Difference between revisions of "ML20136J169"

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#REDIRECT [[IR 05000338/1985024]]
 
  +
{{Adams
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| number = ML20136J169
  +
| issue date = 11/04/1985
  +
| title = Special Insp Repts 50-338/85-24 & 50-339/85-24 on 850909-13. Deviation Noted:Installed Fire Stop Penetration Shields Did Not Have Fire Seal Damming Matl in Place
  +
| author name = Conlon T, Hunt M, Miller W, Taylor P, Wiseman G
  +
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
  +
| addressee name =
  +
| addressee affiliation =
  +
| docket = 05000338, 05000339
  +
| license number =
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| contact person =
  +
| document report number = 50-338-85-24, 50-339-85-24, N, NUDOCS 8511250299
  +
| package number = ML20136J148
  +
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
  +
| page count = 37
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}}
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See also: [[see also::IR 05000338/1985024]]
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=Text=
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{{#Wiki_filter:8
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e
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.
  +
km atRg UNITE 3 STATES
  +
o NUCLEAR REGULATORY COMMISSION
  +
,
  +
[ n REGION 11
  +
g j 101 MARICTTA STREET, N.W.
  +
* t ATLANTA, GEORGI A 30323
  +
%...../
  +
Report Nos.: 50-338/85-24 and 50-339/85-24
  +
i Licensee: Virginia Electric and Power Company
  +
Richmond, VA 23261
  +
Docket Nos.: 50-338 and 50-339 License Nos.: NPF-4 and NPF-7
  +
Facility Name: North Anna 1 and 2
  +
Inspection Conduct d: September 9-13, 1985
  +
Inspectors: , g/ , //- /~ df
  +
W. H. Miller (Teab-head sN Date Signed
  +
G.
  +
.
  +
Wisema
  +
b ld ~
  +
}Ol3/lS.S
  +
Date Signed
  +
, - o, Ic) //y'!/f
  +
/
  +
P. A. Taylor / ~ ~ Da'te'Sfoned
  +
llA T
  +
M. V. 'Huiit
  +
'' '
  +
a~
  +
-
  +
ll lll$ T
  +
Dat4 S'ignea
  +
Approved by: fM
  +
T. E. Conlon, Section Chief
  +
/s/hff
  +
D' ate Signed
  +
Plant Systems Section
  +
Engineering Branch
  +
Division of Reactor Safety
  +
SUMMARY
  +
Scope: This special, announced inspection involved 140 inspector-hours on site
  +
in the areas of fire protection and the licensee's actions regarding the imple-
  +
mentation of the requirements of 10 CFR 50, Appendix R, Sections III.G. , III,J. ,
  +
III.L. , and III.O.
  +
- Results: Within the areas inspected, no violations were identified. One appar-
  +
ent deviation was found - Installed Penetration Seals Are Not In Conformance With
  +
App'aoved Tested Configuration, paragraph 5.a.(2).
  +
8511250299 851114
  +
PDR ADOCK 05000338
  +
G FOR
  +
  +
-
  +
.
  +
..
  +
REPORT DETAILS
  +
1. Persons Contacted
  +
Licensee Employees
  +
*E. Harrell, Station Manager
  +
*G. Smith, Assistant Station Manager
  +
*R. Hardwick, Manager, Nuclear Programs and Licensing
  +
*L. Silman, Station Quality Assurance
  +
*G. Flowers, Station Licensing
  +
*G. Mocarski, Station Loss Prevention Supervisor
  +
*R. Anderson, Station Procedures Coordinator
  +
'*W. Stallings, Station Construction
  +
S. Eisenhart, Station Licensing
  +
*R. Champagne, Project Engineer
  +
*R. Carroll, Project Engineer
  +
*L. Warnick, Fire Protection Engineer
  +
*B. Robbins, Fire Protection Engineer
  +
*J. Hegner, Nuclear Operations - Licensing
  +
*H. Carroll, Nuclear Engineer
  +
*J. Graf, Electrical Engineer
  +
M. Phillips, Electrical Engineer
  +
Other Organizations
  +
*W. Merritt, Engineering Planning and Management
  +
*A. Banerjee, Stone and Webster Energy Corporation
  +
*J. Bonner, C&GNA Energy Services,.Inc.
