IR 05000277/1986008

Insp Repts 50-277/86-08 & 50-278/86-08 on 860317-21.No Violation Noted.Major Areas Inspected:Fire Protection Features to Ensure Ability to Achieve & Maintain Safe Shutdown in Event of Fire

ML20198E570
Person / Time
Site:	Peach Bottom
Issue date:	05/09/1986
From:	Anderson C, Krosopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20198E563	List: ML20198E559 ML20198E570
References
50-277-86-08, 50-277-86-8, 50-278-86-08, 50-278-86-8, NUDOCS 8605280063
Download: ML20198E570 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-08 and 50-278/86-08 Docket N /50-278 License No. DPR-44 and DPR-56 Priority -

Category C Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Peach Bottom Atomic Power Station Units 2 and 3 Inspection At: Delta, Pennsylvania Inspection Conducted: March 17-21, 1986 Inspector: ie Nf Nac4- Y _ /9/6 A. Krasopoul'os, Re%ctor Engineer, DRS

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Also participating in the inspection and contributing to the report were:

J. Stang, Fire Protection Specialist, NRR K. Parkinson, Electrical System Specialist, BNL A. Coppola, Mechanical Systems Specialist, BNL

, Approved by: ~ St2A,A >>44/ //9 f/o 3 3d*DRS ElSection, "' " '"T* ' "' * "'V It** ' '

Inspection Summary: Inspection on March 17-21, 1986 (Combined Report N /86-08 and 50-278/86-08)

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 L, concerning fire protection features to ensure the ability to achieve and maintain safe shutdown in the event of a fir Results: No violations were identifie Five items remained unresolved at the end of the inspectio , PDR ADOCK.0500 e -

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DETAILS 1.0 Persons Contacted 1.1 Philadelphia Electric Company (PECO)

• H. Abendroth, Co-owner Site Representative

• W. Birely, St. Licensing Engineer

• W. Boyer, Electrical Supervising Engineer

• G. Brecht, Jr., Chief Electrical Engineer

• G. Cambell, Senior Designer

• R. Dellangelo, Designer

• R. Fleischmann, Plant Manager

• C. Gerdes, Mechanical Engineer

• M. Lohr, Electrical Engineer R. Lonabaugh, Fire Marshal

• J. McCawley, Electrical Engineer

• W. Mindick, Sr. Electrical Engineer

• G. Morley, Supervising Engineer J. Pizzolo, QA Engineer

• G. Reid, Sr. Mechanical Engineer

• M. Ryan, Compliance Engineer

• 0. Spaner, Engineer

• S. Spitko, Administrative Engineer

• C. Swenson, Compliance Engineer

• G. Termine, Engineer

• W. Ullrich, Superintendent Nuclear Generation Division T. Wilson, Site QA Supervisor 1.2 Licensee Contractors

• A. Melikian, Project Engineer (EPM)

• D. Brecken, Project Manager-(EPM)

1.3 Nuclear Regulatory Commission (NRC)

• T. Johnson, SRI

• G. Gears, Project Manager J. Williams, RI

• Denotes those present at exit intervie .0 Purpose This team inspection was conducted to ascertain licensee compliance with 10 CFR 50, Appendix R, Sections III. G, J, and O. Because full compliance with the above regulations is not required until the end of the next i Unit 2 refueling outage, the team reviewed the licensee's approach to compliance, along with the plans and schedules for completing all other modifications required in this are I i

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3.0 Background 10 CFR 50.48 and 10 CFR 50, Appendix R, became effective on February 17, 198 For Peach Bottom Units 2 and 3, the applicable portions of this regulation are Sections III.G, " Fire Protection of Safe Shutdown Capa-bility," III.J, " Emergency Lighting," and III.L, " Alternative and <

Dedicated Shutdown Capability."

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 are provided to ensure ~ ~ ~~~ ~

that one train of equipment necessary to achieve and maintain safe shut-down 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.I.a). For cold shutdown conditions, repair is allowed using in place procedures and materials available onsite with the provision that cold shutdown be achievable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the initiating event (III.G.1.b).Section III.G.2 lists specific options to provide adequate protection for redun-dant trains of equipment located outside of the primary containmen 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 in-tervening combustibles and with fire detection and automatic fire suppression installed in the fire area (III.G.2.b).

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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 capability be provided which is independent of the area of concern. Any alternate or dedicated system requires NRC review and approval prior to implementation.

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 basi Such exemption requests are submitted to the NRC for review and approval and must be justified by the licensee on a technical basi l Presently the licensee must comply with all of the requirements iterated

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above. One exemption from full compliance is the modification work associated with the alternative shutdown capability for Unit 2. Since some of the alternative shutdown systems are common to both units, alter- !

