power supplies which are located at the shutdewn transfer panel. The cables for these instrurents do not enter the control room and consequently are not subiect to damage due to a fire in the control roo The inspector determined that the instrumentation av provided met the guioance in NRC Information Notice 84-0 .3 Hot Shutdown Panel The hot snutdown panel contains instrumentation and controls for both Train A and Train B components. Train A controls are isolated from the control rocm by switches at the shutdown transfer panel rn Elevatie 810'-6" in the electric ecuipment aren, fire zone 50 The Troin d isolation switchee are lo;ated at *,he he t shutdown panel . A fire at the hot shutdown viel could damage both Train A and Train B cor.trols loc &ted on the pan However, due co the rem 3te location of shut < % n transfer panel, Train A control will be available in the control roorq.

. The major shutdown devices which are operable for alterative safe shutoown at the hot shutdown panel are as follow :

Main Steam Isolation Valves IHV2333A 1HV2334A 1HV2.'..m 1HV2336A i

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Main Sten Isolation Bypass Valves 1HV2333S 1HV23348 1HV2335B 1HV23368 Turbine Driven Auxiliary Feedwater Pump Motor Driven Auxiliary Feedwater Pump 1 Motor Driven Auxiliary Feedwater Pump 2 Steam Generator 1 PORY IPV2325 Steam Generator 2 PORV 1PV2326 Steam Generator 3 PORV 1PV2327 Steam Generator 4 PORV 1PV2328 Service Water Pump 1 Service Water Pump 2 Diesel Genarator i Diesel Generator 2 Centrifugal Charging Pump 1 Centrifugal Charging Pump 2 Pressurizer Level Centrol Valve 1FCF121 Letdown Isolation Yalve ILCV459 Letdown Isolation Valve ILCV460 Letdown Orifice Isolation Valve 1-0149A Letdown Orifice Isolation Valve 1-8149B '

Letdown Orifice Isolation Volve 1-8149C Control Room Manual Reactor Trip Backup Hedter Group A Backup heater Group 8 Backup Heater Group C Pressurizer Block Valve 1-8000A Pressurizer Block Valve 1-80008 Ccaponent Cooling kater Pcmp 1 Component Cooling Water Pump 2 PHR Pump 1 RHR Pump 2 Accumulator Isolation Valve 1-8808A Accumulater Isolation Valve 1-88088 Accumulator Isolation Valve 1-88C8C Accumulator Isolation Valve 1-88080 Charging Pump Isolation Valve 1-8105 Charging Pump Isolation Valve 1-8106 Pressurizer Ptmp PCV455A LPCV455A The applicant has developed modifications which will enable lccal operation of the diesel generators. These are the subject of Design Change Authorization DCA 61447. DCA 61447 was initiated to resolve the consequences of uncocrdinated 125 VDC circuits EG 104509, EG 145211, ard EG 13C661. This DCA, when implen.ented, will recuire the installatinn of branch circuit fuses or the installation cf thermal lag protectie Pending completion of the codification and review by the NRC, this item is considerad open (a45/8722-0-08).

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7.0 PROTECTION FOR ASSOCIATED CIRCUITS Appendix R.Section III.G, states that protection be provided for associated circuits that could prevent cperation or cause malcperation of reduncant trains of systems necessary for safe shutdown. The circuits of concern are ger.erally associated with safe shutdown circuits in one of three ways:

. common bus concern

. spurious signal concern, and

, common enclosure concern The asscciated circuits were evaluated by the team for common bus, spurious signal, and coramon enclosure concerns. Approximately 250 power, control, ano instrumentation circuits were examined by the inspectar for potential problems. This sample size, which represents about 80s sf the safe shutdown circuits, was used in making the review since many cir:dits were involved and a determit.ation of cable routing took co ciderable time. The samples were selected based on the components which he licenses proposed to use for safe shutdow The applicant analysis of protection o 'ssocitted circuits related to safe shutdown was found to be substar.tielly s ..r.pl e ted . The aralysis resulted in the need for a nember of modifications, many of which have not been ecmpleted. One area where a significent amount of work remained to be done was installation of then90 lag. Until the analysis is completed and the staff reviews the results, this item is considared open (445/8722-0-09).