  +
*C. Sinopoli, TENERA Corporation
  +
NRC Resident Inspector
  +
*M. Branch
  +
* Attended exit interview
  +
2. Exit Interview
  +
The inspection scope and findings were summarized on September 13, 1985,
  +
with those persons indicated in paragraph 1 above. The inspectors described
  +
the areas inspected and discussed in detail the inspection findings. No
  +
dissenting comments were received from the licensee.
  +
a. Unresolved Item 338, 339/85-24-01, Review of North Anna Power Station,
  +
Appendix R, Reanalysis and Fire Protection Program, paragraph 5.
  +
b. Unresolved Item 338, 339/85-24-02, NRC/NRR Review of North Anna Power
  +
Station, Appendix R, -Fire Protection Safe Shutdown Methodology,
  +
paragraph 5.a.(1).
  +
a
  +
  +
-.
  +
>
  +
.
  +
2
  +
c. Unresolved Item 338, 339/85-24-03, Review of Seismic Gap Fire Barrier
  +
Penetration Seals, paragraph 5.a.(1).
  +
.
  +
d. Deviation Item 338, 339/85-24-04, Installed Penetration Seals Are Not
  +
In Conformance With Approved Tested Configuration, paragraph 5.a.(2).
  +
e. Unresolved Item (338, 339/85-24-05), Re-entry Into Fire Areas to
  +
Perform Appendix R Hot Standby Shutdown Functions, para' graph 5.a.(5).
  +
f. Unresolved Item (338, 339/85-24-06), Submittal and Review of an Exemp-
  +
tion Request from Providing a Suppression and Detection System in the
  +
Area of Valves M0V.11158 and MOV 2115B in Fire Area 11, paragraph
  +
5.a.(5).
  +
g. Inspector Followup _ Item (338, 339/85-24-07), Verification of Fire
  +
Resistance Rating of Fire Dampers .Between Switchgtar Rooms, paragraph
  +
5.b.(4).
  +
h. Inspector Followup Item (338, 339/85-24-08), NRC Review of Completed
  +
Appendix R Fire Protection Modifications, paragraph 5.b.(11).
  +
i. Unresolved Item (338, 339/85-24-09), Review and Resolution of
  +
Appendix R. Exemption Requests, paragraph 5.c.
  +
J. Inspector Followup Item (338, 339/85-24-10), Appendix R, Plant Shutdown
  +
Components Are Not Included in the Technical Specifications,
  +
. paragraph 5.d.
  +
k. Unresolved Item . (338, 339/85-24-11), Licensee's Re-evaluation of
  +
Conduit Penetration of Fire Barriers to Determine if Penetrations Are
  +
Properly Sealed, paragraph 5.e.(1)(c).
  +
,
  +
1. Unresolved Item (338, 339/85-24-12), Substandard Fire Barrier Penetra-
  +
tion Seals, paragraph 5.e.(2)(a).
  +
m. Inspector Followup Item (338, 339/85-24-13), Sensitivity Calibration Is
  +
Not Included As Part of Smoke Detector Maintenance Program, paragraph
  +
5.e.(3)(a).
  +
n. Inspector Followup Item (338, 339/85-24-14), Licensee to Revise Pre-
  +
Fire Plans to Address Inadvertent Application of Suppression Agents to
  +
Redundant Equipment, paragraph 5.e.(3)(b).
  +
o. Unresolved Item (338, 339/85-24-15), Direct Reading of RWST Level Not
  +
Available Outside the Control Room, paragraph 7.c.(1).
  +
The licensee did not identify as proprietary any of the materials provided
  +
to or reviewed by the inspectors during this inspection.
  +
:
  +
, ., _. _ - _
  +
  +
-
  +
.
  +
3
  +
3. Licensee Action on Previous Enforcement Matters
  +
a. '(Closed) Unresolved Item (338, 339/85-15-01), Battery Maintenance for
  +
Remote Shutdown Instrumentation' Monitoring Panel in Fuel Building. The
  +
batteries for the remote instrumentation panel are not required. Power
  +
for this panel is supplied from an emergency bus of each unit and these
  +
batteries are to be removed. This item is closed.
