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Revision as of 21:45, 1 August 2020
ML20133A725 | |
Person / Time | |
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Site: | Crystal River |
Issue date: | 09/20/1985 |
From: | Conlon T, Hunt M, Mcelbinney T, Mcelhinney T, Mellen L, Miller W, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
To: | |
Shared Package | |
ML20133A714 | List: |
References | |
50-302-85-30, NUDOCS 8510020290 | |
Download: ML20133A725 (25) | |
See also: IR 05000729/2008002
Text
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[R Clou ,D UNITED STATES
o NUCLEAR REGULATORY COMMISSION
[ - #
n REGloN li
101 MARIETTA STREET, N.W.
g j
- ** ATLANTA, GEORGI A 30323
%...../
Report No.: 50-302/85-30
Licensee: Florida Power Corporation
3201 34th Street, South
St. Petersburg, FL 33733
Docket No.: 50-302 License No.: DPR-72
Facility Name: Crystal River 3
Inspection Conducted: July 29 - August 2, 1985
Inspectors: ,
M ~
' ZO'N
W. H. Miller, Jr. ,%m L Date Signed
.W.
G. R. Wiseman
\N W 9lMIB6
Date Signed
. N/ v Ch C- 9'" M- 8C
L. S. Mellen '
'Date Signed
O
M. D. Hunt
k?/ 7f. .
'
4 Y TO SL"
Date Signed
w vv2 &
T. F. McElhinney
c(bkamf4 9ff9h.f
Date Signed
Approved h I/// /M [ 24 I
T.' E. Conlon, Chief, Plant Systems Section Date Signed
Division of Reactor Safety
SUMMARY
Scope: This special announced inspection involved 220 inspector-hours on. site in
the areas of fire protection and the licensee's actions regarding the implementa- I
tion of the requirements of 10 CFR 50, Appendix R, Sections III.G. , III.J., !
III.L., and III.O. l
Results: No violations or deviations were identified.
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REPORT DETAILS
1. Persons Contacted
Licensee Employees
- W. Wilgus,. Vice President Nuclear Operations
- P. McKee, Plant Manager
- G. Boldt, Plant Operations Manager
- E. Howard, Director, Site Nuclear Operations
- E. Renfro, Director, Nuclear Operations Materials and Controls
- W. Rossfeld, Site Nuclear Compliance Manager
- J. Alberdi, Site Nuclear Operations Technical Services Manager
- L. Kelley, Nuclear Operations Training Manager
- G. Westafer, Manager, Licensing and Fuel Management
- K. Wilson, Supervisor, Site Nuclear Licensing
.*S. Powell, Senior Nuclear Licensing Engineer
R. Widell, Manager, Nuclear Engineering
- R. Schmiedel, Nuclear Electrical Engineer
- R. Low,- Nuclear Electrical Engineer
C. Bergstrom, Nuclear Operator
T. Miller, Nuclear Shift Supervisor
M. Kirk, Nuclear Operations Technical Advisor
T. Metcalf, Nuclear Operations Technical Advisor
W. Stephenson, Operations Engineer
H. Koon, Senior Electrical and I&C Supervisor
M. Penovich, Superviser, Operations Training
L. Allegood, Nuclear Materials Coord_inator
- J. Russell, Senior Nuclear Fire Protection Specialist
- C, Williams, Nuclear Fire Protection Specialist
T. Austin, Nuclear Mechanical Engineer
'Other Organizations
- R. Vaughn, Gilbert Commonwealth Inc.
- S. Ford, Science Application International Corp.
M. Horrell, EBASCO
- P. Blomberg, Fluor Engineers Inc.
- K. Kimball, Impell Corp.
- D. Rhoads, Gilbert Commonwealth Inc.
- K. Kramer, Gilbert Commonwealth Inc.
- P. Shipper, Gilbert Commonwealth Inc.
R. 0'Laughlin, Professional Loss Control Inc. l
J. Antignano, Fluor Mechanical Services, Inc. l
,
I NRC Resident Inspector
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- T. Stetka, Senior Resident Inspector
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- Attended exit interview
2. Exit Interview
The inspection scope and findings were summarized on August 2,1985, with
those persons indicated in paragraph 1 above. The inspectors described the
areas inspected and discussed in detail the inspection findings listed
below. No dissenting comments were received from the licensee.
a. Inspector Followup Item 302/85-30-01, Verification of Cable Raceway
Fire Barrier Installation - paragraph 5.b.
b. Inspector. Followup 302/85-30-02, Technical Specifications Required for New
Remote. Shutdown Panel - paragraph 5.c.
c. Unresolved Item 302/85-30-03, Completion of Dedicated HVAC System for
Control Complex - paragraph 5.d.
d. Inspector Followup Item 302/85-30-04, Review of Licensee's Completed
Fire Door Modifications as Denoted by MAR No. 85-02-10-01 - para-
graph 5.f.
e. Inspector Followup Item 302/85-30-05, Verification of Unobstructed
Sprinkler System Spray Patterns - paragraph 5.g.
f. Inspector Followup Item 302/85-30-06, Review of Licensee's Corrective
Actions for NCR No.85-130 - paragraph 5.h.
g. Inspector Followup Item 302/85-30-07, Examine the Reliability of the
Motor 0verload Heater Element Trip Devices as 0pposed to a Magnetic
Trip Circuit Breaker for RB Fan No. 3B. - paragraph 6.a.
h. Inspector Followup Item 302/85-30-08, Review of the Implementation and
Training for AP-880 - paragrapn 7.a.(1).
i. Inspector Followup Item 302/85-30-09, Review of Communications and Area
Access for Control Room Evacuation - paragraph 7.d.(2)(a).
J. Unresolved Item 302/85-30-10, NRR Review and Approval of Appendix R
Emergency Lighting - paragraph 8.
The licensee did not identify as proprietary any of the materials provided
to or reviewed by the inspectors during this inspection. ;
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3. Licensee Action on Previous Enforcement Matters j
l
This subject was not addressed in the inspection.
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4. Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or devia-
tions. New unresolved items identified during this inspection are discussed
in paragraphs 5.c,-5.d, and 8 of the report.