The following sections present tha inspectors r(view of the specific areas of comnon bus concern, spurious rignal concern, common enclosure cr..cern, and rultiple hign impedence fault ,1 Common Bus

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The licensee had reviewea the class IE and associated circuits in the plant to ascertain the effects of ccordination or uncoordination on the plants capability to achieve post fire safe shutdown. It was demcastrated to the inspector that corrective action since the 84-44 inspection had been taken to correct det'iciencies in the electrical coordination of safe shutcown circuits. Some of the actions were as follows:

i . Replace existing fuses with new fuses which ccordinat . Provide thermal lag to protect safe shutdown circuit . Replace existing trip units with Westinghouse AMP tester unit . Reanalysis of circuits which compensated by taking into account ,

feeder or cable lengths located in the fire are ,

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The team examined, on a sampling basis, the protection fcr several circuits including coordir,ation of fuses, circuit breakers, end relay The samples selected for the cocrdination review were as follows:

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. Diesel Generator Source Breake 1EGI for Bus 1EA1

. Component Cooling Pump #1

. Motor Driven Auxiliary Feedwater Pu p #1

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. Centrifugal Charging Pump #1

. Service Water Pemp ill

. Compartment SF MCC XEB1-1 - 480V AC

, MCC IEB1-2 480V AC SWGR

. Circuit 4 Distribution Panel 1E01-2125V DC

, Circuit 1 Distribution Panel 1E01-2125V DC

. Circuit 2-12 Future en Switchbo:ro IE01 125V Cd

. Circuit 1-6 Spare on Switchboard 1EDI 125V DC -

. IEB.1 o 400V Switchgear The applicant's review identified some circuits which Wre not coordinate Some of these circuits were:

. Panel Boards - 1EC3 1EC3-1 1EC4-1 1EC3-2 1EC4-2

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An assessrrent of neea of these circuits for safe shutdown was made by the appl 1 Cant and, with the exception of 1EC3-1, none of the above panels were required for safe shutdown. The applicant proposed to protect the safe .

shutdcwn circuits on IEC3-1 with thermal leg although the thennal lag had not yet been installe The 480V switchgear 181 and IB? were found by the applicant to be uncoordinated and a design change was authorized (DCA42381) to replace the existina trip units with AMPTECTOR Type II A cevice Panel IED-1 (125V DC) was determined to be coordinated by including the added impedance of effected cable located within the limits of the fire are The applicant identified circults which 1.ere not completely analyzed to account for arr.pacity effects due to the increased operating temperature resulting frcm the thermal lag wrap. The applicant indicatsd that Pevision 4 of the CPSES FSSA Calculation i;o. 152 will address this issue and could result in furthar circuit modifications or thermal las change The comon bus concern cannot be satisfactorily resolved until Revision 4 of the FSSA and the final thermal lag report, ECF-K1700, have been complete The issue of ampacity effects due to increased operating temperatures resulting from thennal lag wrap will remain open subject to completion of TV Electric's analysis. This item is censiderec part of Open item (445/8722-0-09).

l 7.2 Spurious Sicnal The spurious signal concern is made up of 2 fteu :

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. False motor, control, snd instrument indications can occur such as those encountered during the Brown's Ferry fire. These could be caused by fire initiated grounds, short er open circuits,

, Spurious operatien of safety related or ocn-safety rela .ed components capability can cccur that (e.g.,RHR/RCS would valves isolation adversely)

. affect shutd' wn 7. Current Transformer Secondaries The applicant had completed the 6.mlysis for the current transformer secondaries concern, ano had datermined that the voltage centrol and governor control circuits were protecteo and would be functional in the local control mode. No adoitional current transformer applications we e identified which could affect post fire safe shutdown. The inspector revi e d portions of the applicarts anain s and found it acceptable.

