IR 05000334/1988034
| ML20195D453 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley, Trojan  |
| Issue date: | 10/20/1988 |
| From: | Chan T, Qualls P, Ramsey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20195D430 | List: |
| References | |
| 50-334-88-34, NUDOCS 8811070013 | |
| Download: ML20195D453 (30) | |
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ja j[ U. S. NUCLEAR REGULATORY COPHISSION U.s 9:p
' REGION V-
1 . Report No. 50-344/88-34 Docket'rio. 50-344 License No. NPF-1 Licensee: Portland General Electric Company 121 S. W. Salmon Street
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Portland, OR 92704 facility Name: .Trcjan Nuclear Plant Inspection at: Rainier, Oregon Inspection Conducted: August 22-25, 1988
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Inspectors: btk % roa - jo .1o . as C. Ramsey, Reactor Inspector Date Signed MM Port . /3 2o -SS
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P. Qualls, Resident Inspector, Rancho Seco Date Signed 3M Fo rt T. Chan, Project Manager,.NRR m.20-es Date Signed l
Other Accompanying Personnel: R. Hodor, Brookhaven National Laboratory K. Su11tvan, Electrical Consultant
- Brookhaven National Laboratory ;
Approved by: 8I::M- WA S. Richards, Chief
_m 10 -se Date Signed
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Engineering Sec. tion i
Summary: l Inspection on August 22-26, 1938 (Report No. 50-344/88-34) ;
Areas Inspected: Announced sp9cial sai'ety inspection concucted to follow-up ,
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on fire protection program compliance and previously identified open item Inspection Modules 30703, 64100, 92701 and 92702 were use !
l 8811070013 esto2o PDR s
O ADOCK 05000344 PDC-
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-2-Results:
General Conclusions and Specific Findings The licensee has made a significant effort to correct the deficiencies identified by the 1983 NRC Appendix R inspectio . The licensee's safe shutdown method for a cable spreading room or control room fire requires that all site AC power be deenergized for up to 40 minutes imtediately following the fir The appropriateness of this method was questioned by the inspectio . Deficiencies were identified with the licensee's safe shutdown procedures, the implementation of those procedures, and the training of operators regarding the use of those procedure . A violation was identified concerning emergency lighting provided for the implementation of safe shutdown procedure . The licensee's Generic Letter 86-10 evaluations were considered to be wea Significant Safety Matters: The licensee's safe shutdown method and deficiencies identified in the implementation of the method were considered significant concern A September 9, 1988 letter to the licensee highlighted these concerns and requested the licensee to take interim action Summary of Violations: One Summary of Deviations: None Open Items Summary: Seventeen items closed, eight items left open, and fcurteen new items opeia !
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DETAILS
, Persons Contacted f
- C. A. Olmstead, Plant General Manager
- T. D. Walt, Manager, Nuclear Safety and Regulation
- A. N. Roller, Manager, Nuclear Plant Engineering
- J. W. Lentsch, Personnel Protection Manager
- D. W. Swanson, Manager, Nuclear Safety Branch
- C. P. Yundt, General Manager, Technical Functions
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- D. W. Swan, Manager, Techr,1 cal Services
- Russell.. Branch Manager, Operations
- P. Schmitt, Manager, Operations and Maintenance
- Brown, Quality Assurance Branch Manager
- Funk, Supervising Engineer
- M. Gandert, Supervising Engineer
- D.. Levin, Acting Manager, Plant Modifications
- R. Reinhardt, Fire Protection Supervisor
- A. Sanchez, Fire Protection l Engineer
- R. N. Hansen, Electrical Engineer
- D. J. Modeen, Senior Nuclear Engineer
- P. Sheppard, Quality Assurance Engineer
- C. Lusky, Electrical Engineer
- J. Siebel, Senior Mechanical Engineer-
- U. Farrady, Electrical Engineer
- B. Lewis, Nuclear Engineer
- D. L. Nordstrom, Compliance Engineer M. R. Snook, Quality Support Services Branch Manager
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M. A. Hoy, Operations Engineer E. L. Davis, Manager, Electrical Branch Oregon Department of Energy
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- H. Moomey, Resident Engineer
- Denotes those attending the exit meeting held on August 26, 1988, Licensee Actions On Previous Inspection Findings (92701, 92702)
' (Closed) Violation 344/83-18 01 "Fire Protection for Charging Pump Cables." This violation identified the licensee's failure to provide fire protection features for redundant charging pumps and associated cabling required for hot shutdown in accordance with Sections III.G.1 and III.G.2 of Appendix '
The inspection team reviewed the cable routing and protection provided for redundant charging pumps P217A, P205A and P205 During the last refueling outage, the licensee installed a 3-hour fire rated fire barrier wrap material to encase all Train A charging pump cables located in Train B fire area Al and provided a separate fire area (A3) for the Train A charging pum Based on the team's review, this item is considered close I
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B. (Closed) Violation 344/83-18-02 "Fire Protection F Pressurizer Heater Cables." This violation identified the licensee's failure to provide fire protection features for redundant pressurizer heater cables in accordance with Section III.G.2 of Appendix The licensee revised the safe shutdown analysis to indicate that credit is no longer being taken for the pressurizer heaters to control reactor pressur The team verified that the licensee's designated method for RCS pressure control is through isolation of the normal letdown lines and operation of the charging portion of the chemical and volume control system (CVCS'j. Based on the team's review, this item is considered close C. (Closed) Violation 344/83-18-03 "Fire Protection F Boric Acid Transfer Pumps." This violation identified the licensee's failure to provide fire protection features for redundant boric acid transfer pumps and associated cabling in accordance with Section III.G.I.b of Appendix The inspection team reviewed the licensee's revised safe shutdown analysis which demonstrates that adequate borated water for reactivity control and cooldown will be supplied from the Refueling Water Storage Tank (RWST). Therefore, the Boric Acid Transfer Pumps are no longer required for safe shutdow Based on the team's review, this item is considered close D. (Closed) Violation 344/83-18-04 "Fire Protection For Residual Heat Removal (RHR) System Cables." This violation identified the licensee's failure to provide fire protection features for redundant RHR pumps and associated cabling in accordance with Section III.G.1.b of Appendix The inspection team reviewed the cable routing and the level of protection provided for RHR pumps P202A and P2028. The licensee installed a 3-hour rated fire barrier wrap material to encase Train A RHR pump cables located within Train B fire area Al and prcvided a 3-hour fire barrier between the Train A and Train B RHR pump [
Based on the team's review, this item is considered close !
E. (Closed) Violation 344/83-18-05 "Alternate Shutdown Capability."
This violation identified the licensee's failure to provide an L alternate means of achieving cold shutdown conditions in the event l of a Control Room or Cable Spreading Room fire in accordance with !'
Section III.L.5 of Appendix The licensee revised the saft shutdown analysis to indicate that credit is no longer being taken for the "se of any boratnd wt.ter f from the Boron Injection Tank or the Boric Acid Transfer Tan !