  +
b. The following items were reviewed as part of this Appendix R inspection
  +
and are considered resolved except as noted in paragraph 5:
  +
(1) (Closed) Unresolved Item (338, 339/83-25-01), Re-evaluation of
  +
Fire Protection Requirements for Charging Pumps.
  +
(2) (Closed) . Unresolved Item (338, 339/83-25-02), Re evaluation of
  +
Fire Protection Requirements for Component Cooling Pumps.
  +
(3) (Closed) Unresolved Item (338, 339/83-25-03), Re-evaluation of
  +
Fire Protection Requirements for Reactor Building.
  +
(4) (Closed) Unresolved Item (338, 339/82-25-04), Repair Cable for RHR
  +
Pumps Not Available.
  +
c. (Closed) Unresolved Item (338/80-42-01 and 339/80-39-01), Fire Hose Not
  +
Provided at Each Hose Connection Within Reactor' Building. The Techni-
  +
cal Specifications have been revised to indicate that the hose connec-
  +
tions within containment are not equipped with fire hose. Fire hose
  +
and miscellaneous fire brigade equipment are stored in cabinets adja-
  +
cent to the-personnel hatch for each containment. This item is closed.
  +
d. (Closed) Unresolved Item (338/80-42-04 and 339/80-42-04), Substandard
  +
Fire / Smoke Detector Installation. The licensee has either upgraded the
  +
fire detection system to meet the requirements of NFPP-72E, Automatic
  +
Fire Detectors, or provided an engineering justification to indicate
  +
that the installed systems meet the intent of NFPP-72E or the NRC
  +
guidelinos. This item is closed.
  +
4. Unresolved Items
  +
Unresolved items are matters about which more information is required to
  +
determine whether they are acceptable or may involvo violations or devia-
  +
tions. New unresolved items identified during this inspection are discussed
  +
in paragraphs 5.a, 5.b, 5.c, 5.e, and 7.c.
  +
5. Compliance with 10 CFR, Appendix'R, Sections III.G. and III.L.
  +
By letter dated June 22, 1982, Virginia Power provided their original
  +
response to Appendix R for the North Anna facility. Additional information
  +
was. submitted on September 30, 1982, and on this basis, the NRC issued a
  +
Safety Evaluation Report (SER) dated November 18, 1982, for North Anna.
  +
  +
- .
  +
4
  +
Subsequent to the SER, the NRC issued Generic Lettar 83-33. In response to
  +
this Generic Letter, Virginia Power commenced an Appendix R reanalysis. For
  +
the North Anna Power Station this reanalysis consists of seven chapters
  +
contained in two volumes. Volume I was submitted to NRC/NRR by letter dated -
  +
March 8,1985 (Serial No. 85-114). Volume II was submitted by letters dated
  +
May 1, 1984 (Serial No. 231) and October 31, 1984 (Serial No. 2318).
  +
Generic Letters 83-33 and Draft 85-01 and other interpretive documents were
  +
used as guidance for their reanalysis effort. At the time of the inspec-
  +
tion, the licensee's revised fire hazards and safe shutdown reanalysis had
  +
not been reviewed or approved by NRR.
  +
Pending review and aeproval of the licensee's revised fire hazard and safe
  +
shutdown reanalysis by NRC/NRR, this item is identified as Unresolved Item
  +
(338,339/85-24-01), Review of North Anna Power Station, Appendix R, Re-
  +
analysis and Fire Protection Program.
  +
Therefore, an inspection of the licensee's reanalysis and revised alterna-
  +
tive shutdown methodology was conducted to determine if the protection
  +
features provided for structures, systems, and components important to safe
  +
shutdown at North Anna Units 1 and 2 were in compliance with 10 CFR 50,
  +
Appendix R, Sections III.G. and III.L. The scope of this inspection deter-
  +
mined if the fire protection features provided for identified essential safe
  +
shutdcwn 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.