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The high low pressure inter faces which were identified by the applicants' analysis are as folicws: -

. Reactor Head and Pressurizer Vent Valves 1-HV3607, 1-HV3608, leR 3607,1HV3610 RHR/RCS Boundary Isolation Valves 1-8701A, 1-8702A, 1-8701B, 1-87028

. Pressuriter fewer-operated Relief Valves 1PCV455A, IPCV456

. hermal letdchn isolation Valve ILCV459 ano excess letdown isolation valves 1-8153 and 1-8154 The app?icant presented the following rrethods to preclude any unwanted spurious actions:

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Reactor Head and Pressurizer Vent Valves. One valve in either train of the valves in each path is disabled by disconnecting DC powe RHR/RCS Scundary Isolation Valve The applicant intends to remove power from either of the two Path A and B valves by opening the appropriate circuit breake Pressurizer Power-operated Pelief Valves. The applicant intends to close the respective pressurizer block valve (1-C000A, 1-80008) or disconnect the DC power to the air centrolling solenoid valve for the P09V. It should be noted the control cables for the block valvcs (1-8000A, 1-80008) are vulnerable to damage as the result of a contrcl room fire and that they 3re not equipped with handwheel Block Valves 1-8000 A & 8 will be clcsed at their respective MCC' The control circuits for the preuurizer PORV's are electrically isolated from the control roo i _ __

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- Excess Letdown Valve - 1-8153, 1-8154 Controls for 1-8153 Cdn be faile(i Closed at the hot shutdown pane Normal letdown isolation valve ILCV459. VA 1-81498 can be closed from the hot shutdown pane . General Fire Instigated Spurious Signals The applicant presented analyses for a number of devices which may be spuriously operated subject to a fire in the control' room, some of which are as follows:

. Main Steam Isolation Valves (M51Vs) 1HV23333A&B, 1HV2334ASB, ihV2335A&B, and 1hV2336A& These devices can be closed frem the hot shutdown panel and tre electrically isolated from the control roo . Steam Generator PORVs IPV2325 IPV2326, 1PV2327, IPV232 The controls for these valves are not electrically isolated from the control room; their manual operation of the valve will bt the neans of operation. The appropriateness of these tranual actions is encornpassed in the previously identified unresolved item -

discussed in Section 5.1 of this repor . The n6rmal charging isolation valves 1-8105 and 1-8106. These val es are electrically isolated from the control room and can be operated from the hot shutdown pane . Pressurizer level control valve 1FCV12 This valve can be put in its fail safe position by either venting through instrument air or disconnecting the DC power to the valv The control circuit for the accumulator isolation valves 1-8802A, B, C and D are not electrically isolattd from the control room. The applicant intends to utilize jumpers to niaintain centrol or manually operate the valves during hot shutdown. The inspection team considers this action a hot shutdown repair which is not consistent with staff guidelines. Further informatian is needed to resolve this concern (445/8722-U-04). Common Enclosure The common enclosure concern occurs when nonsafety related cables are run from one redundart train to another and a fire can thereby endanger bcth redundant train Seven levels of cable separation are in use at Comanche Peak: U Train A, orange cable; 2) Train B. green cable; 3) nonsafety, black; 4) protecticn channel, red; 5) protection channel, whitte; 6) protection channel, blue; and 7) protection channel, yellow. There is no internixture of any of the seven levels, and whenever a cable exits a raceway or enclosure, fire stops or seals are installed. The coccon enclosure concern was founo to be satisfactorily addressed by the applican ,