5. Compliance with 10 CFR, Appendix R, Sections III.G. and III.L.
An inspection was conducted to determine if the protection features provided
for stru ,tures, systems, and components important to safe shutdown at
Crystal River Unit 3, were in : compliance with 10 CFR 50, Appendix R,
Sections III.G. and III.L. The scope of this inspection determined if th'e
fire protection features provided for identified essential safe shutdown
systems were capable of limiting potential fire damage so that one train of
these systems essential to achieving and maintaining hot standby from either
the control room or emergency control stations are free from fire damage.
a. Safe Shutdown Capabilities
In order to ensure safe shutdown capabilities, where cables or equip-
ment 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.2.a,.III.G.2.b, or III.G.2.c.
On the- basis of the above Appendix R criteria, the inspectors made an
inspection of cabling and components associated with the makeup and
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purification system, emergency feedwater, electrical power . system,
nuclear service closed cycle cooling system, reactor coolant system,
main steam system, support air handling systems, and secondary plant
instrumentation to determine the adequacy of the fire protection
features and the separation afforded for these essential shutdown
systems.
(1) Fire Protection for Safe Shutdown Systems / Components
Crystal River Unit 3 is divided into numerous fire areas as
designated by the building name,-building elevation, and area / zone
number as depicted on the fire areas and zones (Cadd Levels 11 and
30: L-001-Series) set of drawings.
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 have been provided with
adequate separation or protected in accordance with Appendix R,
Section III.G.2.
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Included in the review was an evaluation of the acceptability of
the barrier or enclosure construction . configuration as a fire
rated barrier as'u' sed in the plant. Also, the review verified the
adequacy of the installed penetration sealing systems, and fire
dampers / fire doors with respect to installation completeness,
physical condition, and fire ~ test documentation.
Within the following fire areas and their associated fire zones,
the cable routings for redundant safe shutdown and the fire
protection features afforded for t' ,e areas were inspected:
(a) Auxiliary Building, Elevation 95', Fire Area 3, Fire Zones
AB-95-3AA, 3B, 3D, 3E, 3F, 3G, 3K, 3X, 3Z, 3Y.
Safe Shutdown Fire Zone Train 1 Train 2
Systems / Function Fire Area Raceway / Conduit Raceway / Conduit
Makeup Charging 3AA * MUM 13-4 MUM 55-4
3E&3F MUM 1-T MUM 33-T
500 *503
3X *MUV-73 MUV-58
3W *MUC403-1 MUC399-1
3B *100 503
Nuclear Service 3G 500 *503
Seawater 3Z 501 *540
Emergency Feedwater 3B *629 EFE75-3
- 300 EFS59-2
- 100
- 516
NOTE: * Raceways or components to be protected with fire
rated enclosures
An inspaction was made of the makeup charging pumps area to
detamine if the system and the components required for safe
shutdown were provided with the fire protection features and
cable separation in accordance with Appendix R, Section
III.G.2 criteria.
The inspectors verified that the three makeup pump cubicles
.
(Fire. Zones AB-95-3E, 3AA, and 3F) were separated from Fire
( Zone AB-95-3D by a full height three hour fire barrier wall.
One makeup pump is located in each of the three cubicles.
One end pump (3A) is powered and controlled by Train 1
circuits, the other end pump (3C) by Train 2 circuits and the
center swing pump (38) by either Train 1 or 2 circuits.
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The makeup pump cubicles are separate by two full height
concrete walls; however, are connected by an open three foot
wide common corridor.
The local control stations for makeup pumps 3A, 3B, and 3C
are located on the cubicles walls near the openings which
form the common corridor between pump cubicles.
The control stations for pumps 3A and 3C are separated by 16
feet and the two partial concrete walls. No intervening
combustibles are located in the corridor between the control
stations. In addition, the swing pump (38) control station,
located in the center cubicle, is normally deenergized and
must be powered by closing _ a breaker in a MCC located in a
separate fire area.
In the makeup pump area there are ionization smoke detectors
installed which alarm and annunciate in the control room.
Also, an automatic wet pipe sprinkler system has been
installed in the common corridor that connects the ' pump
cubicles. This. arrangement was the subject of an exemption
request and has been reviewed and approved by NRC/NRR. Refer
to paragraph 5.b for a discussion of this exemption request.
Redundant cabling and the valves (MUV-73 and MUV-58) for the
makeup pump's suction alignment to the borated water storage
tank are located within the common Fire Zone, AB-95-3X.
Valve MUV-73 and its associated circuits will be provided
with three-hour fire noted barrier enclosures wraps. The
inspectors reviewed the completed fire barrier enclosure for
valve MUV-73. This enclosure appears to provide the required
fire barrier separation in accordance with Appendix R,
Section III.G.2, to protect one train of the ' makeup charging '
path from a postulated fire in this area.
During the fire barrier walkdown in Fire Area 3, (Fire Zone
AB-95-3Z), the inspectors noted that the seismic rattle space
between the Auxiliary Building / Intermediate Building walls
and the Reactor Building wall was sealed with a cork seal
material. This material has not yet been tested as an
approved through penetration fire stop system. This wall
(located near door assembly A-107). is designated as a three
hour rated fire area boundary wall separating the Auxiliary
Building and Intermediate Building. The licensee provided an
evaluation dated July 30, 1985, of the boundary wall which
was reviewed.
The evaluation indicates that on the Auxiliary Building side
of the fire barrier wall (Fire Zone AB-95-3Z) is located safe
shutdown equipment (Emergency Nuclear Service Cooling Pumps)
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approximately 15 feet away in an area with low combustible
loading (less than 15 minute duration). On the Intermediate
Building side of the barrier wGll chere is negligible
combustible loading in the Annulus (Fire Zone IB-95-200-B)
and no safe shutdown equipment or cables within 100 feet of
the boundary wall. Based on our review of the evaluation and
a walkdown, it appears that the unrated cork penetration seal
material installed in the fire wall seismic rattle space
between the Intermediate Building and Auxiliary Building on
elevation 95 feet will not adversely affect plant safe
shutdown in event of a fire in this area and that the
existing configuration is, therefore, acceptable.