  +
Safe Shutdown Capabilities
  +
In order to ensure safe shutdown capabilities, where cables or equipment of
  +
redundant trains of systems necessary to achieve and maintain hot standby
  +
conditions are located within the same fire area outside the primary contain-
  +
ment, 10 CFR 50, Appendix R, Section III.G.2 requires that one train of hot
  +
standby systems be maintained free of fire damage by one of the following
  +
means:
  +
Separation of cables and equipment and associated nonsafety circuits of
  +
redundant trains by a fire barrier having a three hour rating;
  +
Separation of cables and equipment and associated nonsafety circuits of
  +
reduadant trains by a horizontal distance of more than 20 feet with no
  +
intervening combustibles or fire hazards. In addition, fire detectors
  +
and an automatic fire suppression system shall be installed in the fire
  +
area;
  +
Enclosure of cables and equipment and associated nonsafety circuits
  +
of one redundant train in a fire barrier having a one hour rating. In
  +
addition, fire detection and an automatic fire suppression system
  +
shall be installed in the fire area; or,
  +
Where the protection of systems whose function is required for hot
  +
standby does not satisfy the above requirements or Section III.G.2,
  +
alternative or dedicated shutdown capabilities independent of cables,
  +
  +
- .
  +
5
  +
systems, or components in the area, room, or zone under consideration
  +
shall be provided in accordance with 10 CFR 50, Appendix R, Section
  +
III.G.3 and III.L. In addition, Section III.G.3 requires that fire
  +
detection and fixed suppression be installed in the area, room, or zone
  +
under consideration.
  +
On the basis of the above ' Appendix R criteria, the inspectors made an
  +
inspection of cabling and components associated with the Chemical Volume and
  +
Control- System, Emergency Electrical Power Supply Systems, Auxiliary Feed-
  +
water System, Main Steam System, Service Water System, Reactor . Coolant
  +
System, Support Ventilation Systems, Plant Process Monitoring Instrumenta-
  +
tions, and. Emergency Lighting / Communications Systems.
  +
a. Separation / Fire Protection for Safe Shutdown Systems and Components
  +
Based on the licensee's Appendix R Reevaluation, Virginia Power has
  +
identified 47 fire areas at North Anna Power Station. These fire areas
  +
are listed in Chapter 2, Table 2 of the Fire Protection Reevaluation
  +
Report and illustrated in drawings 11715-FAR 200 through 214.
  +
Within the above areas, the licensee has performed a cable separation
  +
analysis for identified essential safe shutdown systems and components
  +
required to achieve hot standby and cold shutdown. The licensee has
  +
. identified 27 fire areas which contain safe shutdown equipment and/or
  +
cables. .The results of the licensee's cable separation analysis
  +
indicate that a fire in 12. plant areas could potentially cause damage
  +
.to both trains of safe shutdown functions thus requiring alternative
  +
shutdown capability. Alternative shutdown is required in the following
  +
12 fire areas:
  +
-
  +
Fire Area 2, Control Room
  +
-
  +
Fire Area 3-1, Unit 1 Cable Vault and Tunnel
  +
-
  +
Fire Area 3-2, Unit 2 Cable Vault and Tunnel
  +
-
  +
Fire Area 6-1, Unit 1 Emergency Switchgear Room
  +
-
  +
Fire Area 6-2, Unit 2 Emergency Switchgear Room
  +
-
  +
Fire Area 11, Auxiliary, Fuel, and Decontamination Buildings
  +
-
  +
Fire Area 14B-1, Unit 1 Motor-Driven Auxiliary Feedwater Pump Room
  +
-
  +
Fire Area 14B-2, Unit 2 Motor-Driven Auxiliary Feedwater Pump Room
  +
-
  +
Fire Area 15-1, Unit 1 Quench Spray Pump House and Safeguard Area
  +
-
  +
Fire Area 15-2, Unit 2 Quench Spray Pump House and Safeguard Area
  +
-
  +
Fire Area 17-1, Unit 1 Main Steam Valve House
  +
--
  +
  +
-
  +
.
  +
6
  +
-
  +
Fire Area 17-2, Unit 2 Main Steam Valve House
  +
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 and III.G.3.
