ML20215L878

Insp Repts 50-277/87-11 & 50-278/87-11 on 870409.Violation Noted:Failure to Maintain at Least One Safe Shutdown Train Free from Fire Damage

ML20215L878
Person / Time
Site:	Peach Bottom
Issue date:	05/01/1987
From:	Anderson C, Krasopoulos A, Pullani S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20215L867	List: ML20215L865 ML20215L878
References
50-277-87-11, 50-278-87-11, NUDOCS 8705120410
Download: ML20215L878 (5)

See also: IR 05000277/1987011

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U.S. NUCLEAR REGULATORY COMMISSION

-REGION I

Report Nos.- 50-277/87-11 and 50-278/87-11

Docket Nos. 50-277 and 50-278

License Nos. DPR-45 and OPR-56 Category C

Licensee: Philadelphia Electric Company

2301 Market Street

Philadelphia, Pennsylvania 19101

Facility Name: Peach Bottom Units 2 and 3

Inspection At: Philadelphia, Pennsylvania

Inspection Conducted: April 9, 1987

Inspectors: fh8 7

W. K&asop6~ , teactor_Engiaeer da'te '

buNem 4l2WP7

~S. Pull ni Fire Protection Engineer dat'e / '

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Approved by: O ~

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C. Agfderson, Chief, Plant Systems Section date

Inspection Summary: .

Inspection on April 9,1987 (Combined Inspection Report Nos. 50-277/87-11

and 50-278/87-11)

Areas Inspected: Special announced inspection to review and verify the 10 CFR

50 Appendix R nonconformances identified by the licensee.

Results: One violation was identified (Failure to maintain at least one safe

shutdown train free from fire damage). Five examples of the violation were

verified.

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DETAILS

1.0 Persons Contacted (Entrance and Exit Interview)

1.1 Philadelphia Electric Company (PECO) .

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W. Boyer, Supervising Engineer

D. Spammer, Electrical Engineer

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2.0 Background

The Nuclear Regulatory Commission (NRC) during March 17-21, 1986 performed

an inspection to assess the licensee's safe shutdcwn capability required

by 10 CFR 50, Appendix R. As a result of this inspection, the NRC, on

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April 11, 1986, issued a Confirmatory Action Letter requesting that the

licensee complete the Appendix R safe shutdown confirmatory program and

inform the NRC Region 1 of any violations of the Appendix R requirements.

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The licensee, by letters dated May 22, 1986, September 17, 1986 and

October 31, 1986, informed the NRC that in at least 51 instances, the

requirements of 10 CFR 50 Appendix R were not satisfied.

3.0 Purpose and Inspection Methodology

This inspection was conducted to review the details of the violations of

the Appendix R requirements identified by the licensee, and to assess the

extent of these violations. The inspectors reviewed five of the fifty-one

nonconformances identified by the licensee.

To perform this review, the inspectors examined the licensee's safe shut-

down evaluation report and reviewed their consultant's reports prepared

for determining the consequences of fire in any plant location on the

ability to safely shutdown-the plant.

The following section describes the applicable requirements and the

associated nonconformances as identified by the licensee and verified

by the inspectors.

4.0 Review of Nonconformances

10 CFR Part 50, Appendix R, Section III.G.1 requires that fire protection

features shall be provided for structures, systems, and components

iraportant to safe shutdown. These features shall be capable of limiting

fire damage so that one train of systems necessary to achieve and maintain

hot shutdown conditions from either the control room or emergency control

station (s) is free of fire damage.

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Section III.G.2 specifies four alternatives that may be implemented

outside of primary containment to assure that one redundant train of

equipment, cabling and associated circuits necessary to achieve and main--

tain hot shutdown remains free of fire damage. The alternatives are:

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Separation of redundant trains of equipment, cabling and associated

circuits by a three-hour rated fire barrier.

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Separation of redundant trains of equipment, cabling and associated

circuits by a horizontal distance of 20 feet with no intervening

combustibles and fire detection and automatic fire suppression

systems installed in the area.

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Enclosure of redundant trains of equipment, cabling and associated

circuits by a one-hour rated fire barrier with fire detection and

automatic fire suopression systems installed in the area.

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Installation of alternative or dedicated shutdown capability

independent of the equipment, cabling and associated circuits under

consideration, and installation of fire detection and fixed-fire

suppression systems in the area under consideration.

The' licensee informed the NRC that in fifty-one instances, the require-

ments of 10 CFR 50 Appendix R were not implemented.

The inspectors reviewed five of these nonconformances to verify the vio-

lations and assess the severity. The nonconformances reviewed are as

follows:

1. The licensee has identified four safe shutdown methods, A, B, C

and D.

All of these methods require emergency AC power which is provided by

the Emergency Diesel Generators. To prevent tripping of the Diesel

Generators from overheating, cooling water is provided only by the

Emergency Service Water (ESW) Pumps A and B. Either pump is capable

of providing the required flow of cooling water to the Emergency.