(b) Auxiliary Building, Elevation _119', Fire Area 6, Fire Zones
AB-119-6A, 6E, 6J
Safe Shutdown Fire Zone Train 1 Train 2
Systems / Function Fire Area Raceway / Conduit Raceway / Conduit
Makeup Charging 6A 118 *121
System (Makeup 6E 570 *567
Pumps)
Air. Handling 6A 667 *567
System (Diesel 6E 562 *567
Generator Room
Fans)
Electrical Power 6E *551 *567
Distribution
NOTE: * Raceways to be protected with fire rated enclosures
The inspectors verified that Fire Zones AB-119-6A and 6E
(Fire Area 6) were separated ~ from other plant areas by
equivalent three hour fire rated barriers. During their
walkdown, the inspectors noted that the hydrogen (H2) line to
the makeup tank was routed through the area. The licensee
stated that the H2 line is routed inside guard piping
throughout the area and is seismically supported. It appears
that this arrangement would preclude a potential hydrogen
leak in a plant area that contains safe shutdown equipment
and/or cabling, and is, therefore, acceptable.
The inspectors verified that early warning ionization type
fire detectors were provided in the area of Fire Zones
A8-119-6A and 6E. In addition, the inspectors verified that
the sprinkler system protecting these fire zones provided
full floor coverage. The sprinkler system protecting these
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fire zones is a dual level automatic wet pipe type system
comprised of ceiling level sprinklers over the cable / conduit
runs and a level of sprinklers located below the cable tray
obstructions. It appears that if an exposure fire was to
occur within either Fire Zones AB-119-6A or 6E, the present
sprinkler design should be capable of controlling the fire.
(c) Auxiliary Building, Elevation 119', Fire Area 7, Fire Zones
AB-119-7A and 78-
Safe Shutdown Fire Zone Train 1 Train 2
Systems / Function Fire Area Raceway / Conduit Raceway / Conduit
Electrical Power 7A *562 571 and 572
Distribution
Air Handling 7A *562 572
System (Diesel
Generator Room Fane)
NOTE: * Raceways to be protected with fire rated enclosures
The inspectors, during their walkdown of Fire Area 7,
verified that early warning ionization type smoke and thermal
heat detectors' which alarm and annunciate in the control
room, were provided and approximately distributed throughout
the area. In addition, the inspectors verified that the
sprinkler system protecting these zones provided full area
coverage.
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(d) Intermediate Building - Elevation 95', Fire Area 200, Fire
Zones IB-95-200B, and 200C.
Safe Shutdown Fire Zone Train 1 Train 2
Systems / Function Fire Area Raceway / Conduit Raceway / Conduit
Emergency Feedwater 2008 EFM-5, EFM4, *EFE24, *EFE22
EFE96, EFE55, *MOV ASV-5,
EFE35, EFE113, *EFV-11, *EFV-14,
EFE115, EFE32, *EFE45, *EFE25
EFE34, EFE52, *EFE26, EFV32,
EFE54, EFE78, *EFE97, *EFE95,
302 "EFE42, *EFE44
- EFE108, *EFE110,
- EFE73
200C *EFE96, *302 EFS70, EFS59,
EFE95, EFE75
NOTE: * Raceways or components to be protected by fire rated
. enclosures
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The inspectors reviewed the installation of a Thermolag 330-1
fire barrier enclosure assembly constructed around emergency
feedwater valve EFV-14 located in Fire Zone IB-95-200B. This
enclosure is designed to protect the valve and its associated
electrical components from an exposure fire and provide fire
barrier- separation from the systems redundant valve located
in the same fire area. The inspectors reviewed the design
modification package MAR No. 82-10-19-11 to verify the
details of construction of the enclosure and its associated
pipe penetration fire stop seals. The inspectors reviewed
FCN No. 6A, drawing 5-521-267, Revision A, which provides the
details of the enclosure and drawing ICMS CR-M-03-13 which
details the pipe penetrations sealing system. These docu-
ments indicate that the installed enclosure configuration is
of an approved one hour fire resistive construction as
documented by TSI Inc., and that the 3/4 inch thick Dow
Corning #96-081 RTV caulk pipe penetration fire stop seal
system was fire tested by Underwriters Laboratories
[ASTME-814 (UL1479)] on June 1984, for a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rating.
The inspectors verified that early warning ionization type
detectors were provided throughout Fire Zone IB-95-200C and
within the area of the emergency feedwater pump cubicles in
Fire Zone IB-95-200B. As discussed in paragraph 5.a.(1)(a)
of this report the inspectors verified that no shutdown
related cabling was routed within the annulus area of Fire
Zone IB-95-200B.
Based on this review and walk-through, it appears that the
fire protection features associated with Fire Zones
IB-95-200B and 200C provide a level of protection which
should maintain one train of systems necessary to achieve and
maintain hot standby free from fire damage.
(e) Intermediate Building, Elevation 119', Fire Area 201, Fire
Zone IB-119-201A.
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The inspectors observed the installation of the TSI Thermolag
fire rated barrier enclosures / wraps for the protected safe
shutdown conduits (MSE42 and 52) located in Fire Zone
IB-119-201A. The completed fire barrier enclosures within
this area appear to be installed on the conduits in accor-
dance with the design limitations imposed on the TSI
Thermolag fire tested configurations. The installed fire
barrier application appeared continuous and included fire-
proofing of the load-bearing structural steel members which
support the conduit fire barrier enclosure assemblies. The
inspectors noted that all structural steel and non-safe
shutdown conduits that interface with the fire barrier
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enclosure assembly were provided the required fireproofing
protection- application in accordance with the fire-tested
configurations for the Thermolag fire rated barrier designs.
This review indicates that the Crystal River 3 conduit fire
barrier enclosure design and installation compare favorably
with the "as-tested" configurations for the conduit fire
barrier enclosures and; appears to be acceptable.
(f) Control Complex, Elevation 108', Fire Area CC-108-102.