  +
Included in the review was an evaluation of the acceptability of the
  +
barrier or onclosure construction configuration as a fire rated barrier
  +
as used in the plant to separate fire areas. 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, the cable routings for redundant safe
  +
shutdown components / functions, alte native shutdown capabilities, and
  +
the fire protection features afforded these areas were inspected:
  +
(1) Fire Areas 3-1 and 3-2, Units 1 and 2 Cable Vault and Tunnel,
  +
Elevation
  +
Safe Shutdown Train A Train B
  +
System / Function Fire Area / Zone Raceway / Conduit Raceway / Conduit
  +
Chemical Volume and
  +
Control / Makeup Charging
  +
Charging Pumps
  +
1-CH-P-01A 3-1 1AH9140A
  +
1-CH-P-01B 3-1 ITC058P
  +
1TC057P
  +
2-CH-P-01A 3-2 2AH9140A
  +
2-CH-P-01B 3-2 2AH914PA
  +
Emergency Power / 3-1 IWC002P01 1CK0780B
  +
Diesel Generator ICK036PA 1CK955PF
  +
Fuel Oil Transfer
  +
Pumps 3-2 2CK946PB1 2CK946PF
  +
A fire in either of the Units' Cable Vault, and Tunnel area could
  +
result in the loss of power and control cables for both trains of
  +
the Chemical Volume and Control System (CVCS) Charging Pumps, the
  +
charging pump suction valves from the Refueling Water Storage Tank
  +
(RWST).and the emergency diesel generator fuel oil transfer pumps
  +
for that respective affected unit. The licensee stated that the
  +
CVCS has been designed with a manually operated cross connection,
  +
_-
  +
  +
.
  +
7
  +
between the Unit 1 and Unit 2 charging pumps discharge manifolds.
  +
This manual crosstie enables either set of pumps to feed both
  +
units in case of a fire which may affect both trains of one unit
  +
in the affected fire area. Likewise, the licensee stated that for
  +
a fire .in Fire Area 3-1 (causing loss of all Unit 1 emergency
  +
diesel- generators), the emergency diesel generators 2H and 2J
  +
would be available to supply necessary power to the Unit 2 Emer-
  +
gency Switchgear Room, thus providing power to the alternative
  +
shutdown systems required to shut down Unit 1.
  +
This alternate shutdown scheme for fire utilizing system crossties
  +
and the unaffected units emergency power systems is included in
  +
Virginia Power's revised Appendix R reanalysis submitted to
  +
NRC/NRR by letter dated March 8, 1985. Pending NRC/NRR review of
  +
this shutdown methodology,. this is identified as Unresolved Item
  +
(338,339/85-24-02), NRC/NRR Review of North Anna Power Station,
  +
Appendix R, Fire Protection Safe Shutdown Methodology.
  +
The inspectors performed a walkdown of Fire Areas 3-1 and 3-2 and
  +
verified that they were separated from adjacent fire areas by
  +
equivalent three hour rated construction except that the fire
  +
barrier walls between the Cable Vault and Tunnel areas and the
  +
Auxiliary Building, Fire Area 11, at Elevation 259'-6" contain a
  +
l space gap (to allow for seismic event movement) where it abuts the
  +
containment. The filler material in the seismic gap appeared to
  +
be combustible styrofoam. The vertical gap space is covered by an
  +
angle iron attached to the wall. This configuration is typical
  +
throughout the plant and may not provide the required three hour
  +
fire tested barrier rating. The licensee provided an evaluation
  +
addressing this item and identified the fire areas where these
  +
configurations are located. This item is identified as Unresolved
  +
Item (338, 339/85-24-03), Review of Seismic Gap Fire Barrier
  +
Penetration Seals; pending NRR review of the revised North Anna
  +
fire hazards analysis and evaluations.
  +
In addition, the inspectors noted that the fire door frame assem-
  +
blies to Doors 554-5 and 554-9 from the Unit 1 and Unit 2 cable
  +
tunnels to the respective Emergency Switchgear Rooms (Fire Areas
  +
6-1 and 6-2) were not labeled for fire door use. This item is the
  +
subject of Exemption Request #16. Refer to paragraph No. 5.b. for
  +
a discussion of this item.
  +
The inspectors verified that early warning ionization type fire
  +
detectors were provided in the area of Fire Areas 3-1 and 3-2.
  +
Also, heat detectors are provided which actuate a total flooding
  +
low pressure CO 2 system for the areas. In addition, the inspec-
  +
tors verified that the sprinkler systems protecting these fire
  +
areas provided full area coverage. The sprinkler systems protect-
  +
ing these areas are a manual open head sprinkler system for
  +
protection of cable trays in the high ceiling upper levels of the
  +
rooms and a manual closed head sprinkler system in the lower area
  +
  +
c
  +
.
  +
.