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. .Multipic High Irnpedance Faults TUEC's analyses for the effect of moltiple high, impedance faults cn post fire safe shutdown accounted for the surranation of the high irnpedance fault currents for the affected cables in the fire areas in addition to the ntaximum operating current for cables outside the fire area. The power supplies are considered oy TU Electr'c to have failed cue to fire irduced multiple high irrgeoence faults where the total feeder current exceeds the long-term trip carrent of the affecttd power supply feeder breaker. The inspector determin d that separation and protection wnre adequate to prevent loss of redundant safe shutdown power supplies. Based on the inspector's review TV Electric's aralysis was censidered acceptabl .0 OpEN ITEMS Open items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, and which involve sorre action on the part of the NRC or applicart or both. Open items identified curing the irispection are discussed in Sections 3 (one item). 4 (five items), 6 (three items), ard 7 (one item) of this repor .0 UNRISOLVED ITEMS -

Unresolved items are matters about which more information is required in order to determine whether they are acceptable items, violations, or deviations. Unresolved items identified in this ins inSections4(cneitem),5(oneitem),6(oneitem)pectionarediscusseo

, and 7 (cne item) of this repor .0 EXIT INTERVIEl (30703)

An exit inte. ,tew w6s conducted on C;tober 23, 1987, with the applicant's representatives identified in secticn 1 of this report. During this exit Interview, the scope eno findings of the inspection were sumarized.

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APPENDIX A Documents Reviewed Reports and Correspondence TU Electric - Generating Division, "Comanche Peak Steam Electric Station - Unit No.1, Fire Protecticn Report" Nevision 0, September 22, 1987, with the following sections:

a)Section I - Introduction b'Section II - Flre Hazards Analysis Report (FHAR)

c)Section III - Fire Safe Shutdown Analysis Report (FSSAR)

d)Section IV - Appendices "Texas Utilities Electric - Comanche Peak Engineerino

- CPSES Units I and 2 - Design Basis Document - .

Fire Safe Shutdown Analysis", DB0-ME-020. Revisicn 0, June 19, 198 . "FSSA Calculation No-152 Revision 3, CPSES. Unit ho. 1 Fire Area Separation Analysis" Volumes 1, 2 and 3 with transmittal letter 4 May 1987 to Mr. John E. Krechting, TV Electric, from Mr. Elden E. York, Engineering Planning and Management, In . A.F. Gasner; etc. al. 'CPSES - Thermal Hydraulic Analysis of Fire Safe Shutcown xenario", WCAP-11331 Westinghouse Electric Corp, October 30, 198 . CPSES Operator's Log Entry-Evening Shift May 2, 1984 T. Beandi, Shift Superviso . S. Popek, "Spurious Safety Inspection Analysis" Engineering Planning and Management Calculaticn No. EPM - P257 - 167, October 22, 198 . "CPSES Fire Protection Program - Advance Submittal of FSAR Update" -

Sections ~.4 (Systems Required for Safe Shutdown), 9.5.1 (Fire Protection Program) and miscellaneous, transmittal letter October 9, 1987 to U.S. WRC Document Control Desk from W. G. Counsil, TV Electri . Thermalav Arp Schedule ECE - M1 - 1700, Revision cp . Letter from D.P. Barry to Steven D. Einbinder, "Thermalag Cable Ampacity Study."

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1 Design Change Authorization ho. 61441, "Coordination of Breakers on Panels 1 ED1-2 & IED2-2", October 22, 198 A1 - -

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1 Letter from P.B. Stevens to S. Einbinder "CPSES High Irrpendance Fault Study."

