IR 05000348/1985035

Insp Repts 50-348/85-35 & 50-364/85-35 on 850819-23.No Violation or Deviation Noted.Major Areas Inspected: Implementation of Fire Protection & Plant Shutdown Requirements of 10CFR50,App R

ML20132C776
Person / Time
Site:	Farley
Issue date:	09/20/1985
From:	Bradford W, Conlon T, Madden P, Mellen L, Miller W, Ruff A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20132C764	List: IR 05000348/1985035 ML20132C761
References
50-348-85-35, 50-364-85-35, NUDOCS 8509270142
Download: ML20132C776 (27)

Text

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e . 52 0teg UNITED STATES

Do NUCLEAR REGULATORY COMMISSION

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[ *' p REGION li 101 MARIETTA STREET, g j

• 2 ATLANTA, GEORGI A 30323 s*...+/

Report Nos.: 50-348/85-35 and 50-364/85-35 Licensee: Alabama Power Company 600 North 18th Street Birmingham, AL 35291 Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8 Facility Name: Farley Inspection Conducted: August 19-23, 1985 Inspection at Farley site near Do Alabama Inspectors: [ 'M W. H. Brad ord Date Signed

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'Date Signed Accompanying Personnel: E. A. R eyes, NRR/0RBI Approved by /d>//

T. E.~ Conlon, Section Chief

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'Date Signed Plant Systems Section Division of Reactor Safety SUMMARY Scope: This special announced inspection entailed 149 inspector-hours on site in the area of licensee's actions in implementation of the fire protection and plant shutdown requirements of 10 CFR 50, Appendix R, Sections III.G, III.J, III.L and II Results: No violations or deviations were identifie PDR ADOCK 05000348 0 PDR

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REPORT DETAILS Persons Contacted Licensee Employees

• L. Buck, Nuclear Engineering Technical Section L. Bradshaw, Generation Power Technical Superintendent J. Hayes, Plant Fire Protection Staff R. Hendley, Fire Brigade Training

• R. Hill, Operations Superintendent

• D. H. Jones, Nuclear Engineering Technical Section

• S. N. Knight, Senior Engineer

• R. H. Marlow, Assistant Plant Manager

• J. W. McGowan, Manager Safety Audit and Engineering Review

• B. L. Moore, Operations Unit Supervisor

• D. N. Morey, Assistant Plant Manager M. D. Stinson, Plant Modification Group

• L. A. Ward, Maintenance

• W. G. Ware, Supervisor, Safety Audits and Engineering Review

• F. G. Watford, Fire Marshal Other licensee employees contacted included craftsmen, engineers, tech-nicians, operators, mechanics, security force members, and office personnel. ,

Other Organizations Bechtel

• D. G. Butami, Electrical C. Folta, Electrical W. Francis, Electrical

• J. E. Love, Electrical

• P. L. Publ, Electrical

• L. J. Vaz, Site Engineer Southern Company Services

• R. F. Luca, Fire Protection

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• J. M. Maddry, Fire Protection

*J. W. Wilson, Fire Protection

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• Attended exit interview Exit Interview The inspection scope and findings were summarized on August 23, 1985, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding l

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l The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio . Unresolved Items Unresolved items were not identified during the inspectio . Compliance with 10 CFR, Appendix R, Section III.G and II An inspection was conducted to determine if the fire protection features provided for structures, systems, and components important to safe shutdown at Farley Units 1 and 2 were in compliance with 10 CFR 50, Appendix R, Sections III.G and III.L. The scope of this inspection was to determine if the fire protection features provided for the equipment and systems required to bring the plant to a hot standby condition were capable of limiting potential fire damage so that one train of these systems needed to achieve and maintain hot standby from either the control room or emergency control stations would be free from fire damag Safe Shutdown Capabilities To ensure safe shutdown capabilities, where cables or equipment of redundant trains of systems necessary to achieve and maintain hot standby conditions are located within the same fire area outside the primary containment, 10 CFR 50, Appendix R, Section III.G.2 requires that one train of hot standby systems be maintained free of_ fire damage by providing fire protection features which meet the requirements of either III.G. III.G.2.b, or III.G. On the basis of the above Appendix R criteria, the inspectors made an inspection of cabling and components associated with the Chemical Volume Control System, Auxiliary Feedwater System, Component Cooling Water System, Service Water Systems, and Onsite Power Distribution System to determine the adequacy of the fire protection features and separation afforded these essential safe shutdown system The licensee's submittal to NRC Region II of May 28, 1985 identified the specific shutdown systems and support systems required for safe shutdown and the location of the equipment and associated power and control circuit cabling. From this information the inspectors selected a randon sample of the following components and associated cables for review:

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Auxiliary Feedwater Pumps Component Cooling Water Pumps Service Water Pumps

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Valves in Service Water Supply to Diesel Generator Building Valves in Service Water Return from Diesel Generator Building Charging Pumps Reactor Water Storage Tank Outlet Valves Volume Control Tank Outlet Valves Atmospheric Relief Valves Charging Pump Room Coolers Motor Control Center Room Coolers Onsite Power Distribution System Safe shutdown releted instrumentation and associated circuits were not evaluated by the inspectors for compliance to Appendix R Section II The licensee is rerouting cables associated with this instrumentation and conducting other modifications required to meet the NRC guidelines of Regulatory Guide 1.97, Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following An Acciden These modifications are scheduled to be completed during the 1986 refueling outages. The licensee stated that upon completion of the modifications the safe shutdown instrumentation and related cabling will meet the separation requirements of Appendix R, Section II The Farley Nuclear Plant Fire Protection Program Reevaluation, Amendment 5 was used during this inspection as the " approved fire protection plan" for the review of the fire protection systems and features provided within each fire are The licensee submitted to the NRC on March 31, 1985 for Unit 2 and May 31, 1985 for Unit 1 exemption requests to the requirements of Appendix R involving a number of areas in which the plant did not meet Appendix R requirements. These submittals were supplemented by letters dated June 26 and July 19, 1985. The exemptions include plant areas, shutdown system separation and fire protection features which do not meet the literal requirements of Appendix These exemptions are currently under review by the NRC and will be addressed by separate correspondenc Rasults The safe shutdown components, both redundant functions and trains, which were reviewed during this inspection were found to meet one of the following classifications:

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safe shutdown trains (equipment, components and cabling) are located in separate fire areas that are separated from each other by 3-hour fire rated construction;

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redundant shutdown trains are located in the samo fire area but are separated by more than 20 feet with no intervening combus-tibles and with an automatic fire suppressicn system and smoke detection system provided in the fire area;

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redundant shutdown trains are located in the same fire area but are separated by less than 20 feet, one train is enclosed within a one hour fire rated barrier (raceway fire barrier wrap), and an automatic fire suppression system and a smoke detection system are provided within the fire area; or

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An exemption request with justifications has been submitted to the NRC for items which do not meet the literal requirements of Appendix R Section II Following NRC approval of the exemption requests and completion of the modifications associated with the exemptions, and completion of the instrumentation modifications associated with NRC Regulatory Guide 1.97, it appears that Farley Units 1 and 2 will meet the equipment train separation requirements of Appendix R, Section II (1) Fire Protection for Safe Shudown System / Components The Farley plant is divided into approximately 80 fire areas for Unit 1 and 54 fire areas for Unit These areas are separated from each other by construction features that have a 3-hour or equivalent fire resistance ratin Most of the fire areas are further subdivided into smaller fire zones by construction features having a fire resistance rating less than 3-hour The licensee's safe shutdown Appendix R analysis identified the fire areas in which the shutdown equipment and associated cabling were located. The inspectors reviewed this analysis and all fire areas which contained both Train A and B of the above listed shutdown components were selected for further evaluation. An inspection was made to determine if redundant cabling for the safe shutdown systems, required to achieve and maintain hot standby and cold shutdown conditions had been provided with adequate separation or protected in accordance with Appendix R, Section III. Included in the review was an evaluation of the acceptability of the barrier or enclosure construction configuration as a fire rated barrier as used in the plan Also, the review verified the adequacy of the installed penetration sealing systems, and fire dampers / fire doors with respect to installation and completeness, physical condition, and fire test documentatio The 1-hour fire barrier enclosures provided for the electrical cable raceways do not extend to or provide protection for the raceway supports. This item has been identified by the license Exemption No. 2-38 in the Farley Appendix R Fire Hazard Reevaluation Report of February 1985 provides justification for this discrepancy and requests that NRC approve an exemption to this requirement. This item is being reviewed by the NRC and will be addressed by separate correspondenc _ _ _ _ - _ _ _ - _ - _ - _ _

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Within the following fire areas the cable routings for redundant safe shutdown and the fire protection features afforded were inspected:

(a) Fire Areas (Unit 1) - 4 and 2 (Unit 2) - 4 Auxiliary Building, Elevations (Portions) 100', 121', 130', 139', 155',

165' and 175'

Fire Areas 1-4 and 2-4 includes portions of the radiation controlled areas of the Unit 1 and Unit 2 auxiliary buildin Penetrations through the area boundry are sealed or provided with protection equivalent to a 3-hour fire resistance rating, except doors to stairways and elevator shafts have a 1 1/2-hour fire resistance rating and exterior doors are not fire rate Smoke detection systems are installed in all rooms containing safe shutdown equipment or appreciable combustible materials. Portions of the fire areas are provided with automatic fire suppression systems. Interior hose stations are located throughout the fire area. One hour fire barrier enclosures are provided for electrical cable raceways were require The following cabling was inspected and verified to meet separation and protection requirements of Appendix R, Section III.G:

Train A Train B Function Cable / Raceway Cable / Raceway Charging Pump RWST IVAFU-05G/AHHB18 *1VBFV-TSD/BHF025 Suction Valves Charging Pump RWST **1VAFU-05P/AEF028 *1VBFV-T5P/BFDB2G Suction Valves HVAC for Changing IVAFA-HSP/AFD-36 *1VBFB-C2P/BFDB06 Pump Rooms **1VAFA-H5P/AFD-39 1VBFB-C2P/BFD-33 IVAFA-A6P/AFD-36 *1VBFB-C2P/BFDB12&l5

&203 HVAC for MCC #1VAHUAA2A/AHF176 IVBHVAA2A/BHF197 Rooms #1VAHUAA2P/AHli167 and 203 IVBHVAA2P/BHF198 and 203 Charging Pumps *1VADF06P/ADDA09 *1VBDG06P/BDE-09 Swing Charging IVADF07P/ADDA1A IVBG07P/BDE-1A Pump

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Swing Charging *1VCDF07P/CDD005 N/A Pump Swing Charging *1VCDF07Q/CD0006 N/A Pump Charging Pump *2VADF06P/ ADD 1C- *2VBDG06P/BDE06-Swing Charging 2VADF07H/AHF462 2VBDG078/BHM415 Pump 2VADF07P/ADDIAA 2VBDG07P/BDE1A-Swing Charging *2VCDF07P/CDD255 N/A Pump Swing Charging *2VCDF07Q/CDC256 N/A Pump Charging Pump **2VAFU-05D/AHF21A 2VBFV-T5D/BHF457 Suction Valve 2VAFU-05G/AHF441 (RWST) 2VAFU-05P/AFD12G 2VBFV-iSD/BFD06N 2VAQ5061B/AHF410 2VAQ5061D/AHF413 2VAQ5061E/AHF414 Charging Pump *2VAFA-H5C/AHD188 *2VBFBC2P/BFD06B Room Coolers *2VAFA-H5P/AFD0AE Swing Charging ***2VAFA-A6C/AHD18B 2VBFB-M5B/BHF264 Pump Room Coolers MCC Room Coolers ***2VAHUAAZA/AHF426 2VBHVAA2A/BHG350

• • • 2VAHUAA2P/AHH432 2VBHVAA2P/BHG350 Notes: * Raceway enclosed within a nominal one hour fire barrier

• • Raceway proposed to be enclosed within a one hour barrier by an exemption request

1. Redundant cables are located approximately 100' apart with no intervening combustibles

• • • Exemption request submitted for cables being in the same fire area; however, the redundant cables are provided with greather than 20 feet separation and at least one cable train is located within a area provided with automatic sprinkler protectio @ Exemption request submitted regarding existing separation.