  +
8
  +
to provide floor coverage. These systems are provided as manual
  +
backup systems to the primary automatic carbon dioxide suppression
  +
system.
  +
(2) Fire Areas 6-1 and 6-2, Emergency Switchgear Rooms and Instrumenta-
  +
tion Rack Rooms.
  +
Safe Shutdown Train A Train B
  +
. System / Function Fire Area / Zone Raceway / Conduit Raceway / Conduit
  +
: Chemical Volume and
  +
Control System /
  +
Charging Pumps
  +
1-CH-P-01A 6-1 1AH9140A
  +
ITC0330
  +
1-CH-P-018 6-1 1AH914PB
  +
ITC034P
  +
-1-CH-P-01C 6-1 ICC0020D
  +
2-CH-P-01B 6-2 2AH9140A
  +
2TCC0330
  +
'2TC0190
  +
2-CH-P-01B 2AH914PA
  +
2TC027P
  +
2CC021PG
  +
2-CH-P-01C 2AH947GA
  +
Auxiliary Feedwater
  +
-System / Motor-Driven
  +
Auxiliary Feeowater
  +
Pumps
  +
1-FW-P-03A 6-1 1CH0030F
  +
ICC03308
  +
1-FW-P-038 6-1 1CC020PH
  +
ICH946PA
  +
2-FW-P-03A 6-2 2CH0020E
  +
2CC0290E
  +
2-FW-P-038 6-2 2CH947PC
  +
2CC025PD
  +
  +
.. .
  +
9
  +
Emergency Power System /
  +
_
  +
(Diesel Generator Fuel
  +
Oil Transfer Pumps)
  +
1-EG-P-1HA 6-2 1CK9460E
  +
'
  +
1-EG-P-1JA 6-1 1CK946PB
  +
1-EG-P-2HA 6-2 2CK946001
  +
1-EG-P-2JA 6-2 2CK011PB'
  +
2TK011P
  +
2TK009P
  +
2-EG-P-2HB 6-2 2DK0020A1
  +
2-EG-P-2JB 6-2 2TK010P
  +
2CK010PG
  +
Service Water System /
  +
Service Water Pumps
  +
1-SW-P-01A 6-1 1DH0020B1
  +
1CC0230C
  +
1-SW-P-01A 6-1 IDH002PB1
  +
ITC035P
  +
-2-SW-P-01A 6-l' 2CC0300H
  +
2-SW-P-018 6-1 2CC029PE
  +
Auxiliary Service
  +
Water Pumps
  +
1-SW-P-04 6-1 1CH94600
  +
1TC0340
  +
2-SW-P-04 6-2 2CHC94700
  +
2TC0270
  +
2TC0260
  +
A fire in either Fire Area 6-1 or 6-2 can result in the loss of
  +
cabling .and functions affecting the CVCS charging pumps, motor
  +
driven auxiliary feedwater pumps, and the emergency diesel genera-
  +
tor power system for the affected Unit. The licensee has provided
  +
. alternative shutdown methodology as described in previous para-
  +
graph 5.a.(1) for the CVCS charging pumps and the diesel
  +
generators.
  +
  +
I
  +
.
  +
l
  +
.
  +
l
  +
_
  +
10
  +
A 100% capacity turbine-driven auxiliary feedwater pump is avail-
  +
able on loss of the two motor driven pumps. The inspectors
  +
verified that the turbine-driven auxiliary feedwater pumps located
  +
in Fire Areas 14A-1 and 14A-2 are independent of the fire areas of
  +
concern (Fire Areas 6-1 and 6-2). Manual throttling of the
  +
turbine-driven auxiliary feedwater pump discharge flow valve is
  +
required.
  +
The inspectors reviewed the fire area boundaries provided to
  +
separate Fire Areas 6-1 and 6-2 from each other and other adjacent
  +
plant areas such as Fire Area 8 (Turbine Building) and Fire Areas
  +
3-1 and 3-2 (Cable Vault and Tunnel). Section 8.3 of the North
  +
Anna Power Station, FSAR states that, "Dow Corning Q3-6548 RTV
  +
Silicone Foam is used for the fire stop seals. The foam is used
  +
in conjunction with Johns Manville Cerafiber and Cerablanket or its
  +
equal as the damming material and is left in place."