1 Design Change Authorization No. 42381 Regarding "Change of 400 V Swgr (181 & 182) Solid State Trip Devices to kestinghouse Amptector Type IIA" dated June 30, 1987. Letter from 0.W. Lowe to S.L. Star . Letter from 0. W. Lowe to S. L. Stanun, "0C. Emergency Lighting for The Control Room," dated October 13, 198 . Coordination Study - 118, 120, 120/240 & 208/120 the Non-Class IE AC Panel Board Buses - Calculation The-EE. CA-0008-574 Dase-2/26/8 Non Class IE Buse . Coordinatioa Study - Bus IEA1 - Calculation EE - CA - 0008 - M1 .1 Coordination Study - 6.9 Kv System - Bus 1EA1 - Calculation The -

EE-CA-0008 - 15M.7 Date 10/7/8 . Coordination Study - 6.9 Kv Power Distributicn System - Ground Fault -

Calculation The-EE-CA - 0008 157 Rev. O Fig. 9 Date 10/7/86,

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1 EFM Calc. - Analysis and Resolution of FSSA Associated Circuits of Concern by Conmon Power supplies, EPfi - P257-165-000, dated 10/22/8 . Coordination Study - 118; 120 & 208/120 VAC Class IE Panel Board Buse The -EE-CA-0008-183 Rev. O Fig. 43 Date 10/3/8 . Coordination Study - 118, 120 & 208/120 VAC Class IE Panelboard Buses -

The-EE-CA-0008 - 183. Rev. O Fig. Procedures Abnormal Conditions Procedures ABN-803A "Response to a Fire in the Control Room or Cable Spreading Rcom" Rev-0, June 16, 1987 with PCN ABN-803A-RO-1, July 30, 1987, PCN ABN-803A-RO-2, October 9, 1987, PCN ABN-803A-RO-3, October 21, 1987, ABh-604A "Response to Fire in the Safeguards Building," Rev-0, July 15, 198 . ABN-805A "Response to Fire in the Auxiliary Buildins or the Fuel Buildir:g or the Fuel Building", Rev-0, July 15,1987 with PCN ABN-805A-RO-1, October 13, 198 . ABN-807A "Respense to Fire in the Electrical and Control Building,"

Rev-0, July 15, 196 . ABN -807A "Response to Fire in the Containnent Building," Rev-0, July 15, 198 A2 -

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. . , . ABN-808A "Response to Fire in Service Water Intake Structure," Rev-0, July 15, 198 . ABN-809A "Response to Fire in the Turbine Buildin9," Pee-0, July 15, 198 . ABN-301A "Instrument Air System Malfuretion" Rev. 2. September 23, 1987 with PCN ABN-301A-R2-1, October 13, 198 . AEN-601A "Response to a 138/345 KY System Malfunction," Rev. 2, September 11, 198 Drawings Mechanical (Note FDE Flow Diagram)

Number Title Sheet. Re M1-0202 FD-Main Reheat & Steam Dump System -9 CP-9 2323-M1-0206 FD-Auxiliary Feedwater-System CP-7 2323-M1-0206 FD- Type "In Dump Trains 01 CP-2 2323-H1-0202 FD-Main Reheat & Steam Dump System -9 CP-9

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2323-M1-0203 F" Type In 1 CP-6 2323-M1-0216 FD-Compressed Air System A CP-1 ECE-M1-0216 Instrument Air Supply 01 CP-3 Electrical & Control 2323-M1-0233 FD-Station Service Water System - CP-11 Sheet 1 of 3 2323-M1-0233 "Type in A CP-1

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Sheet 2 of 3 2323-M1-0234 "Type" In - CP-9 Sheet 3 of 3 2323-M1-0229 FO-Component Cooling Water System - CP-6 Sheet 1 of 7 " "

ECE-M1-0229

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"Type" In" A CP-1 Sheet 3 of 8 B CP-1 ECE-H1-0229 FD-Component Coolin9 Water System - CP-10 Sheet 4 of 8

" " " " " " " "

LCE-M1-0230 A CP-1 Sheet 5 of 8

" " "

ECE-M1-0230

" B CP-1 Sheet 6 of 8

" "

2323-M1-0231

" ' - CP-8 Sheet 7 of 8

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Number Title Sheet. Re " " " "

ECE-M1-0231 A CP-1 2323-M1-0250 FD-Reactor Coolant System - CP-7

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2323-M1-0251 FD- -

CP-7 FD-Chemical & Volume Control System

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2323-M1-0253 -

CP-7

" " "