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'(b) Fire Area 2 (Unit 2) - 1, Auxiliary Building, Elevations 83',100'

and 121'

Fire area 2-1 includes portions of the radiation controlled area of Unit This area is separated from the reminder of the plant by 3-hour fire rated construction, except the ceiling of 2223 room has tendon openings to room 2334 (fire area 2-34) and the doors into the stairways have a 1 1/2-hour fire ratin A smoke ,

detection system is provided throughout the area except for duct '

and pipe chases and tendon access rooms containing negligable combustibles. An automatic sprinkler system is provided for the piping penetration room on the 121' elevatio Manual hose stations and CO2 have reels from adjacent fire areas are available for use in this are One hour fire barrier enclosures are provided for electrical cable raceways were require The following cabling was inspected and verified to meet the separation and protection requirements of Appendix R Section III.G:

Train A Train B Function Cable / Raceway Cable / Raceway Charging Pump 2VAFA-H5C/AHD128, *2VBFB-C2C/BHJ251, Room Coolers & AHD09B BHM095, BNM065,

& BHM03S Swing Charging 2VAFA-A6C/AHD128, Pump Room Coolers & AHD09B 2VAFA-A6E/AHD12B Auxiliary Feed- 2VAFA-H4C/AHD128, *2VBFB-G5C/BHJ251, water Pump Room & AHD09B BHM095, Coolers BHM065,

& BHM03S Notes: Refer to description notes in above paragraph 5.a.(1).(a)

for additional information (c) Fire Areas 1-5 and 2-5, Auxiliary Building, Elevation 100'

Fire Areas 1-5 and 2-5 contains the three charging pumps for each unit. The pumps for each unit are each located in separate rooms that are separated by non-fire rated walls with normally closed, non-fire-rated watertight door Fire Areas 1-5 and 2-5 are separated from the remainder of the plant by 3-hour fire rated

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construction. A smoke detection system is provided throughout these areas. Manual interior hose stations and CO2 hose reels are available in the adjacent fire areas for use in these area Automatic sprinkler protection is provided in the hallways which ' .

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connect the three pump room This should prevent damage to more I

than one pump in the event of fir One hour fire barrier enclosures are provided for e'ectrical cable raceways were l require The licensee has reruested an exemption (Nos.1-34 and 2-8) for the inadequate fire rated barriers provided between the redundant pumps and safe shut,down component The results of these exemption requests wi31 be handled by separate NRC correspondenc The following cabling was inspected and verified to meet the separation and protectica requirements of Appendix R Section III.G:

Train A Train B Function Qbie/ Raceway Cable / Raceway Charging Pumps **2VADF06P/ADDIC- 2VBDG06P/BDE0A-Swing Charging *2VCDF07P/CDD255 NA Pump (AB)

Charging Pump 2VAFU-05D/AHF281 #2VBFV-75D/BHF275 Suction Valve 2VAFU-05G/AHF409 (RWST) 2VAFU-05P/AEF278 #2VBFV-75P/BHD2KB 2VAQ5061B/AHF410 Charging Pump #2VAFA-H5C/AHD128 Room Coolers #2VAFA-H5P/AFD3A- 2VBFB-C2P/BFD0BB Swing Charging #2VAFA-A6C/AHD15B 2VBFB-M5E/BHF279 Room Coller #2VCFA-A6P/CED254

1. 2VCFA-A6Q/CED253 Notes: Refer to description notes in above paragraph 5.a(1)(1)

for additional informatio (d) Fire Areas 1-6 and 2-6, Auxiliary Building, Elevations 100', 121',

139', 155' and 175'

Fire Areas 1-6 and 2-6 contains the auxiliary feedwater pumps and component cooling water pumps for each uni These areas are separated from remainder of the plant by 3-hour fire rated construction, except for removable nonfire-rated steel hatch covers between rooms 185 and 234, rooms 2185 and 2191, and the doors to the stairway have a 1 1/2-hour fire ratin A smoke detection system is installed in all rooms containing safe

shutdown equipment or appreciable combustible materials.

Automatic water fire suppression systems are provided for portions l of this fire area including the component cooling pump room. One I hour fire barrier enclosures are provided for electrical cable l raceways were require Also, some raceways are provided with a

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nominal 1/2-hour fire barriers which were provided prior to the Appendix R requirement The following cabling was inspected and verified to meet the separation and protection requirements of Appendix R, Section III.G:

Train A Train B Function Cable / Raceway Cable / Raceway Motor Drive *1VADF10P/ADE-0A 1VBDG10P/BDDA0A

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Aux Feedwater Pump Component Cooling IVADF04P/ ADD-1B *1VBDG04P/BDDA1B Water Pumps Component Cooling IVADF05C/AHD115 *1VBDG05N/BHD100 Water Pump (Swing) NA 1VCDF05P/CDD004 NA 1VCDF05Q/CD0003 Motor Driven 2VADF10P/ADE0A *2VBDG10P/BDD12A, Auxiliary BDD09A, Feedwater Pumps BDD06D, BDD03A, BFDOAD Motor Driven 2VAFA-H4C/AHD03B, *2VBFB-GSP/BFD120, Auxiliary AHD06 , BFD09D, Feedwater Pump 2VAFA-H4R/AFF0A- BFD06D, Room Coolers BFD03D, BFD0AD

@ Component *2VADF04P/ ADD 12 , *2VBDG04P/BDD12A, Cooling Water ADD 18- 8DD1BA Pumps

@ Swing Component *2VADF05C/AHD365 *2VBDG05K/BHD09E, Cooling Water *2VADF05P/ ADD 12 , BHD06E, Pump ADD 1A- BHD350

• 2VBDG05P/BDDIAA 2VCDF05P/CDD254 N/A 2VCDF05Q/CDD253 N/A Notes: Refer to description notes in above paragraph 5.a.(1).(a)

for additional information, i

As a result of the fire area walkdowns the inspectors identified that redundant component cooling water pump room cooler cabling was not properly separated in accordance with Appendix R Section II The licensee contended that, based on engineering