Diesels. The licensee determined that the control cables ZB2A1603L

for ESW Pump A and ZC2A1706L for ESW Pump B are routed in fire

area 43. Because these cables are not protected or separated in

accordance with the Appendix R,Section III.G.2 requirements, a fire

induced ground of these cables in this area will render both ESW

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pumps inoperable thus causing the Diesel Generators to trip from

overheat.

Thus, a fire in fire area 43 will prevent safe shutdown of both

Units 2 and 3 by ultimately affecting the emergency power sources,

i.e., the Emergency Diesel Generators.

2. Decay heat removal is a fun:: tion required to achieve the shutdown

goals established by CFR 50 Appendix R,Section III.G.I.

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Decay heat removal is accomplished by the use of the Residual Heat

Removal System (RHR) in the suppression pool cooling mode. The

Unit 2 RHR system utilizes four pumps, 2AP35, 2BP35, 2CP35 and 2DP35.

Anyone of these pumps is capable of providing the flow required to

perform the decay heat removal function. Control cables from all

, four pumps are routed through fire area 3S.

Because these control cables are not protected or separated in-this

fire area as required by 10 CFR 50 Appendix R, Section III.G.2, a hot

short or short to ground by a fire in this area will render all four

RHR pumps inoperable, thus preventing safe shutdown of Unit 2.

3. Monitoring of the reactor water level and of reactor pressure is

required to achieve ard maintain hot shutdown condition in accordance

with 10 CFR 50 Appendix R, Section III.G.I.

In Unit 3 to monitor reactor water level and pressure, the licensee

must utilize any one of the following instruments:

LI3-2-3-85A Reactor Water Level Indicator

LI3-2-3-85B Reactor Water Level Indicator

LI3-2-3-86 Reactor Water Level Indicator

LR3-2-3-110A Reactor Water Level Recorder

LR3-2-3-110B Reactor Water Level Recorder

PI3-6-90A Reactor Pressure Indicator

PI3-6-90B Reactor Pressure Indicator

PR3-2-3-404A Reactor Pressure Reccrder

PR3-2-3-4048 Reactor Pressure Recorder

PR3-6-96 Reactor Pressure Recorder

However, the use of all of these instruments will be lost in a fire

within fire area 13N. This is because required associated compo-

nents of these instruments are located in fire area 13N and have

not been protected in accordance with the requirements of 10 CFR 50

Appendix R,Section III.G.2. Thus, a fire in fire area 13N will

prevent safe shutdown of Unit 3 because reactor water level and

reactor pressure could not be monitored.

4. The licensee's safe shutdown analysis identified four shutdown

methods, A, B, C and D. In these methods, the required reactor

coolant make-up function could be accomplished by the use of the

Reactor Core Isolation Cooling System (RCIC) in Method A or the High

Pressure Coolant Injection System (HPCI) in Method B or by the RHR

system in the Low Pressure Coolant Injection (LPCI) mode or the Core

Spray mode in conjunction with manual operation of the relief valves

for depressurization in Method C. Method D also utilizes the HPCI

system.

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For Unit 2 in fire area 6S, the HPCI system will be lost because the

control cables to the HPCI turbine are routed through this area. The

RCIC system will also be lost because various system components such

as the power distribution panel, the RCIC flow controller, flow

indicator, the RCIC throttle valve, and the lube oil cooler isolation

valve will be affected by a fire in this area.

Also, both LPCI trains A and B and both trains of core spray system A

and B will be lost. Therefore, a fire in fire area 6S will prevent

safe shutdown because no one train of systems necessary to achieve

and maintain hot shutdown will remain free from fire damage as

required by 10 CFR 50 Appendix R, Section III.G.1 because the pro-

tection to redundant safe shutdown trains specified in 10 CFR 50

Appendix R,Section III.G.2 was not provided.

5. All four safe shutdown methods identified by the licensee require

the manual use of the safety relief valves for depressurization.

The manual operation of these valves relies on the use of either

instrument air supply or nitrogen supply (Valves RV3-02-071A,B,C,G

and K require nitrogen, Valves RV3-02-0710,E,F,H,J and L require

instrument air). In fire area 13S in Unit 3, the instrument air

supply to the relief valves and the nitrogen supply are routed

through this area. Because the air and nitrogen supply piping to

the valves is copper tubing with sweated joint connections, a fire

in this area will degrade this tubing, thus rendering the safety

relief valves manually inoperable. Therefore, a fire in fire area

13S will prevent safe shutdown of Unit 3 because redundant safe

shutdown system components (instrument air and nitrogen supply

tubing) were not protected or separated as required by 10 CFR 50

Appendix R,Section III.G.2.

The nonconformances described above as identified by the licensee

and verified by the inspector are violations of 10 CFR 50 Appendix R,

Section III.G. (50-277/87-11-01 and 50-278/87-11-01).

5.0 Exit Interview

The inspector met with licensee management representatives (see Section

1.0 for attendees) at the conclusion of the inspection on April 9, 1987.

The inspectors summarized the scope and findings of the inspection at that

time. The inspectors 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 inspectors.