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native shutdown capability is not required for either unit until the end of the next Unit 2 refueling outage. Also, because the licensee is developing a more detailed fire hazards analysis, compliance with section III.G and J. could not be fully ascertained. The analysis will be completed by September 30, 198 .0 Post-Fire Safe Shutdown Capability 4.1 Systems Required for Safe Shutdown In the event of a fire concurrent with the loss of offsite power, the~ ~~ ~

following systems are used to provide the safe shutdown capability of the plant:

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High Pressure Coolant Injection (HPCI) System

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Reactor Core Isolation (RCIC) System

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Automatic Depressurization (ADS) and non-ADS Safety Relief Valves (SRVs)

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Residual Heat Removal (RHR) System-shutdown cooling mode, suppression pool cooling mode, and low pressure coolant injection (LPCI) mode

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Core Spray (CS) System

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High Pressure Service Water (HPSW) System

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Emergency Service Water (ESW) System

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Onsite AC Power Generation and Distribution System

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Onsite DC Power Generation and Distribution System

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Essantial Ventilation Systems Safe shutdown is initiated from the control room by a manual scram of the control rods or automatically by the reactor protection syste The support systems required for safe shutdown include the emergency service water system (ESW) for diesel generator cooling, high pressure service water system (HPSW) for RHR heat exchanger cooling, onsite AC emergency power system, onsite DC Emergency power system and essential ventilation system The precise methodology used for safe shutdown has not been finalized by the licensee. Currently, the following shutdown methods are under review:

Method-A l

For Method A, RCIC is used to maintain reactor vessel coolant inven-tor RHR and HPSW are used for suppression pool cooling which is required for decay heat remova Heat is transferred from the vessel to the suppression pool via the ADS system and/or the RCIC steam turbine discharg _ _ _ _ - _ .

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Method B For Method B, HPCI is used to maintain reactor vessel coolant inven-tory, RHR and HPSW are required as in method A for suppression pool cooling. Heat is transferred from the vessel to the suppression via the ADS system and/or the HPCI steam turbine discharg Method C For Method C, the reactor is depressurized using the ADS system to a point where either the Core Spray or the LPCI mode of the RHR' - ~ ~ -

systems can be used to maintain core inventor Method D Method D, is the alternative shutdown method for a catastrophic fire in either the Control Room, Cable Spreading Room or the Emergency Shutdown Panel Are This method is described in the following sectio .2 Alternate Safe Shutdown Areas The licensee committed to and is in the process of_ establishing alternate safe shutdown capability independent of the main control room, cable spreading room and the emergency shutdown panel are The alternative shutdcwn stations are provided with circuit isolation capability using manual control switches, relays, breakers or fuse-disconnect switches, to ensure that no electrical connection exists between the alternative shutdown circuits and those affected by a fire in any one of the above-mentioned area In the event of an unmitigated fire in these areas, the operators will proceed to the alternative shutdown stations to initiate shut-down operation Communications will be established between the operators who are at the alternative shutdown stations and the coordinating operator. The alternative control stations for Peach Bottom are or will be in the following locations:

4. HPCI Alternative Control Station - This panel will be located in each unit in the MG set room at elevation 135' - 0". The-HPCI alternative control station will be equipped with pump diagnostic instrumentation and transfer switches and alternative power supplies for the HPCI turbine. This panel will be equipped -

with the alternative process monitoring instrumentation which indicates reactor vessel pressure and level, suppression pool temperature, and condensate storage tank leve . Diesel Generators Alternative Control Station - These panels will be located in Unit 2 4KV emergency switchgear rooms B/D and are common to both Units 2.and 3. The panels will be equipped with transfer switches to isolate all main control room control circuits, and also diesel generator diagnostic instrumentatio _ _

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4. KV Emergency Switchgear Alternative Controls - These controls are located in the 4KV emergency switchgear rooms in each unit. Transfer switches will provide alternative local control and status indication for the motor control centers and for the ESW, RHR and HPSW pump . ADS Transfer / Isolation Station - Alternative control capabilities for 3 ADS valves and the associated nitrogen supply isolation valves will be located on the HPCI Alternative Control Stations in the M-G Set Rooms. The transfer / isolation switches for these controls are located in the 4KV switchgear rooms. The remote locations for the transfer / isolation switches are necessary to preserve safe shutdown capability for the M-G Set Room . RHR/HPSW Suppression Pool Alternative Control Stations -

Alternative control capabilities and transfer / isolation switches for one loop of RHR/HPSW Motor Operated Valves (MOV's), needed to support Suppression Pool Cooling, will be located at the HPCI Alternative Control Stations in the M-G Set Room .3 Remaining Plant Areas The licensee indicated that all other areas of the plant not required to have an alternate safe shutdown system, comply with the requirements of Section III.G.2 of Appendix R, unless an exemption request has been approved by the staf .0 Inspection Methodology The inspection team examined the licensee's provisions 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 compli-ance with Section II The following functional requirements were reviewed for achieving and maintaining hot and cold shutdown:

• Reactivity control

Pressure control

• Reactor coolant makeup

• Decay heat removal

• Support systems

Process monitoring

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The inspection team examined the licensee's capability to achieve and maintain hot shutdown and the capability to bring the plant to cold shut-down conditions in the event of a fire in various areas of the plant. The examination included a review of drawings, safe shutdown procedures and other documents. Drawings were reviewed to verify electrical independence from the fire areas of concern. Procedures were reviewed for general content and feasibilit 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 to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression system The inspection team examined the licensee's fire protection features provided 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, including walls, floors and ceilings, and fire protection.of

openings such as fire doors, fire dampers, and penetration seal The inspection team also examined the licensee's compliance with Section III.J, Emergency Lighting.Section III.0, Oil Collection System for Reactor Coolant Pump is not applicable to the licensee since the contain-ment is inerted during normal operations.