Repairs to the RHR system are no longer required as a result of the licensee's protection of these cables with a 3-hour fire rated
barrie Source range neutron flux monitoring is provided on the
! Bailey system computor conscle adjacent to the Remote Shutdown Station (C-160 panel). Therefore, provisions for installing a spare l drawer to e.nure t!.e availability of this indication is also no
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longer required. Based on the team's review, this item is considered close F. (Closed) Violation.344/83-18-06 "Source Range and Process Instrumentation at the Internal Containment Electrical Penetration Area." This violation identified the licensee's failure to provide required process diagnostic instrumentation at the remote shutdown panel that is free of fire damage in the event of a Control Room (CR) or Cable Spreading Room (CSR) fire in accordance with Section III.L.2 of Appendix The inspection team . determined that the licensee has provided Thot, Tcold and source range monitoring capability at the Bailey system ,
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computer console adjacent to the Remote Shutdown Statio The tean verified that this indication is independent of the CR/CS Based on the tean 's review, this item is considered close G. (Closed) Optn Item 344/83-18-07 "Fire Protection For Service Water ;
Booster Pump and Component Cooling Water Pump Cables." This item l identified tha NRC concern that the power cables for service water booster pumps ?148A,B,C and D were vulnerable to fire damage because of combustibles contained in nearby overhead cable trays or from an exposure fir The inspection team verified that the licensee provided protection l for these cables by enclosing one division in a 1-hour fire rated l fire barrier wrap material and providad fire detection and suppression for the are Based on the team's review, this item is considered close H. (Closed) Open Item 344/83-18-08 "Fire Protection For Intake Structure." This item identified the NRC concern that service water pumps P108A,B and C and cabling for electric fire pump PillA could be lost due to an intake structure fir The inspection team verified that the licensee has provided 3-hour !
fire rated protection for electric fire pump PillA power cables ;
l located within the Intake Structure. The service water pumps are discussed in paragraph 3 of this repor Based on the team's .
review, this item is considered close l I. (Closed) Open Item 344/83-18-09 "Safe Shutdown Procedures."
This item identified the NRC concern that the licensee's procedures I (ONI-17, Rev, 6, ONI-45, Rev.2, ONI-59, Rev. O. EI-0 Rev. 3. El-0, >
! Rev. O and 01-1, Rev. 2) implementing the safe shutdown methodology l were inadequate to meet the intent of Section III.L.3 of Appendix i The inspection team reviewed Emergency Fire Procedure No. EFP-1, '
Revision No. 4, dated June 1988, for a fire in the CR/CSR and
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determined that the procedure identifies responsibility for required .
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i actions and prioritizes them. The required actient are delineated
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in a time sequenre based on initially achieving hut shutdown. The
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availability and unavailability of offsite power is addressed in addition to the affects of associated circuit concerns that were
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assumed by the licer.se Based on the team's review, this item is considered close J. (Closed) Open Item 344/83-18-10 "Associated Circuit Concerns."
This item identified the NRO concern that the licensee's common enclosure analysis of associated circuits did not adequately address the interaction of non-safety related circuits with safe shutdown circuit The inspection team reviewed the licensee's associated circuits common enclosure analysis and determined it to be satisfactory. The team identified other associated circuit concerns that are discussed in paragraphs 3.0, E and J of the repor Based on the team's review, this item is considered close K. (Closed) Open Item 344/83-18-11 "Emergency Lighting."
This item identified NRC concerne regarding periodic testing of emergency lighting units and the adequacy of installed emergency light In response to this concern, the licensee took corrective action by implementing Electrical Department Procedure No. EDP S-1, "Emergency Battery Light Maintenance", which requires that periodic 8-hour performance teste be conducted on emergency lighting units, in addition to an annual verification of lighting unit lamp position Furthermore, the licensee performed a walkdown of the emergency lighting units and made modifications where necessary before determining that adequate emergency lighting was provided in support of safe shutdown. Based on the licensee's corrective action and the discussion of additional daficiencies provided in paragraph 3.J of this report (Violation 344/88-34-11), this item is considered closed.
i L. (Closed) Violation 344/83-18-12 "RCP Oil Collection System."
This violation identified the licensee's failure to install an oil collection system for the reactor coolant pumps capable of withholding the entire lube oil inventory from all four reactor coolant pumps in accordance with Section III.0 of Appendix As corractive action for this violation, the licensee installed a dike around each RCP lube oil collection tank with sufficient volume to contain the lube oil content of an additional reactor coolant pump, so that the total lube oil collection capacity is slightly greater than the entire lube oil inventory of all four reactor coolant pump The licensee requested and was granted an exemption for this arrangement by the NRC. Based on the team's review, this item is considered close M. (Closed) Open Item 344/83-18-13 "Containment Building External Electrical Penetrations Containing Control and Instrumentation Cables." This item identified the NRC concern that instrumentation nnd control cabling required for safe shutdown located within the shield wall adjacent to containment could be damaged by fire, in violation of Section III.G.2.b of Appendix _ _ _ _
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As corrective action for this violation, the licensee revised the Safe Shutdown Analysis (PCE 1012, Sections 3.8.2.2 and 5.2.2) and provided a more accurate description of this are In addition, the licensee requested and was granted an exemption for this arrangement by the NRC. The inspection team verified the exemotion description of the are Based on the team's review, this item is considered close N. (0 pen) Violation 344/83-18-14 "Fire Protection For Nuclear Instrumentation Inside Containment." This violation identified the licensee's failure'to provide adequate fire protection features for required safe shutdown diagnostic instrumentation cables located inside containmen The licensee considers this violation to be closed based on corrective actions taken and described in section 3.8.31 and lable No. 3-11 of PGE 1012, volume III. These corre:tive actions will be verified by Region V during a subsequent inspection. This item remains open pending further Region V revie O. (0 pen) Violation 344/87-34-01 "Fire Protection Staff Involvement in Program Implementation." This violation identified the licensee's failure to have a consistent policy in place requiring an appropriate discipline review of design change packages affecting fire protection features in accordance with Technical Specification No. 6. As corrective action for this violation, the licensee made procedurai changes and provided additional guidance to improve the licensee's staff involvement in the review of design changes affecting fire protection systems and features. Since these changes were only recently implemented, insufficient time has elapsed to evaluate the effectiveness of the corrective actio This item will remain open pending further Region V revie P. (Closed) Violation 344/87-34-02 "Qualifications of Personnel Issuing Welding and Cutting Permits." This violation identified the i licensee's failure to follow procedures requiring qualified j personnel to issue welding and cutting permits and to take
! corrective actions in accordance with Criterion XVI of Appendix B to 10 CFR 5 The inspection team reviewed the licensee's revised procedure Nos.
<- FPP-06, "Fire Watch Training Procedure," and FPP-07, "Hot Works Permit Issue Training for Supervisors" and determined them to be acceptabl In addition, the licensee was in the process of implementing a draft procedure No. LP-01, "Instructor Lesson Plan",
which will contain an outline of specific details that will be taught in classroom sessions on this subjec Based on the team's review of the licensee's corrective actions, this item is considered close Q. (0 pen) Unresolved Item 344/87-34-03 "Fire Suppression Water Supply System Operability Flow Test Every 3 Years." This item id9ntified
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the NRC concern that the site fire protection wate supply system was not being properly tested and evaluated by the licensee to ensure available water flow and system performance in accordance with recognized standard In response to this concern, during the inspection, the licensee provided the inspection team with a revised copy of draft procedure No. PET 11-1 "Fire Main Flow Test". The inspection team determined that the draft procedure appeared te contain instructions for testing the appropriate parameters >1 the syste However, the procedure was still in draft form and actual testing of the system using the procedure had not been performed. This item will remain open pending further licensee action and Region V revie R. (Closed) Open Item J44/f 34-04 "Fire Pump Operability Flow Test Every 18 Months." This tem identified the NRC concern that the station fire pumps wers *ot being properly tested and evaluated by the licensee in accordance with recognized standards to determine their operabilit In response ts .his concerc, the licensee revised "Fire Pump Annual Flow Test" pr juedure No. 9CT 10-10 to incorporate appropriate pump test parameters and then coapleted testing of the diesel fire pump using the procedur Based an the test results, the licensee determined that while the diesel fire pump met Technical Specification flow requirements, it did not meet the more stringent performance requirements of the pump manufacturer's design specifications and the governing cod As a result, the licensee determined i5at the pump will be taken out of service for required maintenanc This is further discussed in paragraph 3.I of the repor Based on the team's review of the licensee's corrective actions for testing the appropriate parameters of the station fire pumps, this item is considered close S. (0 pen) Open Item 344/87-34-05 "Fire Detector Sensitivity Tcating."