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judgement and the pump room volume, the pump room coolers were not needed to support the component cooling water pumps and that hot standby plant conditions could be achieved and maintain without component cooling pump room cooling. In order to substantiate their position, the licensee on August 22, 1985 conducted an area temperature monitoring test in accordance with surveillance test procedure FNP-2-STP-6 The test, with the component cooling water pump room coolers deenergized, monitored the pump room temperature over the operating component cooling water pump every 15 minutes. The test duration was ten hours. At the start of the test the ambient room temperature over the pump was 92* The maximum temperature rise above ambient was 3 F and that was achieved six hours into the test. At the conclusion of the test the room temperature was 95 F. Based on the test data, it appears that if redundant cabling associated with the component cooling water pump room coolers was damage by fire and the room coolers were rendered inoperable the ability to achieve and maintain hot standby conditions would not be jeopardize (e) Fire Area 1-13, Auxiliary Building, Elevation 121' through 175'

Fire Areas 1-13 consists of a cable chase which is separated from the remainder of the plant by 3-bour fire rated constructio A smoke detection system and automatic water fire suppression system are provided for this area. Manual interior hose stations and CO2 hose reels are availabe in the adjacent fire area for use in this are One hour fire barrier electrical raceway enclosures are provided were require The following cabling was inspected and verified to meet separation and protection requirements of Appendix R, Section III.G:

Train A Train B Function Cable / Raceway Cable / Raceway Component Cooling *1VADF04B/AHJ029 1VBDG04G/BHD127 Water Pumps *1VADF04E/AHE133 Component Cooling *1VADF05B/AHJ029 IVBDG05G/BHD127 Water Pump (Swi r. ; )

Charging Pumps *1VADF06B/AHJ029 1VBDG06F/BHD129

• 1VADF06C/AHE133 IVBDG06H/BHD129 1VBDG06L/BHJ148 Swing Charging *1VADF078/AHJ029 1VBDG07I/BHD129 Pump *1VADF07C/AHJ133 1VBDG07J/BHD129 1VBDG07K/BHD129 1VBDG07L/BHD129

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Note: Refer to descriptive notes in above paragraph 5.a.(1).(a)

for additional informatio The licensee has requested an exemption from Appendix R Section III.G.2.c to the extent that one train of redundant safe shutdown cables associated with instrument air, depressuri-zation/ letdown and RCS boundary, main steam isolation, and instrumentation cables are not separated by a 1-hour fire rated barrier in this fire are Justification for the lack of these barriers has been provided by exemption No. 1-1 The NRC will address this exemption by separate correspondenc (f) Fire Area 1-20, Auxiliary Building,121' Elevation Fire Area 1-20 contains electrical cables associated with both safe shutdown trains. This area is separated from the remainder of the plant by 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated construction, except for a nonfire-rated removable steel hatch between rooms 234 and 345 (fire area 1-42) and doors to the stairways have a 1 1/2-hour fire ratin A smoke detection system and an automatic water suppression system are provided for the entire fire area, except a suppression system is not provided for the battery charger roo A CO2 hose reel provides coverage for this are One hour fire barrier enclosures are provided for electrical cable raceways were require The following cabling was inspected and verified to meet the separation and protection requirements of Appendix R, Section III.G:

J Train A Train 8 Function Cable / Raceway Cable / Raceway Component Cooling *1VADF04B/AHJ029 IVBDG04G/BHD127 Water Pumps *1VADF04E/AHE133

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Component Cooling *1VADF05B/AHJ029 1VBDG05G/BHD127 Water Pumps (Swing)

Changing Pumps *1VADF06B/AHJ029 IVBDG06F/BHD129

• 1VADF07C/AHJ133 1VBDG07J/BHD129 1VBDG07K/BHD129 1VBDG07L/BHD129 Charging Pump *1VAFA-HSB/AHD102 IVBFB-C2E/BHF222 Room Coolers

Room Cooler *1VADF05B/AHJ029 IVBDG05D/BHG227 Swing Charging *1VADF05E/AHE133

Pump

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i - 12 Fire Area 2-020 Charging Pumps *2VADF068/AHF485 2VBL2F14A/BFD18M,

• 2VADF06C/AHF487 BFD21M, BF02CM

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2VBDG06F/BHF489, BHF03F, BHD344 2VBDG06H/BHF488, .

BHF03F, !

BHD353 2VBDG06L/BHG157 2VBL2F14A/BFD18M, BFD21M, l BFD2CM Swing Charging *2VADF078/AHF485 2VBDG07B/BHM24Y, Pump *2VADF07C/AHF487 BHM21Y,

• 2VADF07F/AHF487 BHM1BY, l BHM15Y, i BHG463 l

2VBDG07I/BHF489, i BHF03F, l BHD344 2VBDG07J/BHF487, BHF03F, BHD353 Charging Pump *2VAFAH58/AHF487 2VBFBC2D/BHM3'43, Room Coolers BHM24Y, 2VBFBC2E/BHG372, BHG12A, BHG09A, BHM15Y, BHM18Y, BHM21Y, BHM24Y, BHM343 2VBFBC2F/BHF18C, BHF490 Swing Charging *2VAFAA6A/AHF487 2VBFBMSC/BHF18C, l Pump Room BHF21C, l Coolers BHF24C

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2VBFBM5F/BHM343, BHM24Y, BHM21Y,

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BHM157, BHG09A, BHG12A, t

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BHG372 2VBFBM5G/BHM343, BHM24Y

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2VBFBM5H/BFH18C BHF490 Motor Driven *2VADF10E/AHF485 2VBDG10G/BIJ18 ,

Auxiliary BIJ21-Feedwater Pumps 2VBDG10H/BHF487, BHF03F, BHD344 2VBDG10L/BHG15Z 2VBL2F14A/BFD18M BFD21M BFD2CM Auxiliary *2VAFAH4B/AHF487 2VBFBG5D/BHM343, Feedwater BHM24Y Pump Room 2VBFBG5E/BHG372, Coolers BHG12A, BHG09A, BHM15Y BHM18Y BHM21Y BHM24Y BHM343 2VBFBG5F/BHF18C BFH490 Component *2VADF048/AHF486 2VBDG04D/BHG15Z Cooling Water *2VADF04E/AHF485 2VBDG04F/BHG15Z Pumps 2VBDG04G/BHF488, BHF03F BHD353 2VBDG04I/BHF487, BHF03F, BHD344 2VBDG04R/BHG15Z I