) 6.0 Inspection of Protection Provided for Safe Shutdown Systems 6.1 Protection in Various Fire Areas The team reviewed the protection prov'ided to SSSs in selected fire areas for compliance with Appendix R, Sections III.G.1, 2 and The following fire areas were inspected:

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The Control Room

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The Cable Spreading Room

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'The Switch Gear Room

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The Battery Room

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The Intake Structure (Fire Areas 47 and 48)

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The Turbine Building

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The Reactor Building, Fire Areas 5, 6, 12 and 13

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The Radwaste Building, Fire Areas 2 and 25

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Yard Area Manholes 25, 89 and 90 No unacceptable conditions were identified except as follows:

Inspection effort incomplete because of unfinished analysi The inspection team could not ascertain the licensee's compliance with Section III.G of Appendix R because the analysis identifying the shutdown methodology had not been finalized at the time of the inspection. This is an unresolved item pending completion of the analysi (50-277/86-08-01 and 50-278/86-08-01)

6.2 Safe Shutdown Procedures The team requested to review safe shutdown and alternative shutdown procedures to ascertain that shutdown can be achieved in a safe and orderly manne The licensee stated that these procedures have not been developed as yet but will be in effect by the end of the next Unit 2 refueling outage. This is in agreement with previous commitments made to the NR This is an unresolved item pending licensee completion of the procedure (50-277/86-08-02 and 50-278/86-08-02)

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6.3 Protection for Associated Circuits Appendix R,Section III.G requires that protection be provided for associated circuits that could prevent operation or cause malopera-tion of redundant trains of systems necessary for safe shutdow The circuits of concern are generally associated with safe shutdown circuits in one of three ways:

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Common bus concern

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Spurious signals concern

Common enclosure concern

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The associated circuits were evaluated by the team for common bus, spurious signal, and common enclosure concerns. . Power, control, and instrumentation circuits were examined on a sampling basis for potential problem . Common Bus Concern-The common bus concern may be found in circuits, either safety related or non-safety related, where there is a common power source with shutdown equipment and the power source is not electrically protected from the circuit of concer .

. 9 The team examined, on a sampling basis, protective relay coordination for 4160V and 480V buses and protection for specific instrumentation, control and power circuits. The coordination of fuses and circuit breakers was checked by examination of the licensee's fuse and breaker coordination curves. The licensee performs relay calibration during refueling outages on approximately 18 month interval No unacceptable conditions were identifie .3.2 Spurious Signals Concern ~ ~~ -

The spurious signal concern is made up of 2 items:

False motor control and instrument indications can occur such as those encountered during the 1975 Browns Ferry fire. These could be caused by fire initiated grounds, short or open circuit *

Spurious operation of safety related or non-safety related components can occur that would adversely affect shutdown capability (e.g., RHR/RCS isolation valves).

The team requested to review documents, on a sampling basis, in the following areas to ascertain that no spurious signal concern exists:

Current transformer secondaries

• High/ low pressure interfaces

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General fire instigated spurious signals The licensee explained that an associated circuit analysis for spurious signals is currently being developed but is not yet finishe This is an unresolved item pending the licensee's comple-tion of an associated circuits analysis for spurious signal (50-277/86-08-03 and 50-278/86-08-03).

6.3.3 Common Enclosure Concern The common enclosure concern may be found when redundant circuits are routed together in a raceway or enclosure and they are not electrically protected or when a ~ fire can destroy both circuits due to inadequate fire barriers. The team could not inspect this area since the licensee's analysis was incomplete. The licensee stated that this analysis is currently in proces ..

, 10 This is an unresolved item pending licensee completion of the analysis and reinspection in this are (50-277/86-08-04 and 50-278/86-08-04)

7.0 Emergency Lighting 10 CFR 50, Appendix R, Section III.J, requires that emergency lighting units with at least an 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes theret ~. - _ . - -.

Due to lack of safe shutdown procedures, the team was not able to inspect this area. This item remains unresolved. (50-277/86-08-05 and 50-278/86-08-05)

8.0 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. As the containment for either unit is inerted during normal operation, the above requirement does not apply to Units 2 or .0 _ Unresolved Items Unresolved items are matters for which more information is required in order to ascertain whether they are acceptable, violations, or deviation Unresolved items are discussed in Sections 6.1, 6.2, 6.3 and .0 Exit Interview The inspection team met with the licensee representatives, denoted in Section 1.0, at the conclusion of the inspection on March 21, 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 this inspection was written material provided to the licensee by the team.