ML20204F445
| 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: |
| 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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Chemical and Volume Control
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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
- 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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.
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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.
,
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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17
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
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:
'
. .
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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. _ .
.
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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)
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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.
.
o .
.
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
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.
.
,
.
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.
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'.
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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