This item identified the NRC concern that the licensee's maintenance program for periodic measurement of fire detector instrument set point drift (sensitivity) was inadequat The inspection team verified that the licensee was evaluating a
"draf t" program for implementing an established criteria for fire detector sensitivity testin Since no program has been formally approved by the licensee and no trial program was in place, the team had no basis for assessing the adequacy of the licensee's proposed corrective actions. This item will remain open pending further licensee action and Region V revie T. (Closed) Open Item 344/87-34-06 "Seismic Qualification of Interior Standpipe Fire Hose Stations." This item identified the NRC concern that firefighting standpipe hose connections required for fighting fires in safety related areas were not analyzed for their capability to withstand a seismic even _ _ __
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In response to this concern, the licensee documented a conversation with NRC (NRR) staff in which the licensee was told that the requirements for seismic qualification of firefighting hose stations in safety related areas ~did not apply because of backfit/ cost benefit considerations. Based on the team's review, this item is !
considered close >
U. (0 pen) Open Item 344/87-34-08 "General Employee fraining Program."
This item identified the NRC concern that the licensee's General Employee Training (GET) program inappropriately directed general employees to evaluate fire occurrences and perform firefighting '
activities as part of their normal dutie Since the site five brigade has first-line responsibility for fire extinguishment, the NRC was concerned that this action by general employees would delay the fire brigade's response to fires.
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The inspection team verified that the licensee revised procedure N A0-10-2 (entitled "Fire Protection"), which now instructs general employees to immediately notify the control room upon discovery of a fir Then, if trained, the employee can attempt to extinguish the fir The General Employee Training course had not been revised to reflect this new approac However, the licensee was in the process of revising the course at the time of the inspectio This item will remain open pending further licensee action and Region V revie V. (0 pen) Open Item 344/87-34-09 "Implemantation of MCJifications Required by Amendment No. 22 to License No. NPF-1." This item ;
identified the NRC concern that the licensee may not have completed ,
all of the modifications that were required to be implemented by l Amendment No. 22 to the facility operating licens '
In response to this concern, the licensee performed a reassessment of the plant configuration and the required scheduler modification *
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According to the licensee, the results of this reassessment indicate some of these modifications may not have been implemented or have ,
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Appendix R compliance. The licensee indicated that the evaluation ;
of these conditions was in progress and when completed, will ;
indicate whether full compliance was achieved with regard to the 1978 SER and the Amendment No. 22 license condition; or the :
evaluation will justify the plant configuration and propose a t schedule to complete modifications to bring the plant in conformance I with the 1978 SER and other SER supplements. The licensee indicated that this evaluation will be submitted for NRC review by December l 31, 1988. Furthermors, the licensse indicated that s license ,
amendment request would be submitted, as required, in order to achieve compliance. This ites will rer.ain open pending further [
licensee and NRC action, j
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W. (Closed) Unresolved Item 344/87-34-10 "Use of Fire Water Supply as a Backup to the' Service Water System." This item identified the [
NRC concern that in the event of a loss of service water, as j l
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l discussed in Section 9.2.1 of the FSAR, the capability of the station fire pumps and offsite fire department pumpers to provide a backup to the service water system had not been verified by the licensee.
l The licensee's performance of fire pump test Procedure No. TPT-251 successfully demonstrated the capability of the station fire pumps j to perform as a backup to the service water system if both pumps operate in parallel. This is further discussed in paragraph 3.I of the repor To provide makeup to the cooling tower basin when it is used as a backup to the service water system, the licensee and the j offsite fire department successfully demonstrated that two offsite i fire department pumpers draf ting and r elaying water from the '
Columbia River can provide adequate makeup to the cooling tower basin. The results of the licensee's water flow test using this methodology are documented cased on the licensee's performance of test procedure No. OM-5-8-3, Revision 0, in June 1988. Based on these results, this item is considered close (0 pen) Violation 344/88-17-01 "Failure to Install Fire Detectors on the 93 Foot Elevation of the Fuel Building." This violation identified the licensee's failure to install fire detectors on the 93 foot elevation of the Fuel Building as required by Amendment N to the facility operating licens The licensee provided a response to the NRC for this violation by letter dated June 22, 198 Since the violation is related to the modifications that were required by Amendment No. 22 to the facility operating license (0 pen Item No. 344/87-34-09), resolution to this violation will be included in the licensee's evaluation that is scheduled to be submitted to the NRC by December 1, 198 This is further discussed in paragraph 2.V of the repor This item will remain open pending further licensee and NRC actio . Modifications Made To Achieve and Maintain Safe Shutdown (64100)
10 CFR 50.48 required the licensee to implement all fira protection modifications needed to satisfy the provisions of Appendix R to 10 CFR 50. The results of the inspection team's review of the licensee's implementation of modifications to comply with 10 CFR 50.48 are as follows: Systems Required For Safe Shutdown l
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The Trojan Nuclear Plant is a four loop Westinghouse Pressurized Water Reactor rated at 1130 MWe and is operated by the Portland General Electric Company. The plant has been in commercial j operation since 1975. Since the plant is a pre-1979 licensed t nuclear plant, the following 10 CFR 50, Appendix R performance goals must be me * The reactivity control function must be capable of achieving and maintaining cold shutdown reactivity conditions (reactor
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!I h coolant temperature less than or equal to 200 degrees Fahrenheit).
- The reactor coolant makeup capability must be capable of maintaining water level within the level indication in the pressurizer at all times during the shutdown operatio * The reactor heat removal function must be capable of achieving and maintaining decay heat remova * The process monitoring function must be capable of providing direct readings to perform and control the above function * The support functions must be capable of providing process cooling, lubrication, etc. , necessary to permit operation of the equipment used for the safe shutdown function Reactivity Control - The licensee's initial reactivity control consists of an automatic Reactor Protection System (RPS) trip or an operator initiation of a manual RPS tri Based on an analysis (TNP84-07, dated March 9, 1984) provided to the inspection team by the licensee entitled, "Calculation of Shutdown Margin for Appendix R Scenario", the shutdown margin can be maintained during cooldown assuming no RCS letdown, and make up only for shrinkage using 2000 ppm borated water from the Refueling Water Storage Tank (RWST).