Safe Shutdown Fire Zone Train 1 Train 2
Systems / Function Fire Area Raceway / Conduit Raceway / Conduit
Electrical Power 102 628 *640
Distribution
Emergency Feedwater 102 628 *640
633 *EFE73-3
Makeup Charging 102 628 *120, *643
633 *650, *651
Nuclear Service 102 628 *640
Closed Cycle Cooling
NOTE: * Raceways to be protected by fire rated enclosures
The inspectors verified that Fire Area CC-108-102 was
separated from other plant areas (Fire Areas CC-108-103, 105, i
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and - 107. ) by equivalent three hour fire barriers. The
inspectors reviewed doors C208 and C213. These doors appear '
to be UL listed fire door assemblies; however, door C213 has
, piping, heating and ventilating (HVAC), and cable penetra- i
tions through the transom panel which voids the labeled door
assembly. This item has been identified by the licensee and
a modification package has been developed. This item is
discussed in detail in paragraph 5.a.(1)(f) of this report.
The inspectors performed a walkdown of the area and verified
that early warning ionization type detectors were provided.
(g) Control Complex, Elevation 108', Fire Area CC-108-104
Safe Shutdown Fire Zone Train 1 Train 2 i
L ~ Systems / Function Fire Area Raceway / Conduit Raceway / Conduit
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Electrical Power 104 101 *103
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Distribution
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NOTE: * Raceways to be protected by fire rated enclosures
The inspectors performed a walkdown and verified that fire area
CC-108-104 was separated by equivalent three hour rated
construction from adjacent Fire Areas, CC-108-103 and 106. The
inspectors verified that early warning ionization type detectors
were provided within the fire area.
(h) Control Complex, Elevation 108', Fire Area CC-108-105
Safe Shutdown Fire Zone Train 1 Train 2
Systems / Function Fire Area Raceway / Conduit Raceway / Conduit
Air Handling 105 *629, *630 642
System /(Diesel
Generator Room
Fans)
Makeup Charging 105 *628, *629, 120
- 630
Emergency Feed- 105 *631, *630 641, 6a2
water *628, *629
NOTE: * Raceways to be protected by fire rated enclosures
The inspectors verified that . Fire Area CC-108-105 was
separated by equivalent three hour rated construction from
adjacent fire areas and that ionization type smoke detectors
were provided within the fire area.
'(i) Control Complex, Elevation 108', Fire Area CC-108-106
Safe Shutdown Fire Zone Train 1 Train 2
Systems / Function Fire Area Raceway / Conduit Raceway / Conduit
Makeup Charging 106 114, 212 *120
Air Handling System 114, 212 *120
Diesel Generator Room
Fans
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Emergency Feedwater 114,~212 *EFE107-1
- NOTE: Raceways to be protected by fire rated enclosures
The inspectors verified that this fire area was separated
from the adjacent fire areas by equivalent three hour rated
construction.
(j) Control Complex, Elevation 124', Fire Area CC-124-111
Safe Shutdown Fire Zone Train 1 Train 2
Systems / Function Fire Area Raceway / Conduit Raceway / Conduit
Air Handling 111 212 *120
System (Diesel
Generator Room Fans) ,
Makeup Charging. 111 212 *120
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Electrical Power 111 212 *120
Distribution
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Seawater *633 634
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Nuclear Service 111 *633 634
Closed Cycle Cooling
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NOTE: * Raceways to be protected by fire rated enclosures
The inspectors performed a walkdown of Fire Area CC-124-111
and verified that it was separated from adjacent fire areas
by equivalent three hour rated construction except that fire
doors C304 and C305 leading to fire areas CC-124-117 and
CC-124-116, respectively have unrated penetrations in their
transoms. This concern is discussed further in para-
graph 5.f. of this report. In addition, the inspectors
reviewed the design detail drawings within MAR Nos. 80-10-
66-01, 80-10-66-02 and 80-10-66-19 and verified that the
gypsum wall assemblies and their associated penetration seals
which separate fire areas CC-124-112,113,114, and 115 from
area CC-124-111 were of. approved three hour rated fire
barrier construction.
During this inspection, the licensee identified control
circuits located in Fire Area CC-124-111 of the control
complex to valves MUV 23, 24, and 25 which are associated
with the reactor coolant makeup charging path were all in
cable raceway No. 623. To protect these valves in accordance
with the requirements of Appendix R, Section III.G., the
licensee is to reroute the circuits for valves MUV 23 and 24
into another raceway and is to provide a cne hour cable tray
fire barrier enclosure for raceway No. 623. This fire
barrier has been added to work package MAR 82-10-19-04 by
Field Change Notice 94. The addition of this fire barrier
will result in these cables meeting the protection and
separation requirements of Appendix R, Section III.G. The
existing fire protection compensatory measures provided for
the additional cable interaction discrepancies within this
area are considered adequate until these modifications are
complete.
Within the areas inspected, no violations or deviations were
identified.
b. Exemptions From Fire Protection Technical Requirements of 10 CFR 50,
Appendix R Sections III.G.2 and III.G.3.
FPC letters of September 24, October 5 and December 11, 1984 requested
12 exemptions from the separation and protection requirements specified
in Appendix R Sections III.G.2 and 3. NRC's letter and SER of July 18,
1985, approved these 12 items, but reclassified them into 6 exemptions
from Appendix R and three deviations from the NRC fire protection
guidelines of Appendix A to Branch Technical Position 9.5-1. The
exemptions were for the following plant areas:
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Fire Area IB-95-200, Intermediate Building redundant emergency
feedwater system pumps and valves.
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Fire Area AB-95-3, Auxiliary Building seawater pump room
- Fire Area AB-95-3, Auxiliary Building makeup pumps
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Fire Area AB-95-3, Auxiliary Building makeup system valves
- Fire Area'IB-119-201, Reactor Building penetration assemblies
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Fire Area CC-164-121, Control Complex HVAC equipment room
The deviations were for the following areas:
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Penetration between Fire Areas AB-95 3 and AB-119-6
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Separation of Auxiliary Building ~ decay heat pits. Fire Areas
AB-75-4 and AB-75-5
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Ceiling and floor penetrations between Fire Areas IB-95-200 and
IB-119-201
The inspectors reviewed the above areas and verified that the modifica-
tion commitments except for the required cable raceway fire barriers
needed to protect and maintain one train of redundant circuits free of
fire damage, had been implemented. The installation of cable raceway '
fire barriers is-scheduled to be completed prior to March 31, 1986.