ECE-M1-0253 FD- A CP-1

" " " "

2323-M1-0254 - CP-8

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2323-M1-0255 FD- - CP-9 Volume Control Tank loop ECE-M1-0255 FD-Chem. & Vol. "Control "System Charging and Positive Displacement Pump Trains 2323-M1-0260 FD-Residual Heat Removal System - CP-9 2323-M1-0261 FD-Safety injection System - CP-6 2323-M1-0262 FO-Safety Injection System - CP-7 Sheet 2 of 3

. 2323-M1-0264 FD-Liquid Waste Processing -

CP-5 Reacter Coolant Drain Tank Subsystem 2323-El-0001 Plant One Line Diaoram Units CP-2 Units 1 & 2 2323-El-0C01 Plant one Line Diagram Units CP-3

! Units 1 & 2 2323-El-0C03 6.9 KV Auxiliaries-One Line Diagram CP-4 ene Line Diagram Normal Buses 2323-El-0C04 6.9 KV Auxiliaries-One Line Diaoram CP-6 Safeguard Buses

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ELE-El-CC04 6.9 KV Auxiliaries-One Line Diaaram A CP-1 Safeguard Buses

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2323-El-0005 480V Auxiliaries-One Line Diagram CP-2 Safeguard Buses 2323-El-0007 Safeguard & Auxiliary Buildings Safeguard 480V NCC's One Line Diagram CP-7

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- j o .. , o M b,ef, Title Shee h 2323-El-0009 Containment & Desser Cenerator CP-4 Safequard 480V NCC's One Line Diagram 2323-El-0010 Cora.cn Auxiliary & Control Blogs CP-5 Safeguard 480 V hCC's One Line Diagram 2323-El-0014 Service Water intake Structure CP-3 and Casser Generator Safeguard 400V NCC's - Oae Line Diagran 2323-El-0018 118V AC Instrument Bus Distribution CP-4 Cne Line Diagram 2323-El-0018 118V AC & 125V D.C. One Line Diagram 02 CP-4 2323-El-0019 24/48V & 125/2ECV DC One Line Diagram CP 4 2323-El-0020 125V D.C. One Line Diagram CP-5 2323-El-C024 118V AC & 120V AC Corron & Unit il 03 CP-3'

Instr. Distribution Panels One Line Diagram ThE-El-0067 Diesel Generator IC G1 AC Scheoratic, CP-1 Unit 1 THE-El-006M Diesel Generator IEG1 Engine Start- 05 CP-3 Stop DC Centrol Schenictic 2323-El-0031 6.9 KV Switchgear Bus IEA1 Diesel Ge CP-3 Bkr. 1EG1 Schematic Diagram 2323-El-0031 6.9 KV. Switchgear Bus. IEA1 25 CP-2 Component, Cooling, Water PP #11 Schematic Diagran 2323-El-0031 6.9 KV Switchgear Bus IEA1 Auxiliary 31 CP-3 Feedwater Pump all Schematic Diagram 2323-El-0031 6.9 KV Switchgear Eus IEA1 Station 41 CP-5 Service Water Pump W11 Scher.atic Diagram 2323-El-0031 6.9 KV. Switchgear Bus IEA1 53 CP-1 Centrifugal Charging P.P ill Sch watic Diagram 2323-El-0033 480 V Switchgear Bus IEB1 01 CP-1 Supply Breaker IEB1-1 Schematic Diagram

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fiumber Title Shee Re El-0033 460 V Switchgear Bus lEB3 03 CP-1 Supply Breaker AEB3-1 .

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Schematic Diagram 2323-El-0037 Air Operated Value - 1PV-24538 07 CP-1 2323-El-0039 Main Steam Loop 1MS!V/BYP Value 41 CP HSP. Indication & Manual BY '

ISOL Value IHV-23?3 B Scherratic Otagram

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