Reactor Coolant Makeup - For a postfire safe shutdown, the Reactor Coolant System (RCS) volume is controlled first by isolating all reactor coolant leakage paths and verifying isolation of those path This action will limit most of the variations in pressurizer level due to cooldown inventory shrinkage. Borated inventory makeup can be provided as required via the centrifugal charging pumps taking suction from the RWST. In the event of fire-induced spurious operation of any one of four valves (MO-1128 and C - Volume Control Tank outlet valves, MO-8110 and 8111 - Centrifugal Charging Pump mini flow valves), the Positive Displacement Pump (PDP) is use Reactor Coolant System Pressure Control - Overpressure protection for the RCS prior to a controlled cooldown and depressurization is provided by the pressurizer safety relief valve After alignment of the Residual Heat Removal (RHR) system, at approximately 350 degrees Fahrenheit and 425 psig, overpressure protection is provided by an RHR system pressure relief valv Reactor Decay Heat Removal - Decay heat is removed from the reactor following a reactor scram by natural circulation cooldown using the steam generatot A minimum of one steam generator is required to be available for the natural circulation cooldown. Auxiliary feedwater is required within 30 minutes of a reactor trip to preclude steam generator dryout. Auxiliary feedwater can be supplied to the steam generators by the ESF turbine and diesel driven Auxiliary Feedwater (AFW) pumps or the non-ESF electric motor driven pump. Transition from stable hot shutdown conditions to cooldown is achieved by manual control of generator pressure via the
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steam generator atmospheric dump valves and continued operation of the auxiliary feedwater syste After reduction of the RCS pressure and temperature to below 350 degrees Fahrenheit and 425 psig, the RHR system is used to remove decay heat from the RCS to the environment via the Component Cooling Water (CCW) system and~ Service Water (SW) syste Process Monitoring - To achieve and maintain the post-fire safe shutdown goals, operators require diagnostic instrumentation readings to. ascertain and control various plant operating parameters. The licensee has provided the following process monitoring instrumentation for this purpose:
Pressurizer level and pressure
- RCS hot and cold leg temperatures
- Wide range steam generator level
- Steam generator pressure
Source range neutron flux monitoring
- CST, RWST and emergency diesel generator fuel oil tank levels Support Equipment - The licensee's safe shutdown systems and components require the availability of the following support systems:
Service Water (SW) system
Component Cooling Vater (CCW) system
- Diesel fuel oil transfer system
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- Ventilation system
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- Communications
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Emergency lighting Cold Shutdown - During cold shutdown operations, reactor coolant flows from the RCS to the HHR pumps through the tube side of the RHR heat exchangers and back to the RCS. The heat load is transferred by the RHR heat exchangers to the CCW system (which is circulated on the shell side of the RHR heat exchangers). The inlet line to the
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RHR system is located in the hot leg of RCS loop 0, while the return lines are connected to each cold leg of the RC The cooldown rai.e of the reactor coolant is controlled by regulating the flow through the tube side of the RHR heat en anger A bypass line, which serves both RHA heat exchangers, is L. s to regulate the
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temperature of the return flow to the RCS, as well as to maintain a constant flow through the RHR system. Two h:otor-operated valves in
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series (M0-8701 and MO-8702) with pressure interlocks isolate the
'RHR loop from the RCS. Overpressure protection in the RHR loop is provided through.a relief valve (PSV-8708) in the low pressure letdown lin No violations or deviations were identifie Alternate Shutdown Capability Sections III.G.3 and III.L of Appendix R require the licensee to provide an alternative shutdown capability, for specific fire areas, *
that is independent of such areas and capable of accommodating postfire conditions where offsite power is available and where offsite power is not available for 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> The equipment and systems providing this capability are required to be free of fire damage so that they are able to achieve and maintain subcritical reactivity conditions in the reactor; maintain reactor coolant ,
inventory; maintain hot standby or hot shutdown conditions; and, i maintain cold shutdown condition During such postfire shutdown '
. conditions, the reactor coolant system process variables are required to be maintained within those parameters predicted for a normal loss of AC power and the fiJsion product boundary is required to be unaffected (i.e. there shall be no fuel clad damage, rupture .
i of any primary coolant boundary or rupture of the containment '
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The licensee's safe shutdown method requires alternative shutdown
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capability for the following areas:
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Control Room (fire area C11)
- Cable Spreading Room (fire area C7)
- Service Water Pump Room (fire area II)
Manhole MH3 (fire area M3)
- Manhole MH4 (fire drea M4) ,
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Generally, all of these fire areas contain control and/or power
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circuits for redundant trains of safe shutdown equipment that are
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not separated or protected in accordance with the specific criteria of Appendix The Control Room and Cable Spreading Room contain control and instrumentation circuits for all redundant safe shutdown equipment The service pump room and manholes NH3 and MH4 contain redundarc, power cables for all service water pumps.
- The licensee's alternative shutdown station, for a Control Room or '
Cable Spreading Room fire requiring evacuation of the Control Room, provides the following features:
I * Remote Shutdown Station Control Panel (C-160 Primary Station)
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Indication of primary system pressure, pressurizer level,
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and steam generator pressure and leve r
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Steam generator level contro Decouple switch to isolate AFW pump from CR/CS ,
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Source range ~ neutron flux. -Thot and Tcold are available adjacent to the C-150 panel at the Bailey process display
- consol * Turbine-Oriven Auxiliary Feedwater Pump Room (Support Station)
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Local operation of steam inlet valve to turbine drive * Control Building Switchgear Room (Support Station)
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Decouple switches for all Train 8 safe shutdown equipment requiring electrical powe Isolation of AC (Train B) and DC (Train A and B) power-to components with the potential to spuriously operat ;
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Local operation of Train B 4.16kV and 480V feeder * Turbine Building Switchgear Room (Support Station) ,
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Isolation of electric power to Train A components with the potential to spuriously operat '
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- Train B Emergency Diesel Generator Room (Support Station)
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Decouple switch (es) to isolate CR/C5R control circuits.
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Local diesel generator start /stop, speed and voltage l
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Diesel generator diagnostic instrumentatio ,
- Hiscellaneous Valve Locations (Support Stations)
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Isolation of instrument air to potential safe shutdown spuriously operating valve .
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Verification of valve. positions as necessar !
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- Initially, the manning requirements for alternative shutdown in the 1 event of a control roos or cable spreading room fire is five operators who are augmented at the end of the first hour by ;
operators returning from the fire brigad The feasibility of the l
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licensee's reliance on operators returning from fire brigade duty af ter one hour is further discussed in paragraph 3.B(4) of the I repur ,
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For the other three areas where alternative shutdown capability is required (service water pump room, manhole MH3 and manhole MH4), a fire can result in damage to power cables and the loss of all service water pump Alternative shutdown capability is available for these areas using gravity flow through the service water system from the circulating water cooling tower basin. This arrangement is sufficient to provide cooling to safe shutdown equipment, assuming a loss of offsite power, for 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> when spent fuel pool cooling is maintained; or, for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> if spent fuel cooling is isolate Once the cooling tower basin water capacity is depleted, the diesel driven fire pump can be connected to the service water system header by means of fire hoses through an installed hose connection and provide limited cooling water (up to 3000 Gallons Per Minute) from the Columbia River indefinitel A cooldown to the RHR initiation temperature (350 degrees Fahrenheit) can be accomplished within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. However, the RHR system cannot be initiated prior to 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> after shutdown because of the limited flow to the service water system provided by the alternate systems. Cold shutdown can be achieved in approximately 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> when the alternate methods of service water are employe Additional alternate service water capability can be provided by using the cooling tower makeup pumps, which can be powered from the emergency diesel generators. These pumps recirculate a portion of the circulating water system flow; thus, extending the time that the circulating water system can be used as an alternate to the service water syste Even with this additional capacity, cold shutdown cannot be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> using this alternate metho Based on the inspection team's review, the team determined that the licensee's alternate shutdown capability appears to be inconsistent with the requirements of Appendix R as follcws:
(1) The methodology that has been implemented may not have been fully recognized by the NRC staff during its 1985 revie The licenseo's method requires an intentional loss of all AC power for approximately 40 minutes in order to mitigate the adverse consequences of fire damage to safe shutdown circuits located in the Control Room or Cable Spreading Room. Although the shedding of offsite power to preclude certain spurious activations has been a methodology that has been accepted by the staff, the concurrent unavailability of onsite AC power for 40 minutes may be excessiv Section III.L.3 of Appendix R requires that onsite AC power be available when of fsite power is available, and when offsite power is not available for 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (2) A weakness in the methodology appears to be that if fire damago to certain safe shutdown circuits occurs prior to the licensee's manual operator actions being performed, in accordance with procedure No. EFP-1, the alternate safe shutdown capability may be defeated by the fire damage ( fire damage to Service Water System control cables). In the event of a concurrent loss of offsite power and a loss of .
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service water to the EDG's, damage could occur to both EDG's within 3 to 5 minutes. This appears to be contrary to section .