This schedule was reviewed by the NRC/NRR and approved by letter dated
July 16, 1985. This is identified as Inspector Followup Item
(302/85-30-01),. Verification of Cable Raceway Fire Barrier Installa-
tion, for review during a subsequent NRC inspection.
c. Technical Specifications for Remote Shutdown System
FPC's letter of August 30, 1984, from G. R. Westafer to H. R. Denton,
NRC/NRR requested an amendment to the Technical Specification to revise
the existing Section 3.3.3.5, Remote Shutdown Instrumen.tation, to
include data on the new remote shutdown panel which was installed
during Refueling Cycle V. On July 3, 1985, the NRC issued Amendment
No. 75 to the Crystal River Operating License which restricted this
requested change to only indicated that the previous instrumentation
was relocated to the new remote shutdown panel. Other features of the
new remote shutdown panel such as' transfer switches were not incor-
,
porated into the revised Technical Specifications. Pending issuance of
' a revised Technical . Specification by NRC/NRR covering the features of
the' new remote shutdown panel, this item is identified as Inspector
t Followup Item 302/85-30-02, Technical Specifications Required For New Remote
! -Shutdown Panel.
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d. ' Control Complex Dedicated Cooling System
FPC's evaluation of the installed ventilation system for the control
complex indicated that it was economically impractical and technically
unfeasible _ to protect this system to meet the requirements of
Appendix R, Section III.G.2. Therefore, a dedicated cooling system is
to be provided for the shutdown component areas of the control complex
which require cooling. A description of this system was provided to
the NRC on January' 2,1985, and a schedular exemption was requested by
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letter dated March 1, 1985, to defer completion of this modification to
March 31, 1986. The scheduler exemption was approved by the NRC by
letter dated July 16, 1985; however, the review of the design by
NRC/NRR has not yet been completed. Pending NRC/NRR review and
approval of the system design and completion of the installation by the
licensee, this item is identified as Unresolved Item 302/85-30-03,
Completion of Dedicated HVAC System for Control Complex.
Until the dedicated HVAC system is installed the licensee has estab-
lished compensatory measures consisting of a roving fire watch patrol
in the control complex and a temporary HVAC system for the required
areas of the control complex.
The licensee has located temporary HVAC units in the turbine building
and on the roof above the control complex. These units are wired
temporarily to Motor Control Centers (MCC). The HVAC unit located on
the turbine room floor is powered from MCC-A compartment 13 and will
supply air to the control room through temporary cloth ducts (elephant
trunks) through an open door into the control room. The HVAC units
above the control complex is powered from MCC-3 located in the machine
shop. The unit will ~ supply cooling air into the top of the control
complex stairwell. The licensee advised the inspectors that, during
the recent outage the systems were used for a period of time and
functioned adequately. All circuits and breakers are identified.
e. Fire Watch Program
On. July 29, 1985, FPC initiated a roving fire watch program for all
plant areas which contain Appendix R, Section III.G.2 cable interaction
discrepancies, fire barrier discrepancies, and open or unprotected fire
barrier penetrations. A total of 25 personnel have received general
employee training and special fire protection and prevention training
and are to be assigned fire watch duties as required. Three people per
'
shift are performing fire watch duties. All required plant areas are
visited once each 20 minutes.
!
l The inspectors reviewed the fire watch records for July 29 and 30,
1985, and verified that the fire watch program was being satisfactorily
implemented.
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f. Fire Doors
i
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On October 15-17, 1984, FPC and a fire protection consultant, Pro-
fessional - Loss Control (PLC), conducted a survey at Crystal River
Nuclear Plant to verify the level of adequacy of the installed fire
doors. The inspectors reviewed the results of this survey contained in
PLC Report, dated December 1, 1984 (File Reference No. FP-11-001-08).
L
The report identified and provided recommended corrective actions or l
f justification for deviations from National Fire Protection Association
l (NFPA) Standards for the following fire door features:
1
- (1) Fire door / Frame Assembly Lack Labels
l (2) Signs Attached to Doors
l (3) Protection Plates Attached to Doors
(4) Latch Throw Less than Minimum
(5) Holes in Doors
(6) Penetrations in Transoms
(7) Security Hardware Attached to Fire Doors
The inspectors reviewed the licensee's documented engineering analysis
and justifications for items (1), (2), (3), (5), and (7) noted above.
It appears that the licensee's engineering analysis is adequate for
justifying the above noted deviations from NFPA Standards. Based on
this review, the inspectors concluded that the deviations noted in
items (1), (2), (3), (5), and (7) above do not degrade the overall
performance of the fire door assemblies. The licensee stated that fire
- door latch adjustments for Item (4) will be reverified upon completion
j of the existing refueling out-age activities. The licensee's correc-
tive actions for Item (6) are to be completed under MAR No. 85-02-10-01
dated March 13, 1985. The inspectors' review of this MAR Package
indicates that modifications to fire doors C-213, C-304, and C-305 are
required. Completion of these modifications will be reviewed during
future routine NRC inspections of the plant fire protection program,
and is identified as Inspector Followup Item 302/85-30-04, Review of
Licensee's Completed Fire Door . Modifications as Denoted by MAR
No. 85-02-10-01.
The inspectors verified that compensatory measures for the degraded
fire barrier door assemblies (Fire Doors - C213, C304, and C305)
consisting of a roving fire watch as described in paragraph 5.a.(1)e of
this report had been established for the .affected fire areas / zones.