2VBL2F14A/BFD18M, BFD21M, BFD2CM Swing *2VADF05B/AHF486 2VBDG05D/BHG15Z Component *2VADF05C/AHE322 2VBDG05G/BHF489, Cooling Water *2VADF05E/AHF486 BHF03F, Pump BHD353 2VBDG05H/BHF488, BHF03F, BHD344 l

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2VBDG05K/BHF489, BHF03F, BHD344 2VBDG05R/BHG15Z 2VBL2F14A/BFD21M, BFD2CM (g) Fire Areas 1-21 and 2-21, Auxiliary Building, Elevation 121'

Fire Areas 1-21 and 2-21 contain Train 8 switchgear for the respective uni These fire areas are separated from the remainder of the plant areas by 3-hour fire rated construction. A smoke detection system is provided. The 4.16 Kv switchgear, SKv disconnect switch and the 600V load centers are protected by automatic CO2 systems activated by heat detectors located in each piece of equipmen Manual hose stations and CO2 hose reels are available in adjacent fire areas for use in these fire area Cable raceway fire barriers are not required for these area The separation and fire protection features provided for these areas meet Appendix R Section II (h) Fire Areas 1-23 and 2-23, Auxiliary Building, Elevator 121 These fire areas contain Train B switchgear for the respective unit and are provided with 3-hour fire rated separation between other plant area Smoke detection systems which activate a total flooding Halon system are provided for each switchgear room. A manual fire hose station is located in the adjacent fire area for use in these areas. Cable raceway fire barriers are not required for these area The separation and fire protection features provided for these areas meet the Appendix R Section II requirement (i) Fire Areas 1-41 and 2-41, Auxiliary Building Elevation 139'

These fire areas contain the Train A switchgear and load centers for respective unit and are separated from the remainder of the plant by 3-hour fire rated construction. A smoke detection system is provide The 4.16 Kv switchgear, 5 Kv disconnect switch and 600V load center are protected oy an automatic CO2 system activated by heat detectors located in each piece of equipmen Manual hose stations and CO2 hose reels in adjacent fire areas are available for use in these fire area Cable raceway fire barriers are not required for these area The separation and fire protection features provided for these areas meet Appendix R Section II (j) Fire Areas 1-42 and 2-42, Auxiliary Building, Elevation 139'

Fire Areas 1-42 and 2-42 are the corridors between the cable shaft-(Fire Area 13) and the cable spreading and Train A

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switchgear room These areas are separated from the remaining plant areas by 3-hour fire rated construction, except for the nonfire-rated removable steel hatches in the floor and ceiling between fire area 42 and fire areas 4 and 20, and the 11/2 hour fire rated doors to the stairways. A smoke detection system and automatic sprinkler system are provided for this area. One hour fire barrier enclosures are provided for electrical raceways were require The required cabling was inspected and verified to meet the separation and protection requirements of Appendix R Section III.G:

Train A Train B Function Cable / Raceway Cable / Raceway Component Cooling IVADF04B/AHJ029 *1VBDG04D/BHGZ27 Water Pumps IVADF04E/AHE133 Swing Component IVADF058/AHJ029 *1VBDG05D/BHGZ27 Cooling Water IVADF05E/AHE133 Pump Charging Pump See comments below *2VBDG06E/BHD57-Swing Charging See comments below *2VBDG06H/BHD57-Pump Charging Pump See comments below *2VBFBC2D/BHJ33Z Room Coolers Swing Charging See comments below *2VBFBM5G/BHJ33Z Pump Motor Driven See comments below *2VBDG10G/BIJ33-Auxiliary *2VBDG10J/BHD57-Feedwater Pumps Auxiliary See comments below *2VBFBG5D/BHJ33Z Feedwater Pump Room Coolers Component Cooling See comments below *2VBDG04D/BHG27Z, Water Pumps BHF33F

• 2VBDG04H/BHD57-

• 2VBDG04F/BHG27Z Notes: Refer to descriptive notes in above paragraph 5.a.(1).

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A fire in the Unit 2 fire area 2-20 could cause loss of Train "A" power distribution capabilities; however, no Train "B" power distribution system is in this area and the Train "B" shutdown components are enclosed within a 1-hour fire barrier. This meets the Appendix R Section III.G. requirement (k) Fire Area 56A, Diesel Generator Building This fire area contains a Train A switchgear room and is separated from adjacent fire areas by 3-hour fire rated constructio An area smoke detection system is provide Each individual switchgear in the area is protected by an automatic CO2 system which is activated by heat detectors located within each switchgear unit. Manual interior fire hose stations are provide Only one shutdown train of equipment is located in this room. The separation and fire protection features provided for these areas meet Appendix R Section II (1) Fire Area 56C, Diesel Generator Building This fire area contains a Train 8 switchgear room and is separated from adjacent fire areas by 3-hour fire rated constructio An area smoke detection system is provide Each individual switchgear in the area is protected by an automatic CO2 system which is activated by heat detectors located within each switchgear uni Manual interior fire hose stations are provide Only one shutdown train of equipment is located in this are This meets the separation and fire protection requirements of Appendix R Section II (m) Fire Area 72A, Service Water Intake Structure The service water intake structure is a separate building well detached from the main plant. Fire area 72A contains the service water pumps for both unit The pump room is separated from the associated switchgear rooms by reinforced concrete wall The

! doors between the pump room and each train switchgear room are nonfire-rated but are well separate A smoke detection system is provided throughout the fire area and an automatic sprinkler system is provided for the service water pumps, area coverage over the pumps, in the pump strainer area, and in the cable area in the northeast corner of the pump room which should prevent damage to both switchgear rooms in the event of a fire. Manual interior hose stations and exterior yard hydrants are provided. One hour fire barrier enclosures are provided for electrical raceway were required. Non rated fire barriers are also provided between redundant pump The licensee has requested an exemption (Exemption No. 1-3) from the Appendix R Section III.G requirements