III.L.4 of Appendix R. Section III.L.4 of Appendix R requires that if such equipment and systems will not be capable of being powered by both onsite and offsite power because of fire damage, an independent onsite power system shall be provide (3) By implementing Alternate Shutdown Procedure No. EFP-1, it ;
appears that plant operators are placed in a position t ;
intentionally disable all AC power, perhaps prematurely, upon l receipt of a Cable Spreading Room fire alarm, in order to avoid sustaining fire damage'to safe rhutdown circuits prior to implementing the alternate shutdown methodolog This appears to involve a voluntary entry into Technical Specification 3.0.3. The licensee stated that the criteria for declaring a fire an emergency. event is' consistent with the site Emergency Pla However, the licensee emphasized that the site Emergency Plan criteria allows.for Shift Supervisor discretion under such ,
circumstance This statement by the licensee appears to support the inspection team's position that the provisions of i 10 CFR 50.54(x) were used as a basis for writing the procedure and placing the plant in a condition outside of those conditions analyzed in Chapter 15 of the FSAR, when the procedure is implemente Once the decision is made to enter the procedure (Control Room evacuation), there are no additional decision points or related ;
symptoms provided prior to the deenergization of all AC power supplies. The licensee indicated that this approach was intended to address worst case fire scenarios. However, a less severe fire situation could result in Shift Supervisor decisions to enter the procedure and cause an unwarranted disabling of all AC powar supplie The decision point at -
which the Shif t Supervisor is directed to evacuate the Control Room and enter the procedure is defined as "a fire lasting more
than fifteen minutes and affacting redundant safe shutdown '
trains". If the decision to evacuate the Control Room and enter the procedure is made fifteen minutes after a verified '
fire, the time threshold for carrying out certain steps in the
,
procedure may have elapsed (i.e. diesel generators must be stopped within three minutes and pressurizer PORV's must be -
closed within five minutes). l (4) After one hour has elapsed, the licent,ee relies on operators who are assigned fire brigade duties to return and assist in implementing the methodolog '
This reliance appears to be
,
based the assumption that a fire occurrence will not last for ;
- more than one hour or, additional firefighting assistance will !
arrive before one hour has elapse ,
l The above (items 3B(1), (2),(3) and (4)) appears to be l inconsistent with sections II.A. III.G.A and I!!.2.a of ;
Appendix R and is considered an Unresolved Item (344/88-34-01) ;
pending further NRC revie l
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C. Reactor Coolant Pump Seal Injection The inspection team identified a concern that a loss of coolant flow to the seals can result in RCP seal degradation and subsequent excessive leakage of primary coolant during the approximate 1-hour period that the seals are without seal injection during implementation of the alternate safe shutdown methodology. According to the time lines in the procedure for implementing the methodology, it will take approximately 40 minutes to start the EDG's and another 20 minutes for che charging pumps to restore seal cooling. The licensee's position was that only normal leakage would occur during this period based on a Westinghouse analysis (WCAP 10541). The inspection team's review of the referenced analysis disclosed inconsistencies between assumptions in the analysis and interpretations of the analysis by the license The analysis assumes that a seal leakage rate of 21 gpm/ pump will occur immediately upon loss of seal injection at reactor temperature and pressure and a possible leakage rate of 480 gpm/ pump can eventually resul Based on the team's review, the team determined that the inconsistencies between the Westinghouse analysis (WCAP 10541) and the assumption that a loss of seal injection for a period up to I hour will have no adverse affect on seal integrity by the licensee, represent a significant level of uncertainty about the integrity of the primary reactor coolant system boundary due to the potential for RCP seal damage and subsequent leakage during the period that seal injection is los This appears to be inconsistent with sections III.L.1 and III.L.2 of Appendix R and is considered an Unresolved Item (344/88-34-02)
pending further NRC revie D. Mitigating Damage To Both Emergency Diesel Generators The inspection team identified the concern that damage could occur to both emergency diesel generators due to a loss of cooling water during implementation of the alternate safe shutdown methodolog The team is concerned that in the event of a concurrent loss of offsite power wit. a loss of service water to the diesels, damage could occur to both EDG's within 3 to 5 minutes after a diesel automatic start is initiated upon loss of offsite powe The time lines examined for this occurrence by the team from PGE 1012 and the licensee's internal memorandum dated June 1, 1988 (D.J. Harvey to R.L. Russell), entitled "Validation For EFP-1," indicates an elapsed time of more than 3 minutes for an operator to arrive at the EDG rooms to shut the EDG's down before this damage occur During the walkdown of the procedure by the licensee's staff and the inspection team on August 25, 1988, the team also determined that more than 3 minutes could elapse before an operator completes these action Based on this assessment, the team determined that the marginal time frame permitted for an operator to complete required actions before damage occurs to the EDG's is of questionable adequac _ - _ _ _ _ -
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This appears to be inconsistent with sections III.G.3 and III.L.4 of Appendix R and is considered an Unresolved Item (344/88-34-03)
pending further NRC revie E. Mitigating Spurious Operation of Pressurizer PORV's The inspection team raised the concern that an operator is directed to open the DC supply breakers for the pressurizer's Power Operated Relief Valves (PORV's) to prevent or mitigate spurious operation of the valves in the event of a CR/CSR fire. The licensee's procedure No. EFP-1 cautions operators that this action must be accomplished within five minutes. According to the licensee, the five minute time frame is based on sustaining spurious operation of one pressurizer PORV and the loss of primary system inventory through the open valve. If the PORV is closed within five minutes, the licensee's position is that fuel damage will not occur and the loss of primary system inventory can be recovered when normal charging is restored epproximately 40 minutes late The inspection team expressed concern to the licensee regarding the narrow time line established to accomplish this action. The team's position is that if fire damage occurs to the control circuits to the valves and certain control room instrumentation prior to receipt of a fire alarm, time 0.00 for closing the valve starts when the damage occurred. In this case, by the time operators respond to the receipt of a fire alarm, evacuate the control room, implement the procedures for disabling all AC power and closing the valve, more than five minutes could have elapse The team recognized however, that operators would probably attempt mitigating actions for this condition prior to control room evacuatio During the team and licensee's walkdown of procedure No. EFP-1 on August 25, 1988, the ,
team observed that the operator assigned responsibility for opening the DC supply breakers for the PORV's appeared to accomplish this action in excess of five minutes, when time 0.00 was established as the time that the Shift Supervisor decided to evacuate the Control Roora because of a postulated verified Cable Spreading Room fire of significant magnitud This is further discussed in paragraph .