These measures will remain in effect until the modifications are
complete,
g. Automatic Sprinkler Systems
Automatic wetpipe sprinkler systems have been installed for portions of
the auxiliary, intermediate and control complex buildings. These
systems were provided to meet the fire protection requirements of
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Appendix R, Section III.G. and were designed and installed to conform
to the requirements of NFPA . Standard 13, Sprinkler Systems, for
ordinary hazard occupancy. The inspectors evaluated the systems and
noted that the installed systems appeared to meet NFPA-13. However,
. due to the large quantity of scaffolding and other temporary construc-
tion features in place for the existing plant outage, the inspectors
could not determine if serious obstructions existed between the ceiling
level sprinklers and the floor which might affect the proper water
spray pattern from the systems in the event of fire. This is identi-
fled as Inspector Followup Item 302/84-30-05, Verification of Unob-
structed Sprinkler System Spray Patterns, and.will be reviewed during a
subsequent NRC inspection after all of the temporary construction
features have been removed.
h. Interior Fire Hose System
On July 19, 1985, the licensee identified a number of plant areas
primarily within the control building, which could not be reached by
less than 100 feet of 1 -inch fire hose. Operating license para-
graph 2.C.(9) states that the licensee is required to complete the
modification identified by paragraph 3.1 through 3.31 of the Fire
Protection Safety Evaluation Report (SER) dated July 27, 1979. If
these modifications were not to be completed a report explaining the
circumstances was ~ to be submitted to the NRC. SER paragraph 3.24
required the licensee to verify that all safety-related areas of the
plant including the control complex could be reached with at least one
I effective hose stream utilizing no more than .100 feet of hose.
j. Apparently this verification was not accomplished.
The inndequate -interior fire hose station coverage .was identified by
the licensee and documented by Nonconforming Operational Report (NCOR)
No.85-130. This condition is being evaluated by the licensee to
determine the appropriate corrective action. Also, the licensee stated
that this discrepancy was to be reported to the NRC by a letter type
report. This appears to meet the intent of the license.
The inspectors reviewed fire protection system layout drawings, walked
down the installed fire hose stations 'and verified that a number of
plant areas could not be reached.with an effective hose stream supplied
by less than 100 feet of 1 -inch fire hose. The licensee's corrective
action on this NCOR will be reviewed during future routine NRC inspec-
tions of the plant fire protection program, and is identified as
Inspector Followup Item 302/85-30-06, Review of Licensee's Corrective
Actions for NCOR No.85-130.
i. Damage Control Measures for Cold Shutdown
F
Appendix R, Sections III.G.1.b and III.L.5 require fire protection
features to be provided for structures, system and components important
to safe shutdown and to be capable of limiting fire damage so that
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l
j 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 the capability for 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 repairs.
The licensee has designated an electric motor and set it aside with
proper identification to ' restore a decay heat pump to service if
-required to enable the unit'to be taken to cold shutdown. Additionally
the cable and termination materials to effect repairs or totally
replace the_ power cable are set aside and identified. This material is
controlled and audited in accordance to Procedure MP-192, Post Fire
Cold Shutdown Repair of Decay Heat Closed Cycle Cooling Motors Power
Cable DCP-1A and DCP-18. The inspectors verified that the materials
set aside are adequate for the service intended.
6. Protection of Associated Circuits
The inspection was conducted to verify compliance with associated circuit
provisions of 10 CFR 50 Appendix R, Sections III.G and III.L. The emphasis
was on the following areas of concern:
Common Bus Concern
Spurious Signal Concern
Common Enclosure Concern
a. Common Bus Concern
The common bus concern is found in circuits, either safety or~ nonsafety-
related, where there is a common power source with shutdown equipment
and the power source is not electrically protected from the circuit of
concern by coordinated breakers, fuses or similar devices. .The
inspectors examined the licensee's fuse / breaker coordinations study for
the largest load circuit from Engineered Safeguard Buses 3A and 38.
The time-current characteristic curves for the following circuits were
examined:
- Emergency Feedwater Pump PP-3A (800 HP Motor)
- Diesel Generator Feeder Breaker to 4160V Bus 3A
- Diesel Generator Feeder Breaker-to 4160V Bus 38
- Normal Feeder Breaker to 4160V Bus 3A
- Normal Feeder Breaker to 4160V Bus 3B
- Emergency Nuclear Service Water Pump PP-3B
- Normal Feeder from 4160V Bus 3A to Engineered Safeguard
i Auxiliary 4160/480V Transformer 3A
,
- Feeder Breaker to 480V Bus 3A from Auxiliary 4160/480V
Transformer 3A
- 480V Bus 3A Feeder from 480V Bus 3A to Engineered Safeguard
l Motor Control Center (MCC) 3A-2
- 480V Feeder from 480V Bus 3A to~ Engineered Safeguard MCC 3A-3
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- 480V Feeder from 480V Bus 3B to Engineered Safeguard MCC 3B-3
- 480V Feeder to Control Complex Chiller CHHE-20 from 480V Bus 3B
In addition to the above listed items, the fuse / breaker coordination
was examined for the 480V Engineered Safeguard Bus 3B 250VDC control
voltage from the 250V battery thru Breaker DPDP-1B and 300 Amp fuses to
Panel DPDP-58,_ to 100 Amp fuses thru MTE-17 switch 9 to Breaker 3310
and fused to each compartments.
It' was noted that the curves for the Reactor Building Fan 3B appeared
to approach the same trip value for the motor breaker and the feeder
board breaker. The licensee advised the inspectors that the circuit
contained specially dssignated motor overload elements to prevent the
current flow from approaching the value close to the trip setting of
the board feeder and motor circuit breaker. The inspectors inquired as
to what assurance had been established that the motor overload heater
tripping device would function at the same setpoint over an extended
period of time and not be affected by the thermal cycling that occurs
during normal starting of the fan motor. The licensee advised that
consideration would be given to installing a magnetic trip-only circuit
breaker to replace the motor heater trip devices for improved reli-
ability. This item will be identified as an Inspection Followup Item
302/85-30-07, Examine the Reliability of the Motor Overload Heater
Element Trip Devices as Opposed to a Magnetic Trip Circuit Breaker for
RB Fan No. 3 B.
The inspectors reviewed the isolation methods used fc.' instruments that
furnish indication / control functions to both the main control and the
remote shutdown panels. Where a signal was shared between panels, the
inspectors verified that isolation equipment was installed to insure
that a fault on one indication / control circuit would not disable the
other parallel function. The following instrument loops were examined:
-
Once Through Steam Generator (OTSG) A Level
-
OTSG B Level
-
OTSG A&B Pressure
-
Emergency Feedwater Flow Loop A
-
Emergency Feedwater Flow Loop B
.