  +
During their walkdown, the inspectors noted that the conduit fire
  +
stop penetration seals identified as ICK0790I, ICK0790D, and
  +
ICK050PF, located in the wall that separates Fire Area 6-1 from
  +
Fire Area 8 did not have the fire seal damming materials in place.
  +
In addition, the inspectors reviewed the licensee's Silicone Foam
  +
penetration sealing specification No. NAS-1014 dated October 15,
  +
1980. .Section 1, paragraph 9, line 6.36, states that the Cera-
  +
fiber or Cerablanket material is not to be removed as it is part
  +
of the permanent seal. This configuration does not conform to the
  +
FSAR commitments to the NRC. This discrepancy was also noted in
  +
other plant fire areas and is identified as Deviation Item (338,
  +
339/85-24-04), Installed Penetration ~ Seals Are Not In Conformance
  +
With Approved Tested Configurations. During the inspection, the
  +
licensee reviewed the penetration seals in question and determined
  +
that a minimum nine inch depth of RTV Silicone Foam was provided
  +
in each seal. Based on this depth of foam, the seals can be
  +
considered acceptable for protection for a limited fire condition.
  +
Although the seal damming material was not in place, the seals are
  +
not considered to be in a fully degraded condition, therefore, a
  +
limiting condition for operation (LCO) was not issued at the time.
  +
The licensee is to investigate this further and will take the
  +
appropriate corrective action.
  +
During the fire barrier walkdown for Fire Area 6-2, it was also
  +
noted that no fire damper was installed in the main ventilation
  +
duct which is routed through the fire area barrier wall from the
  +
Unit 2 chiller room (Fire Area 8) to the Unit 2 Emergency Switch-
  +
gear Room (Fire Area 6-2). The licensee stated that in lieu of a
  +
barrier fire damper, the ventilation ductwork was enclosed in a
  +
three hour fire barrier. The inspectors reviewed engineering
  +
Design Coordin. . ion Report Nos. CED 10070-R-2 and 10070-T-2 for
  +
the installation. The licensee's reports indicate that the fire
  +
.- .-- .
  +
-
  +
.-
  +
  +
. .
  +
11
  +
barrier configuration for the duct enclosure is similar to Under-
  +
writers Laboratories tested Design No. X306 for protection of
  +
steel column assembly. The licensee stated that this item is
  +
discussed in the North Anna SER dated February 1979 and is also
  +
the subject of Exemption Request No.13. Refer to paragraph 5.b.
  +
of this report for a discussion of this item.
  +
In addition, the inspectors verified that early warning smoke
  +
detectors and fixed manual Halon 1301 fire suppression system
  +
were provided in Fire Areas 6-1 and 6-2. The inspectors reviewed
  +
the licensee's design basis for the Halon suppression system, the
  +
fire detector locations and the licensee's evaluation (No.11) and
  +
.
  +
justification for .the smoke detector locations in these area
  +
which do not meet the specific requirements of NFPA 72E as related
  +
to detector placement in ceiling structural beam pc kets. Howev-
  +
er, based on the review of the licensee's design basis, detector
  +
evaluations, and our walkdown of the fire areas, the fire detec-
  +
tion and suppression systems provided for these areas appear
  +
adequate.
  +
(3) Fire Areas 9A-1, 9B-1, 9A-2, 9B-2, Emergency Diesel Generator
  +
Rooms
  +
Safe Shutdown Train A Train B
  +
System / Function Fire Area / Zone Raceway / Conduit Raceway / Conduit
  +
Emergency Electrical
  +
Distribution System /
  +
Emergency Diesel
  +
Generators-(E.D.G.)
  +
EDG-1H 9A-1 ITH0040
  +
1DH001081
  +
10H0010A1
  +
EDG-1J 9B-1 ITH002P
  +
IDH001PB3
  +
IDH001PA3
  +
EDG-2H 9A-2 2TH0010
  +
2DH0010B2
  +
2DH0010A2
  +
EDG-2J 9B-2 2EGPCPH001
  +
2DH001PB4
  +
2DH001PAA
  +
Emergency Diesel
  +
Generator Fuel Oil
  +
Transfer Pumps
  +
  +
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
  +
.
  +
.