3.J(3)(a) of this repor This appears to be inconsistent with sections !!!.G.3 and III.L.1 of '
Appendix R and is considered an Unresolved Item (344/88-34-04)
pending further NRC revie ;
F. Availability of Process Instrumentation The inspection team identified the concern that for a period of 40 minutes while power is not available from the EDG's, diagnostic instrumentation for Thot, Tcold and source range neutron flux monitoring is not available on the remote shutdown (C-160) pane When power is available from the EDG's, this instrumentation will be i available at the Bailey process display console adjacent to the
! C-160 pane The team's concern is that the lack of capability to
! read these process variables during this period was not recognized by the NRC staff during its 1985 review of this methodolog r l
l 5
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This appears to be inconsistent with section III.L.2 of Appendix R and is considered an Unresolved Item (344/88-34-05) pending further NRC revie G. Safe Shutdown Procedures In the event of a CR/CSR fire, the licensee has developed and l Implemented Emergency Fire Procedure No. EFP-1. The procedure is l' written in a two column format with the second column providing I
contingency actions in the event actions or responses in the first I column are not obtained. -Five operators are required to implement the procedure and are assigned responsibilities as follows:
- Shift Supervisor - responsible for directing activities of
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l operators and monitoring primary and secondary system conditions. Also, acts as initial emergency coord*nator for radiological emergency respons * Control Operator - responsible for establishing AFW flow to at l 1 east one steam generato l l
- Assistant Control Operator - responsible for de-energizing the l pressurizer and transferring control from the CR/CSR to the
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local switchgear for Train B safe shutdown equipment. Also, opens Train B breakers to prevent spurious operation of equipment and provides local start of safe shutdown pump * Auxiliary Operator A - responsible for manual line-up of Chemical and Volume Control Syste Also, restores seal injection and CCW flow to containment air coolers and throttles charging pump flo * Auxiliary Operator B - responsible for opening circuit breakers of Train A components as well as securing the emergency diesel generator Also, isolates the instrument air header Immediate actions af ter a reactor trip include removing offsite and onsite oower, as well as instrument air, to preclude damage to the emergency diesel generators from a possible loss of service water and to prevent unpredictable spurious operation of safe shutdown equipmen The inspection team and the licensee's staff performed a walkdown of the procedure for implementing alternate CR/CSR safe shutdown on August 25, 1988 at 11:00 A.M. During the walkdown, the inspection team assessed emergency lighting, connunications effectiveness, operator familiarity with the procedure and equipment locations, and the availability of required tools, equipment and other instruction Procedural deficiencies were identified during the walkdown of Alternate Safe Shutdown procedure No. EFP-1 as follows:
(1) The NRC concern for the design basis parameters for safety related values and actuators, failsafe positions and movement times with respect to a rapid or gradual loss of air was
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. identified to the licensee in Region V inspection report N /87-31. NRC Generic Letter No. 88-14, Information Notice No. 87-28 and NUREG 1275, provided the licensee with information on instrument and service air system problems and recommendations for actio Paragrahh2.BofRegionVinspectionreportNo. 50-344/87-31 documents the NRC concern that a gradual loss of instrument air test at Trojan has never been performed and safety related backup accumulator testing has been accomplished on only a few selected accumulators. This brings into question whether the backup accumulators at Trojan will perform their intended functio During the implementation of EFP-1, operators will be out of the Control Room with the minimum required process instrumentation provided on the (C-160) remote shutdown pane This instrumentation does not include instrument air monitors or provisions for monitoring the failsafe positions of air supplied safety related or non safety related instrument Since the reliability of the instrument air system design and backup safety related accumulators is not supported by testing, and the licensee did not provide the inspection team with a supporting analysis, disabling the plant instrument air system in accordance with step "B" of attachment No. 3 to procedure No. EFP-1 appears to potentially place the plant in e condition outside of those analyzed in Chapter 15 of the FSA (2) The procedure was not opdated to reflect new licensee identified change (3) Operators were apparently unsure of some steps in the procedure (i.e. the operator implementing attachment 1 of the procedure was unsure of steps K and 0).
(4) An operator did not have a key to access the RHR pump roo (5) A sound powered phone was missing in one location where the '
operator implementing attachment I had to restore the nitrogen supply to the pressurizer PORV's and make pressure adjustments in accordance with the Shif t Supervisor instruction (6) Sound powered phones are the designated means of communications but they were not stored in secured cabinet (7) The emergency firo procedures Stored in the "B" Diesel Generator Room were found to be one revision behind the current revisio (8) In keeping track of the status of the shutdown, it was necessary for the $hif t Supervicor to work between the body of the procedure and the attachment The team took the position that this process could be enhanced by providing tabs for the
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6 a'ttachments and referencing the steps in the body of the procedure to the steps in the attachment The above items are considered an Unresolved Item (344/88-34-06)
pending further licensee action and NRC revie Operator Trainino The inspection team reviewed operator training records and interviewed a selected sample of plant operators to determine the extent that operators had been trained on the safe shutdown modifications and procedures implemented by the licensee for compliance with Appendix R. In general, the inspection team found the operators to be knowledgeable of the safe shutdown metho Appropriate classroom sessions had been conducted. However,
,
deficiencies in operator training were identified as follows:
(1) Training did not include periodic scheduled walkdowns of the emergency fire procedures. Only one shif t of plant operators had performed a walkdown of the procedure (2) Operators appeared to be unaware that they wou* be without certain diagnostic instrumentation (Thot, Teolo and source range) for approximately 40 minutes while implementing the alternative safe shutdown methodolog (3) The opers. tors interviewed indicated that they had a lack of confidence in the use of the Bailey computer system for alternate safe shutdown. They also indicated that they had no knowledge of the mounting brackets provided for portable emergency lights that the method relies on to accomplish certain required manual operator action During the inspection, the licensee indicated that the operator training program would be reviewed and immediate corrective actions taken where require The above appears to be inconsistent with section III.L.1 of Appendix R and is considered an Unresolved Item (344/88-34-07)
pending further NRC revie I. Use of Fire Pumps As a Backup to the Service Water System For the case where the fire pumps are used as a backup to the Service Water System, the licensee indicated that the diesel fire pump may be scheduled to be out of service for maintenanc Therefore, during this period it will not be available for this purpos During the inspection, the licensee was evaluating what (if any) compensatory measures would be implemented during this perio The licensee's internal Memorandum No. RQR-Q15-88, dated August 31, 1988, which was forwarded to NRC Region V, concluded that for a fire in fire areas M3 (Manhole 3), M4 (Manhole 4) and II (Service Water L_ n
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Pump Room), both fire pumps would be needed to supply the 4450 Gallons Per Minute (GPM) that would be needed as a backup water supply for the Service Water System. Therefore, during the period that either fire pump is out or service, the licensee's internal memorandum indicates that fire patrols will be established to detect and mitigate a fire in any of the three fire areas to prevent the-loss of all three service water pumps and the subsequent need to use the fire pumps as a backup to the service water pumps. The memorandum indicates that these measures will continue until an indepth review is completed or relief is granted by the NR This is considered an Open Item (344/88-34-08) pending further licensee and NRC actio J. Associated Circuits The inspection team reviewed the licensee's associated circuit analysis to determine the adequacy of protection provided for the common bus, common enclosure and spurious signal concern The results cf the team's review ars as follows:
(1) Common Bus Concern - The common bus concern arises when safety related or non-safety related electrical circuits share a common power source with safe shutdown equipment, and:
- The associated electrical circuits lack adequate separation from the required safe shutdown circuits, and:
- The required power source is not provided with coordinated electrical fault interrupting device protectio The licinsee's analysis'for this concern took credit for the coordinated electrical protection of power sources relied on to achieve safe shutdow (a) Circuit Coordinatfor - The team reviewed the licensee's circuit coordination by reviewing a representative sample of time-current characteristic curves developed for the electrical protective devices associated with the required safe shutdown power source The objective of the review was to verify that fire induced faults will be isolated by the individual load protective devices prior to the fault propagating to trip the upstream power supply feeder breake The following power sources were reviewed:
,
CIRCUIT COMMENT 125VOC BUS D10 Acceptable
"
125VDC BUS 40
"
120VAC BUS Y11
"
120VAC BUS Y22
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480VAC LOAD CENTER BUS B01
"
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480VAC MCC BUS 625
"
480VAC MCC BUS B21
"
4160VAC BUS A05
"
4160VAC BUS A01 (b) High Impedance Fault Concern - The high impedance fault concern arises in the case where multiple fire-induced faults exist as loads on a power supply required to achieve safe shutdown. Such faults are postulated to be of a value which is just below the trip point of the individual load circuit protective device The occurrence of a sufficient number of such faults within a given fire area may result in a trip of the power supply feeder breaker and therefore may cause the loss of the required power sourc I,' response to this concern, the licensee states in sectioi; 3.5.5.2 of the Trojan Fire Protection Plan (PGE 1012) tnat "due to the low probability of occurrence, the coordination for multiple high impedance circuit faults was not considered within the scope of its review."