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High Pressure Injection Flow A1, A2
-
High Pressure Injection Flow B1, B2 Pressure Level
-
Letdown Flow
-
Decay Heat Inlet /0utlet Temperature
-
Em'ergency Feedwater Control Valve Status Lights for EFV 57, 58, 55
and 56.
Since the signals from the various sensing devices are in the milliamp
range the main concern is to assure that there is adequate isolation-
between devices sharing a common signal. The protection was found
adequate for those circuits reviewed.
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,.-e-s .,cw., ,. - m- -
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b. Spurious Signal Concern
A review of the licensee's spurious signal analysis was conducted to
determine if. the following conditions had been considered:
-
Unwanted motor operations, control signals undesired or not
responsive and false instrument readings such as what occurred at
the 1975 Browns Ferry Fire, that could affect safe shutdown of.the
plant. These could be caused by fire-initiated grounds, shorts or
open circuits.
-
Spurious operation of safety-related or non-safety-related
components that would adversely affect shutdown capability (e.g. ,
~
RHR/RCS Isolation Valves).
The inspectors reviewed the licensee's analysis of the circuits for the
various motor operated valves and solenoid operated valves which are
needed to bring the unit to hot standby or could have an adverse affect
on bringing the unit to a hot standby condition. The logic and methods
used were found adequate. In certain instances valves will be locked
in the proper position to insure that movement would not occur as the
result of . a fire induced spurious signal. The following motor and
solenoid operated valves' circuits were examined to determine where
spurious signals could be developed as the result of shorts or ground
faults:
MUV-73 Borated water to makeup pump 3A
MUV-69 Suction Header Isolation valve between makeup pump 3A
and 3B
MUV-62 Makeup pump 3C Suction Header Isolation valve between
makeup pumps 3C and 3B
MUV-58. Borated water to makeup pump 3C Suction Header
MUV-27 Makeup. Discharge Header' valve to Reactor Loop A Inlet
MSV-55&56 Main Steam to Turbine Driven Emergency Feedwater Pump
ASV5 and 204 Turbine Driven Emergency Feedwater Pump Steam Inlet
Valve.
EFV 1 Hotwell to Turbine Driven Emergency (TDE) FW Pump 3B
EFV 2 Hotwell to Motor Driven Emergency (MDE) FW Pump 3A
EFV 3 Condensate Storage Tank to MDE FW Pump 3A
EFV 4 Condensate Storage Tank to TDE FW Pump 3B
EFV 11 and 14 FW Inlet valves to Once Through Steam Generator 3A
(OTSG).
EFV 32 and 33' Inlet Valves to OTSG 3B
EFV 56 and 58 FW Flow Control valves to OTSG 3A
EFV 55 and 57 FW Flow Control valves to OTSG 3B
The licensee advised the inspectors that at present, valves EFV 1 and 2
would be locked closed and ' valves EFV 3 and 4 would be locked in the
.open position. The licensee's studies indicated that the valve control
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circuits are located such that there is adequate valving provided in
each instance to enable the operators to bring the unit to a hot
standby condition through either manual operation or that the required
equipment is protected by fire barriers.
c. Comon Enclosure Concerns
The common enclosure concern is found when redundant trains are routed
together with a non-safety circuit which crosses from one raceway or
enclosure. to another, and the non-safety circuit is not electrically
protected or fire can . destroy both redundant trains due to inadequate
fire protection.
The fire barriers for protection of cable tray and seismic cable tray
supports had not been completely installed at the time of this inspec-
_
tion. This item is addressed in paragraph 5.b of this report. The
licensee reported that all power and control cables are protected by
breakers and/or fuses sized to preclude any cable overheating that
would . impact on cabling used for safe shutdown. The fuse / breaker
protection for the circuits identified as part of associated circuits
were found adequate.
The inspectors examined the schematics for various items of equipment
which have the control function transferred from the main to the remote
shutdown panel. The circuits reviewed were found to have alternate
fusing as discussed in IE Information Notice No. 85-09, Isolation
Transfer Switches and Post-fire Shutdown Capability, with the exception
of the diesel generator governor control circuit. However, the
licensee had identified this condition and had completed protective
measures to assure that fire -induced shorts or spurious signals would
not affect the operation of the diesel generator governor circuits by
encasing the wiring in fire barrier material. This protection was
inspected in the congested area behind the main control boards and
found adequate.
Because proper fuse size and type are important to the function of
various circuits, the special fuses installed in the various circuits
must be controlled to insure that like replacements are used. The
licensee acknowledged that special fuses had been incorporated into
several circuits and agreed to review the drawings and fuse replacement
lists to insure that all specially fused circuits were identified with
the proper fuse requirements identified. This item will be followed as
part of an existing Inspector Followup Item 50-302/85-09-02, relating
to fusing to AC and DC distribution panels.
7. Alternate Shutdown Capabilities
The inspectors reviewed operating personnel training, shift staffing, and
the licensee's use of normal operating and alternate shutdown procedures to
determine if the requirements of Appendix R, Section III.L were met.
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a. Personnel Training
(1) Procedure AP-880, Fire Protection System Activation, Revision 3
was issued during the Appendix R inspection. The inspectors did
not review implementation or training for AP-880 Fire Protection
System Activation, Revision 3. This item is identified as
Inspector Followup Item 302/85-30-08, Review of the Implementation
and Training for AP-880.
(2) Procedure AP-990, Shutdown from Outside Control Room, Revision 1
had been fully implemented prior to the Appendix R inspection.
The licensee demonstrated adequate training for AP-990 during
selected operator interviews, discussions with training personnel,
and a procedure walkthrough.
b. Shift Staffing
The licensee demonstrated the minimum Technical Specification staff
level was adequate for AP-990 during the procedure walkthrough. The
inspector reviewed AP-880 for staffing requirements for Appendix R
shutdown from within the control room. While the staffing levels
appear adequate, the review will be included in Inspector Followup Item
302/85-30-08. ~
c. Appendix R Shutdown from the Main Control Room
The licensee has not prepared individual procedures for Appendix R
fires that do not require shutdown from outside the main control room.