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for the enclosure of one train of redundant cables and equipment by a 1-hour fire barrier and the provision of total automatic fire suppression system coverage for the entire fire are This

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exemption is being reviewed and will be addressed by separate NRC correspondenc The following cabling was inspected and verified to meet the separation and protection requirements of Appendix R Section III.G:

Train A Train B Function Cable / Raceway Cable / Raceway Unit 1 Power & 1VADF02C/AHP118 *1VBDG02C/BHQ108 Control Feeds IVADF02C/AHRC18 *1VBDG02C/BHRC48 1VADF02Q/ADN139 *1VBDG02Q/BDN129 IVADF02R/ADN140 Unit 1 Service 1ZADK03B/AHRC03 *1ZBDLO3B/BHRC45 Water Pumps 1ZADK03P/ADN142 *1ZBDLO3P/BDN132 1ZADK04B/AHRC03 *1ZBDLO4B/BHRC48 1ZADK04P/ADN143 *1ZBDLO4P/BDN133 Unit 1 Service *1ZAFK-C3C/AHS127 *1ZBL-C3C/ BHP 093 Water Pump *1ZAFK-C3P/AEN007 *1ZBFL-C3P/ BEN 105 Strainers Unit 2 Power & 2VADF02C/AHP368 *2VBDG02C/BHS358 Control Feeds 2VADF02Q/ADN387 *2VBDG02Q/BDN379 Unit 2 Service *2ZADK03P/ADN390 2ZBDLO3P/BDN382 Water Pumps *2ZADK04P/ADN391 2ZBDLO4P/BDN383 Notes: Refer to descriptive notes in above paragraph 5.a.(1).(a)

for additional informatio Within the areas inspected no violations or deviations were identifie b. Associated Circuits of Concern (1) General The separation and protection requirements to Appendix R, apply not only to safe shutdown circuits but also to associated circuits that could prevent operation or cause maloperation of safe shutdown systems and equipment. The identification of these associated circuits of concern was performed for the Farley Nuclear Site in accordance with NRC Generic Letter 81-12 and subsequent NRC clarification. Associated circuits of concern are defined as those circuits that have a physical separation less l

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than that required by Section III.G.2 of Appendix R, and have one of the following:

(a) A common power source (common bus) with the shutdown equipment and the power source is not electrically protected from the circuit of concern by coordinated breakers, fuses, or similar devices; or (b) A connection to cicruits of equipment who spurious operation (spurious signal) would adversely affect the shutdown capability; or (c) A common enclosure with the shutdown cables, and (Type 1) are not electrically protected by circuit breakers, fuses or similar devices, or (Type 2) will allow propagation of the fire into the enclosur At Farley Nuclear Site, for Appendix R, circuits that are needed for shutdown operations and circuit as a result of fire induced failures, that could defeat shutdown operations are classified and protected the same as safe shutdown circuit (2) Associated Circuits by Comon Power Supply (Common Bus)

Circuits and cables associated by common power supply are simply nonsafe shutdown cables whose fire-induced faiure will cause the loss of a power source (bus, distribution panel, or MCC) that is necessary to support safe shutdow This problem could exist for power, control, or instrumentation circuit The problem of associated circuits of concern by comon power supply is resolved by ensuring adequate electrical coordination between the safe shutdown power source supply breaker and the component feeder breaker or fuse In order to audit this concern at Farley Nuclear site, Electrical Distribution System Coordination Study Calculation No. 82, was reviewed and a sample selection of circuits were checked. The following are example of the components that were fed from or controlled by circuits that were reviewed during the inspectio Components Time-current charactristic curve RHR Pumps SK-E-135 CCW Pumps SK-E-134 CC Pumps SK-E-137 Service Water Pumps SK-E-126

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125V DC circuits on Sheet #83 in Calculation #82 Panel IB, 2B, 1E and 2E Farley Nuclear Station has a requirement for reevaluation protective relay setting This is an on going program with a maximum reevaluation interval of five years. This is acceptabl The licensee in their Alternative Shutdown Capability submittal of July 1982 identified that the control power indicating lights on the control room Emergency Power Board (EPB) for 4160 volt switchgear buses IF,1G, and 2G are connected directly to a 125V DC distribution panel branch without a fuse Fuses will be added during the next refueling outage in 198 This modification is covered by Production Change Requests 85-1-3211 and 85-2-321 The licensee stated that the modifications were scheduled exemptions which were approved as part of the items identified in the above submitta Exemption request No.1-3 will be handled by separate corres-pondenc This requests concerns coordination between safe-shutdown circuits and associated nonsafe-shutdown circuits powered from 125 VDC Distribution Panels IN, 2N, IM and 2 The safe-shutdown circuits from these panels provide control power for safe-shutdown breakers. The licensee states that a less of breaker control power from a single effected panel will not interrupt the operation of the load powered by the breake A loss of power to one of the subject DC Distribution panels will not preclude any necessary controls and operation of safe-shutdown equipment. If necessary, manual operation of the affected subject breaker would be possible. A design change has been initiated to improve the breaker coordinatio IE Information Notice 85-09, Isolation Transfer Switches and Post-Fire Shutdown Capability, was issued January 31, 1985. This Notice identifies a potential problem concerning fuses in contrcl circuits that are common for operation of equipment from the Control Room and Alternate Hot Shutdown area. A fire in the Control Room could cause these common fuses to blow before transfer is made to the Alternate Hot Shutdown are If the control circuit is needed at the Alternate Shutdown area to energize a piece of equipment and if the fuse (s) blew before transfer, equipment would not be operable without replacing the blown fuse (s). The licensee stated that this is not a problem at Farley because design changes have been made to assure that l

redundant fuses or circuit breakers exist in at least one train of

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alternate shutdown system circuit No exception to this i statement were noted for the circuits that were reviewe The licensee stated that as result of these design changes extensive analyses have been performed and that it had been concluded that Farley could shutdown to Appendix R requirements following a fire.