To further highlight this concern to the licensee, by letter dated January 24, 1985, the NRC staff requested that the licensee provide additional information regarding this concern. The staff requested that the licensee provide either, "A quantification of the argument which demonstrates that if all the load side ci'.'cuits in a common fire area were to receive a fault, the coordination ensures that the power source is not lost"; Or, " A '
description of how a tripped breaker un the power supply resulting from multiple faults would be identified to the operators and the corrective action that would be take Also, verify that these actions can be taken prior to the plant entering a nonrecoverable state." This position was repeated by the staff and given to all licensee's as guidelines for addressing this concern in section 5.3.8 of Generic Letter No. 86-1 By letter dated March 6, 1985, the licensee responded to the staff's request and basically reiterated their previous position that due to the low probability of occurrence, further consideration of multiple high impedance faults was unwarrante Based on these statements by the licensee, the NRC staff concluded in SER supplement No. 5, dated October 15, 1985, that operators ,
could identify the location of a fault and the status of the br A>'r where an appropriate action could be taken to
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restot- .cse The inspection team's review disclosed that the licensee had not performed an analysis for this concern and did not '
have procedures in place to direct operator actions to
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mitigste the potential affects of such occurrence The NRC staff stated in supplement No. 5 to the SER that the licensee would rely on operator cctions to restore the affected buses. However, due to the lack of procedural gt,! dance, 'it was not clear to the inspection team how operators would identify those power sources which may be affected by the occurrence of high impedance fau?ts or how operators would be aware of which loads are requ' ired to be '
rcloaded onto the bus in a timely manner during bus restoratio (c) Circuit Srtaker and Relay Maintenance - The inspection team's revikv disclosed that the licensee currently performs circuit breaker maintenance on a rotating outage basis such that all breakers are tested at a frequency not to exceed six years for 480V MCC's and five years for 120VAC and 125VOC breaker The HRC staff position stated in the clarification letter to Generic Letter No. 81-12 states that, "In order to take credit for the coordinated protection of molded-case circuit breakers, the devices must be periodically exercised and inspected for ease of operation, and on a refueling outage basis, a sample of these breakers must be tested to verify tnat drift is within the allowed design limits."
While the licensee currently has an establist.ed maintenance program for molded sase circuit breakers, the inspection team identified the concern that this program is relatively new, having been implemented by the licensee just prior ti the 1988 refueling outag Apparently due to limitations Jf scheduling and manpower since the implementation of the program, all molded case circuit breakers of concern have not yet been subjected to the program's maintenance and testing requirement Therefore, the maintenance activities described in the NRC staf f's clarification letter to Generic Letter No. 81-12
- have not been performed for all molded-case circuit
! breakers relied on to provide coordinated circuit ( protection for fire induced fault Based on the inspection team's review, the Itcensee's apparent lack of adequcte procedures to address required operator actions during bus restoration from potential
, damage due to multiple fire induced high impedance faults and the lack of verification of molded-case circuit breaker operability, places the adequacy of the licensee's resolution to the common bus concern in questio This (items 3.J.(1)(b) and (c)) appears to be inconsistent with Sections I!!.G.3 and !!!.L.7 of Appendix R and is considered an Uaresolved item (344/88-34-09) pending further NRC revie l
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(2) Common Enclosure Concern - The common enclosare concern arises when redundant safe shutdown circuits are routed together in a raceway or enclosure and they are not electrically protected or, fire can destroy both circuits due to inadequate fire barrier protectio The inspection team found this concern to be satisfactorily addressed by the licensee based on a sample review of a sociated circuits that were identified as sharing a common enclosur (3) Spurious Sianal Concern - The spurious signal concern arises when the potential exists for fire initiated grounds, shorts and open circuits to cause false motor control and instro>ent indications such as those that occurred during the 1975 Browns Ferry nuclear plant fir This concern further extends to consideration for spurious operation of other safety related non-safety related components that would adversely affect safe shutdown capabilit By letter dated January 24, 1985, the NRC staff requested that the licensee provide additional information for the staff's review regarding spurious signal concerns. The staff's position stated in the Requesc for Additfor.a1 Information (RAI)
is consistent with section 5.3.1 of Generic Letter No. 85-1 The licensee responded to the staff's RAI by letter dated March 6, 1985 and stated that it is PGE's position that the two types of cable short conditions in question are of such low likelihood that they need not be considered in producing spurious compontat malfunction The licensee further stated that this position was applied to all potential spurious operation concern In addition, the licensee stated that high-low pressure interface valves had been addressed with regard to spurious valve operation resulting from DC and AC control circuit fault ased on these ,'atements by the licensee, the NRC staff concludud in n pp.6 ment No. 5 to the SER that manual isolation for DC contro , awer to components such as PORV's, AC and DC motor operateo ,alves, and solenoid operated valves, will prevent or terrina*.1 their potential '
spurious operation. During the inspection, the licensee reaffirmed the previcusly stated position regarding consideration given to high-low pressure interface valve spurious operation. The licensee further stated that in
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accordance with supplement No. 5 of the SER, adequate l procedures and administrative controls were implemented to l prevent or mitigate potential' spurious operation of equipmen The results of the inspection team's review of this concern are ,
as follows:
(a) Hiqh-tow Pressure Interface Concern - The high-low pressure interface concern exists where there is the potential for a single fire to induce the spurious operation of redundant motor operated isolation valve Such an event may result in a fire initiated unisolable ,
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Loss Of Coolant Accident (LOCA) outside of the primary contair. ment due to the inability of a low pressure system
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to withstand the suostantially higher primary system pressur The licensee's high-low pressure interface analysis did not take credit for the norma)1y open sootor operated PORV
, block valves (M0-8000A and MO-8008) which are connected in series and located upstream of the PORV's. The primary purposi for th(, licensee's position is that following a CR/CSR fire and control room evacuation, the licensee's ;
procedures require the shedding of of fsite power and the disabling of both emergency diesel generators. Therefore AC power would noc be available to operate these valve ;
Based on the inspection team's review of applicable schematic and control wiring diagrams, it appears that the occurrence of a singler hot short within either the CR/CSR could result in the spurious operation of either of the two pressurizer PORV's. To prevent or mitigate this condition, the licensee's procedure No. EFP-1 directs :
opetators to open the DC supply breakers for the PORV' r The procedures state that this action must be accomplished '
within five minutes. This preventive or mitigating action appears to h lettended to address the case cf a largo
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exposure fire requiring control room evacuation. However, the team determined that a small fire postulated to occur !
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in the CR/CSR that initiates ope: 'ng of the PORV prier to .
propagating into a large exposure fire and an immediate !
fire alarm, has the potential to significantly impact the i five minute time line established by the licensee for this conditio Furthermore, the occurrence of multiple fire
' induced hot shorts on the PORV cables was not considered [
j in the licensee's analysi,.
! This appears to be inconsistent with Sections III.G.3 and i!!.L.7 of Appandix R and is considered an Unresolved Item
- (344/88-34-10) pending further NRC ratvie .
(b) Current Transformer Open Circuit Secondaries - This i concern addrvsses the potential for a fire lnduced open j
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secondary circuit to overheat and result in an additional
, fire outside of the fire area of concern. The licensee's ana'.ysis for this concern (CT Overvoltage Fire Review, i Calculation TE-62, dated January 7, 1985) was reviewed by l the inspection team and found to be based on plant ;
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specific manufacturer's informatinn that verified current transformer protection in the event u a fire induced ;
open secondary circuit. In addition, in the event of a i CR/CSR fire, the licensee h s implemented procedures ta short the CT cables which will leave the switchgea- >
cubicles controlled through local / remote swit-hes at the r sMtchgear by contact i i !