The licensee uses their normal symptom based procedure' for all
Appendix R fires when the main control room is available. NRC
Region II, Nuclear Operator Licensing Section has previously identified
this matter; therefore, it will not be addressed further in this
report.
d. Appendix R Shutoawn from Outside the Main Control Room
(1) The inspectors reviewed AP-990, Shutdown from Outside Control
Room, and operating procedure, OP-209, Plant Cooldown, to verify
that Appendix R, Section III L requirements listed below have been
incorporated:
-
Achieve and maintain hot standby conditions
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Achieve and maintain subcritical reactivity conditions in the
reactor
-
Provide decay heat removal capabilities
-
Maintain reactor coolant inventory and steam generator
inventory
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Achieve and maintain control shutdown conditions
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Provide direct readings of process variable necessary to
control the above conditions
The inspectors verified that the following instrumentation was
available to the operator at the remote shutdown panel.
(a) Pressurizer Level
(b) . Pressurizer pressure (Hot leg pressure)
(c) Hot Leg temp (exit core thermocouples)
(d) cold leg temp
.(e) S/G pressure
(f) S/G Level
(g) Flux (Source Range)
(h) Level indication
Condensate Storage Tank (CST)
Borated Water Storage Tank (BWST)
(2) AP-990 Walkthrough
The inspectors conducted a walkthrough of- AP-990 to verify that:
-
Communications between various stations are adequate and
operable.
-
Identification plates installed on valves and instrumentation
agree with that called for in the procedure steps.
-
Emergency lighting at stations is adequate.
-
Equipment and valves to be operated can be reached and are
not obstructed.
-
Procedure to.be used are available and contain the latest
revision.
-
Steps of procedures'are clear and can be accomplished.
-
Instrumentation identified in -IEN 84-09 is available to
monitor system process variables or approval received from
NRR to use other means.
! The results of the walkthrough are as follows:
(a) The licensee has agreed to review the storage location of
access keys and hand held ' radios with' their associated
charging stand. They are currently located in the fire area
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which requires the use of the remote shutdown panel and may
be unavailable if a rapid- evacuation of the control room was
required. This is identified as Inspector Followup Item
302/85-30-09, Review of Communications and Area Access for
Control Room Evacuation.
(b) In all cases, the identification plates on valves and
instruments agreed with the nomenclature in the procedure.
(c) Emergency lighting is discussed in report Section 8.
.
(d) Equipment and Valves that require manual operation were
accessible.
(e) The latest revision for all required procedures were avail-
able in a dedicated storage area in the Remote Shutdown Panel
Room.
(f) The licensee demonstrated a thorough knowledge of AP-990 and
the operations procedures such that the remote shutdown panel
could be used successfully to bring the plant to a safe
condition..
8. Compliance With 10 CFR 50, Appendix R, Section III.J., Emergency Lighting
Section III.J requires emergency lighting units with at least 8-hour battery
power supply to be provided in all areas needed for operation of safe.
shutdown equipment and in access and egress routes thereto.
A total of approximately 33 battery powered emergency lighting units have
been provided in plant areas needed for operation of hot shutdown equipment
and components and in the access and egress routes to these areas. These
units are Exide Model B-200 and are rated by the manufacturer to provide in
excess of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> illumination with the number of lights supplied by each
battery. powered unit. The installation and arrangement of the installed
lighting units were reviewed by the inspectors and found to meet Appendix R,
Section III.J; however, battery powered emergency lighting units are not
provided in a number of plant areas in which operators verify shutdown
component operability, valve alignment, etc. and for operator actions which
may be required due to spurious operations. For these plant areas the plant
operators are to use the existing permanently installed emergency lighting
system supplied from the emergency diesel generators and from lighting
supplemented by portable hand lights. The portable hand lights are main-
tained in designated storage cabinets located in the remote shutdown panel
room, auxiliary building nuclear operators office on 95' elevation, and
turbine building operators office on 119'; elevation. By letter dated
July 25, 1985 from G. R. Westafer, FPC to J. F. Stolz, NRC/NRR, FPC provided
an evaluation and justification for the existing emergency lighting system.
Pending NRR rei~vew and approval, this item is identified as Unresolved Item
302/85-30-10, NRR Review and Approval of Appendix R Emergency Lighting.
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The inspectors reviewed procedure SP-807, Mounted and Hand Held Emergency
Battery-Powered Light Units. This procedure requires a monthly inspection
and operability test of each 8-hour battery unit. Procedure PM-110,
Miscellaneous Plant Batteries, is being revised to require the portable hand
lights to be~ inspected and tested weekly for operability. These procedures
should assure that the emergency lighting units will be functional in the
event of an emergency.
Within the areas examined, no violations or deviations were identified.
9. Compliance With 10 CFR 50 Appendix R, Section III.0
The inspectors reviewed the following documentation / drawing file Modifica-
tion Authorizaton Record, MAR 1-03-65-01, of the oil colection system for
the reactor coolant pumps.
a. System Drawings:
Drawing Nos. Title
FD-302-292 Flow Diagram - Reactor Coolant
Pump Motor Lube Oil Collection
NUS Corporation . Details - RCP Motor Oil
drawings 8605-M-007 Collection System
through 8605-M-023
b. Design / Seismic Documents:
-
NUS Corporation Seismic Report No. 4223
-
Installation Procedure No. 1-8605-03
- Seismic Test Program Report No. 45781-1
There is a total of 192 gallons of oil contained in each of four reactor
coolant pumps (RCPs).
Potential oil leakage points for each pump have been provided with a oil
containment system consisting of a lower bearing catch pan, lower bearing
oil level indicator enclosure, oil line enclosure, and oil header and
flange / riser enclosure.
These enclosures are connected to oil collection piping headers which are
designed in accordance with ANSI B31.1 and are supported to withstand a
design basis seismic event.
The oil collection piping headers for each pair of the four reactor coolant
pumps discharge into two separate 400 gallon tanks. Each collection tank is
vented and provided with a vent flame arrestor. Each tank's capacity is
sufficient to hold the full volume of oil from the two connected RCPs.
Within the areas reviewed, no items of noncompliance or deviations were
identified.
E