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(3) Associated Circuits Causing Spurious Operation (Spurious Signals)

Circuits associated because of spurious operation are those that can, by fire-induced failures cause safe shutdown equipment or nonsafe shutdown equipment to maloperate in a way that defeats the function of safe shutdown systems or equipment. Examples include the uncontrolled opening or closing of valves, or of circuit breakers, due to fire-induced damage to nonsafe shutdown instrument and control circuits that affect the control circuit interlocks of the safe shutdown component The analysis of spurious operations considered equipment (safe shutdown and nonsafe shutdown) that could affect safe shutdown of the plan The potential effects of associated circuits of concern were considered in the spurious operations analysi Redundancy between shutdown circuits with proper separation, protection, modification and/or analysis has been used by the licensee to resolve this concer Also, electrical power was removed from many valves whose position is the same for safe-shutdown and normal operation These valves have no automatic or manual realignment requirements for normal operations nor do they need to be repositioned for safe-shutdow The electri al t power was removed to eliminate any possibility of their operation as a result of induced spurious signal The Unit 2 high/ low pressure interface electrically operated valves were reviewed for spurious signal concern These valves are the residual heat removal (RHR) isolation valves, normal and excess letdown valves, sampling system valves, pressurizer power operated relief valves (PORV) and the reactor head vent valve The spurious operation of these valves were mitigated by valve redunancy, proper ~ separation, protection, analysis, operator actions and flow restrictors installed in some reactor coolant system fluid line The licensee identified certain exemption associated with these valves in their February 1985 Appendix R Reevaluation. These exemption requests will be handled by separate correspondenc (4) Associated Circuits by Common Enclosure A circuit, whether safety-related or not, is classified as an associated circuit of concern if it shares a common enclosure (e.g., cable tray, conduit, panel or junction box) with an Appendix R, " Required Circuit", and, is not adequately protected by circuit breakers, fuses or similar devices, or could allow fire propagation into the Shared Common Enclosur At the Farley nuclear site, the concern was answered satis-factorily wher a sample of circuits selected were all found to be electrically protecte Fire stops are installed whenever a cable

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4 penetrates a fire are In addition, the licensee's represen-tative stated that non safety related circuits were never routed from one redundant train to another. During the physical plant review no exception to this statement were foun (5) Damage Control Measures Appendix R Sections III.G.1.b and III.L.5 require fire protection features to be provided for structures, systems and components important to safe shutdown and to be capable of limiting fire damage so that systems necessary to achieve and maintain cold shutdown are free of fire damage or can be repaired such that the equipment can be made operable and cold shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Materials for such repairs are required to be readily available on site and procedures are to be in effect to implement such repair The inspector reviewed portions of Farley's Abnormal Operating Procedure (A0P) 28.1, Fire in Cable Spreading Room. This procedure is used to bring the plant to hot standby and cold shutdown under abnormal conditions and provides for repair measures, if necessary, to affect cold shutdow The equipment for the repair measures identified by this procedure have been dedicated for this purpose and are located in the Electrical Maintenance Storage Area under lock and key. All of the equipment was audited to the procedure requirements and was found tagged to identify it to the applicable procedure section so that its location and use, in an emergency, could be readily determine A walkdown for the designated routes for replacement of cables was made. The routes were found to be practicable and all areas were accessible for jumper installation and cable pullin Within the areas inspected na violations or deviations were identifie c. Alternative Shutdown Capabilities The inspectors reviewed operating personnel training, shift staffing and the licensee's use of operating and alternate shutdown procedures to determine if the requirements of Appendix R Section III.L were me (1) Personnel Training The inspectors reviewed selected training records that pertained to Appendix R. In addition, the inspectors conducted interviews with vperating personnel to determine consistency and adequately of Appendix R classroom and on-the-job trainin The results of the selected review of the Farley Appendix R training indicate it is satisfactor _

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The licensee demonstrated the minimum Technical Specification (TS)

staffing level was adequate for Procedure FNP-1-A0P-28.1, Fire in the Cable Spreading Room. The inspector noted that administrative procedures allow Farley to operate at the TS minimum staffing leve However, this inspection confirmed that procedure FNP-1-A0P-28.1, can be performed with the TS minimum staffing level in an adequate amount of tim (3) Appendix R Shutdown from outside the main control roo (a) Fire in Cable Spreading Room, FNP-1-A0P-28.1 and FNP-2-A0P-28.1 l The inspectors reviewed A0P-28.1 to verify that Appendix R Section III.L requirements listed below have been incor-porate Achieve and maintain hot standby conditions

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Achieve and maintain subcritical reactivity conditions in the reactor l

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Provide decay heat removal capabilities

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Maintain reactor coolant inventory and steam generator inventory

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Achieve and maintain cold shutdown conditions

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Provide direct readings of process variables necessary to control the above conditions (i) Procedure The inspector noted several minor procedural errors during the review of A0P-28.1, which included instrument air alignment and boron concentration calculation The errors were corrected and a revised procedure was issued before the inspection team left the sit In addition, the licensee made voluntary changes to reduce the manpower requirements of A0P-2 The current revision of A0P-28.1 is procedurally adequate.

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[ The licensee demonstrated through the implementation of A0P-28.1 that the plant could be brought to hot standby within 40 minutes with TS minimum staffing leve To further demonstrate the adequacy of A0P-28.1, the

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licensee performed an identical evolution on their plant simulator. Equipment was turned on at times that simulated the manual switching during the procedure walk-throug The simulator run demonstrated the conservatism in A0P-28.1. Through the use of the walk through and the simulator verification the licensee den:onstrated the adequacy of A0P-2 (iii) Communications During the walk through of A0P-28.1 the licensee relied primarily upon runners for communication between the remote shutdown panel and plant operators. While this was adequate for the purposes of A0P-28.1, Farley has a communications study in progress. A further evaluation of Appendix R communications will be performed when this study is complete (b) Fire in the Main Control Room, FNP-1-A0P-28.2 and FNP-1-A0P-2 The procedure was issued during the inspectio The preliminary evaluation indicates the procedure is adequat It will be reviewed in depth when the procedure addressed in below item 5.c.(5) are in compliance with applicable exemption (4) Remote Shutdown Panel (RSP) Instrumentation The following instrumentation was available to the RSP operator:

Instrumentation Location Pressurizer Level RSP Pressurizer Pressure RSP Hot leg temperature RSP Cold 42g tempcrature RSP Steam generator level RSP Steam generator pressure RSP Flux (source and full range) RSP Note 1 CST level Local RWST level Local Note 2 This instrumentation appears to meet the minimum instrumentation guidelines of Information Notice 84-09 Attachment 1, Item I Note 1: Flux monitoring system is currently not a TS ite The surveillance for the flux monitoring system is under the preventative maintenance program (PM Job No. NMI0048A-1)

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Note 2: RWST local level indication calibration has been added to FNP-0-FHP-1.0, controlling procedure for refuelin STP-4 contains the specific calibration procedur (5) Non-alternative Shutdown fires The procedures for non-alternative shutdown have been included in the Farley exemption reques The schedule reivew of these procedures will be based upon the final disposition of the appliable exemption request Within the areas inspected no violations or deviations were identifie . Compliance with 10 CFR 50, Appendix R, Section II Section III.J, requires that: " Emergency lighting units with at least an 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto."

The inspector (s) performed a walkdown inspection of the design and installation of the 8-hour emergency lighting unit The evaluation was based on licensee design drawings and Abnormal Operating Procedure FNP-1-A0P-28.1 " Fire In Cable Spreading Room."

The inspector determined that the 8-hour emergency lighting, installed to facilitate a safe shutdown of the plant as directed by A0P-28.1, is not adequate to fulfill the requirements of Appendix No 8-hour emergency lighting had been installed in the room containing Unit 2 hot shutdown panels "C" and "F".

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Several lights located in critical areas were mounted behind cable trays, piping, and other obstructions and could not be used as a light sourc In some areas there were not enough emergency lights installe On October 4,1984, the licensee received an exemption from NRC for schedule installation of portions of the alternate shutdown capability for Units 1 and 2. This exemption extends the deadlines for completion of portions of the alternate shutdown system until the end of the 1986 refueling outages for each uni The licensee stated that all fire related safe shutdown procedures will be finalized and ia place at this tim The licensee also stated that the 8-hour emergency battery powered lights will be installed and functionally evaluated by the use of each safe shutdown operating procedure to verify that the lighting is adequate to perform each operational step called for in the procedur This area will be reinspected at a later date.

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Within the areas inspected no violations or deviations were identifie . Compliance with 10 CFR 50, Appendix R, Section III.0, Oil Collection System The reactor coolant pump (RCP) shall be equipped with an oil collection system if the containment is not inerted during normal operation. The oil collection system shall be so designed, engineered, and installed such that failure will not lead to fire during normal or design basis accident conditicns and that there is reasonable assurance that the system will withstand the Safe Shutdown Earthquak Such collection systems shall be capable of collecting lube oil from all potential pressurized and unpressurized leakage sites in the reactor coolant pump lube oil system Leakage shall be collected and drained to a vented closed container that can hold the entire lube oil system inventor A flame arrestor is required in the vent if the flash point characteristics of the oil present the hazard of fire flashbac Leakage points to be protected shall include lift pump and piping, overflow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines and lube oil reservoirs where such features exist on the reactor coolant pumps. The drain line shall be large enough to accommodate the largest potential oil lea A visual inspection of the Farley Nuclear Plant reactor coolant pump oil collection systems was not made during this inspection since both units were operatin A review was made of certain construction drawings to evaluate the design of the syste The oil collection systems modifications consisted of enclosures, catch basins, drip pant, drain lines and collection tanks, which appear to be in compliance with Appendix To protect against an oil leak in the oil lift system, oil cooler and oil cooler piping, enclosures are provided isolating the pressurized oil components from the environment. Drip pans are provided under the upper and lower oil level controls, upper RTD conduit box and below the motor coupling. A catch basis is provided below the RCP motor and just outside the periphery of RCP/ motor shaf t coupling flanges. The flanged connections on the oil piping and oil cooler are provided with enclosure = to prevent potential oil leakage problem Drain lines are provided from the drip pans and from the enclosures to a vented collection tan Because of the high flash point characte-ristics of the oil, a flames arrestor is not provided in the vent lin The collection tank has a capacity of 300 gallons as compared to 265 gallons of oil in the lube oil system of each pump. A drain tank is provided for ecch reactor coolant pump oil collection syste The individual reactor coolant pump oil collection systems are designed to withstand Safe Shutdown Earthquak ,

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The inspector reviewed documentation contained in Production Change Notice (PCN)-81-963 for 'Jnit 1, and (PCN)-81-2007 for Unit 2, and verified that components of the systems were seismically qualified to remain functional following a design base seismic even Within the areas reviewed, no violations or deviations were identifie . Fire Brigade Drill During this insepetion, the inspectors witnessed an unnounced fire brigade dril The intent of this drill was to establish a scenerio which would cause the plant operators to evacuate the control room, implement abnormal operating procedure A0P-28.1 and regain control of the plant from the hot shutdown panel (see pagagraph 5.c regarding the walk-through exercise of A0P-28.1).

The fire scenario was a fire in the Unit 1 cable spreading room, fire area 1-040 on Auxiliary Building elevation 139-0", in an overhead cable tray in the center of the room. In addition, the fire condition due to the heavy smoke conditions caused the visability inside the room to be limite It should be noted that the fire brigade drill was terminated by the shift supervisor at the commencement of the walk-thourgh of A0P-2 Therefore, the inspectors did not make a full assessment of the fire brigades capabilities to effectively execute proper manual firefighting technique Six fire brigade members, in full protective clothing responded to the fir Ten minutes af ter arrival of the fire brigade, the fire brigade leader gave the order for one member to don a piece of self contained breathing apparatus, gain access into the room and try to extinguish the fire with portable CO2 fire extinguishe Fifteen minutes into the fire scenario the drill was terminated by the shift superviso The fire brigade organization will be further evaluated during a subsequent NRC inspectio l

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