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s 4 Emergency Lighting Section III.J of Appendix R to 10 "~a 50 required the licensee to install emergency lighting units with at an least 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery power supply in all areas needed for operation of safe shutdown equipment and in access and egress areas thereto. Open Item N /83-18-11 identified several NRC concerns regarding the adequacy of the licensee's lighting provided to support safe shutdown in 198 The concern that no emergency lighting war provided in the access and egress route between the Turbine Building and Intake Structure was identified in open item 344/83-18-11. As of this inspection, this condition continues to exist. In addition, a subsequent analysis by the licensee disclosed that for a fire in fire areas II, H3 and M4, equipment needed for safe shutdown is located near the south wall and on the west side of the Intake Structure. However, 5 the required emergency lighting was not provided in support of this safe shutdown method. . Additionally, the required emergency lighting was not provided in the Circulating Water Pump Pit at the pump discharge and suction valves and at the fire hydrant east of the Circulating Water Pump Pit, where other operator actions are required for safe shutdow Instead of the required fixed 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery power supply emergency lighting, the licensee elected to provide four 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> hand held portable lighting units for operator use in these area Two of the hand held portable lighting uni's . are stored in the Control Room and l two are stored in a radiologically controlled access are The portable units stored in the Control Room may be left there during a i Control Room evacuation because there is no procedure requiring I their use upon evacuation. These portable units are electrically charged by a non-vital electrical receptacle which would de-energize upon a loss of AC powe In this case, the portable lighting units
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auto,atically provide emergency DC lighting for the Control Room.
I During this period, their 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> capacity would be reduce In the I event that these portable lighting units are used by operators in I
support of safe shutdown, they are rather bulky, so the licenste installed mounts for them at the locations where they are exAected to be used in support of safe shutdown.
i During interviews with operators, the inspection team learned that the operators interviewed had no knowledge of the mounts for the portable emergency lighting unit The mounts are constructed with unistrut channels and when the inspection team requested licensee personnel to demonstrate installing the units into the mounts, the individuals encountered difficulty in completing this task due tc the construction of the mount This request was made by the inspection team during daylight hours. If this task had to be performed in the dark, the inspection team questioned whether or nut it could be achieve Although the use of portable lighting units is an alternate approach that the staff considers viable on a case-by-case basis, the
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licensee did not request and was not granted an exemption from the NRC for the lack of fixed 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery powered emergency lighting units in support of safe shutdow In addition, the inspection team questioned the adequacy of installed emergency lighting in the "A" Switchgear Roca, Turbine Building, and the 45 foot and 61 foot elevations of the Auxiliary Building, during the walkdown of alternative safe shutdown procedure No. EFP- The licensee's failure to install 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery powered emergency lighting units in support of safe shutdown is considered an apparent violation of section III.J of Appendix R to 10 CFR 50 (344/88-34-11). Communications Sections III.K.12.j and III.L of Appendix R require that instructions for plant operators and the necessary supporting functions be provided to permit operation of the equipment used for safe shutdow During alternate shutdown, the licensee relies on a sound powered phone system to provide the communications needed to sy port safe shutdow The independence of this system from the CR/CSR was reviewed by the inspection team and found to be satisfactor However, the availability of a required sound powered phone in one area and their method of storage in other areas was identified as a concern by the team. This is further discussed in paragraphs 3.G(4) and (5) of the repor . Generic Letter 86-10 Evaluations (64100)
The inspection team reviewed a selected sample of the licensee's Generic Letter 86-10 evaluations. The evaluations reviewed were adequat However, their content was found to be wea There was rio procedure in place to standardize the quality or content of the evaluation In one instance (water curtain fer fire areas Al and A3) where the licensee stated that the guidance of Generic Letter 86-10 was followed, toe licensee failed to perform the required evaluatio The licensee's txplanation for this was that a previous exemption for the installation of a water curtain had been granted by the NRC for another fire area and therefore the licensee assumed that the exemption could be applied to any fire are Evaluations reviewed by the inspection team included C-FP-1.3.1 for fire area boundariet, C-FP-1.3.4 for a plaster wall in the Control Building at elevation 65 feet; C-FP-1.3.6 for an open pipe chase between fh e areas ,
Al and A2; C-FP-1,3.9 for non-fire rated penetration seals in the seismic gap; C-FP-1,3.11 for the cable wrap system; C-FP-1,3.13 for fire protection materials inside containment; and C-FP-1.3.16 for the transient combustibl9 control progra Exarples of the weaknesses in the evaluations include the lack of proper consideratior for fixed and transient combustibles and the effects of locali7ed heating for assumptions made about fire severity potential in fire area . _ _ _ _ -
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The licensee acknowledged the apparent weaknesses in the evaluations and indicated that the existing evaluations would be reviewed and strengthened where necessary and procedures would be implemented to standardize the quality and content of the evaluation This is considered an Open Item (344/88-34-12) pending further licensee action and Region V revie . Fire Brigade Training and Fire Barrier Installations (64100)
The inspection team reviewed the licensee's fire brigade training program to the provisions of Section III.I of Appendix R and determined that the required training was being provide The team also verified on a sampling basis that "Thermolag" fire barrier wrap installations were installed with proper consideration for intruding steel or conduits and provided the requfred 1-hour or 3-hour fire barrier protection pursuant to design specification . Fire Protection Improvement Plan (64100)
The licensee identified that mole than 50 NCAR's (Non-Conforming Activity Reports) document fire protection code non-conformances. Examples of the non-conforming conditions include the inability of the diesel fire pump to meet rated design criteria (however, Technical Specification limits are being met), supervision of automatic fire suppression systems, pipe supports for automatic fire suppression systems and sizing of fire suppression system pipin In addition, during the inspection, the licensee provided the inspectors with copies of NCAR No. H88-79M, which identified deficiencies in the emergency fire procedures and operator actions required by the safe shutdown analysis breaker coordination protection schemes and the affects of approximately 100 recent Field Change Notices (FCN's), which were initiated as a result of the remote shutdown panel modification during the last refueling outage. The licensee indicated that review of fire protection code conformance and program implementation is ongoing. Work has been contracted to vendors and drs.vings and pre-fire plans are being revised. When this effort is complete, the licensee indicated that PGE 1012 would be revised to accurately reflect the status of compliance and appropriate NRC notification will be provided. This considered an Open Item (344/88-34-13) pending further licensee action and Region V revie . Trending of Fire Protection Events (64100)
The inspection team reviewed the licensee's corrective actions for Licensee Event Reports (LER's) submitted during the past year. The team noted that most of the LER's submitted in the fire protection area by the licensee determined that the cause of the event was personnel erro Prior to the inspection, the licensee had initiated a request for the Piant Monitoring and Event Analysis (PMEA) group to review these events and determine if any trends or common causes exist. This review was not complete at the time of the inspection and there was no other basis for the team to assess the adequacy of the licensee's corrective actions in
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this regar This is considered an Open Item (344/88-34-14) pending further licensee action and region V revie . OJen Items Open items are matters that htve been discussed with the licensee, that will be reviewed further by the inspector, and that involve some action on the part of the NRC, the licensee, or both. Open items disclosed during the inspection are discussed in Paragraphs .0, 2.Q 2.S, P.U, 2.V, 2.X, 3.I, 4 and . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, or items of noncompliance, or deviation Unresolved items disclosed during the inspection are discussed in Paragrapnr 3.8, 3.C. 3.0, 3.E, 3.F. 3.G, .J (1)(b) and (c) 3.J (3)(a).
10. Exit Meeting (30703)
An exit meeting was held with the licensee's staff on August 26, 198 The #.tems of concern in this report were discussed at that tim The licensee acknowledged the content and scope of the inspection findings.