ML20133A725

Insp Rept 50-302/85-30 on 850729-0802.No Violation or Deviation Noted.Major Areas Inspected:Fire Protection & Licensee Action Re Implementation of Requirements of 10CFR50,App R,Sections Iii.G,Iii.J,Iii.L. & Iii.O

ML20133A725
Person / Time
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: IR 05000302/1985030 ML20133A710
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. .

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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

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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

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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

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(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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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-

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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.

l

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f-

f. Fire Doors

i

l

I

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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16

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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.

_ _ _ - - _ _ _

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17

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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, ...--ei. m .w--.,-e-.v.- --

,.-e-s .,cw., ,. - m- -

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19

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

-

Achieve and maintain subcritical reactivity conditions in the

reactor

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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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23

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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24

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