  +
12
  +
9A-1 ITC0720
  +
1CC9020B
  +
1CC9020C
  +
98-1 1CC903PD
  +
ITC038P
  +
ICC933PE
  +
The inspectors performed a walkdown and verified that Fire Areas
  +
9A-1, 9B-1, 9A-2, and 9B-2 were separated by equivalent three hour
  +
rated construction from each other and from adjacent Fire Area 8
  +
except that the fire doors from the four emergency diesel genera-
  +
tor rooms to the turbine building are not of labeled construction.
  +
These doors are the subject of exception request No.16. See
  +
paragraph No. 5 b. for a discussion of this item.
  +
(4) Fire Areas 10A and 108, Emergency Diesel Generator Fuel Oil Pump
  +
Rooms
  +
Safe Shutdown Train A Train B
  +
System / Function Fire Area / Zone Raceway / Conduit Raceway / Conduit
  +
Emergency Power System /
  +
Emergency Diesel Generator
  +
Fuel Oil Transfer Pumps
  +
1-EG-P-1HA 10A 1DK001083
  +
1-EG-P-1JA 10K003PB3
  +
2-EG-P-2HA 2DK0020B3
  +
2-EG-P-2JB 2DK004PB3
  +
1-EG-P-1HB 10B 10K0010A3
  +
1-EG-P-1JB 1DK003PA3
  +
1-EG-P-2HB 20K0020A3
  +
1-EG-P-2JB 2DK004PB3
  +
A fire in either Fire Area 10A or 10B can result in loss of
  +
cabling or equipment for both trains of a single set of emergency
  +
diesel generator fuel oil transfer pumps. However, a redundant
  +
alternate set of pumps and power cabling are provided in the other
  +
unaffected fire area, thus providing the required emergency diesel l
  +
generator power function for operation or shutdown of the affected '
  +
unit.
  +
The inspectors performed a walkdown of Fire Areas 10A and 10B and
  +
verified that they were separated from each other by equivalent
  +
three hour rated construction. The inspectors verified that early
  +
l
  +
  +
- a
  +
. .
  +
13
  +
warning ' heat and smoke . detection and a full area automatic high
  +
pressure C0 2 fire suppression system were provided in each of the
  +
fire areas.
  +
(5) Fire Area 11, Auxiliary, Fuel, and Decontamination Buildings
  +
Safe Shutdown Train A Train B
  +
System / Function Fire Area Raceway / Conduit Raceway / Conduit
  +
Chemical Volume 1
  +
and Control System /
  +
Charging Pumps
  +
1-CH-P-01A 11 1AH9140A
  +
1-CH-P-01B 1AH001PA
  +
2-CH-P-01A 11 2AH9140A
  +
2-CH-P-04.. 2AH914PA
  +
Train C
  +
Swingrumps Raceway / Conduit
  +
1-CH-P-01C 11
  +
1AH914GA
  +
2-CH-P-01C 2AH947GA
  +
(Suction Valves
  +
e,o RWST)
  +
H0V-1115B 11 1CK026PK
  +
1TK026P
  +
MOV-11150 11 1TK0680
  +
MOV-2115B 2CK028PU
  +
2CK028PU
  +
2TK028P
  +
'
  +
Component Coolirg
  +
Water System For
  +
Cold Shutdown /
  +
Component Cooling
  +
Water Pumps
  +
1-CC-P-01A 11 1AH9140B
  +
1-CC-P-01B 1AH914PB
  +
2-CC-P-01A 2AH9140B
  +
2-CC-P-01B 2AH914PB
  +
Fire Area 11 consists of the Auxiliary, Fuel, and Decontamination
  +
Buildings which are common for both Units 1 and 2.
  +
_ _ - _ - _ _ _ - _ _ _ _ _ _ _ _ _
  +
  +
.
  +
,
  +
I
  +
'
  +
14
  +
The Fuel Building portion of Fire Area 11 contains the Auxiliary
  +
Monitoring Panel which is to be utilized given fire in the Control
  +
Room, Emergency Switchgear Rooms, or Cable Vault / Tunnel. No safe
  +
-shutdown equipment is located in the Decontamination Building
  +
portion of Fire Area 11.
  +
The Auxiliary Building portion of Fire Area 11 contains six
  +
charging pumps, four CCW pumps, and the associated cabling and
  +
valves required for safe shutdown.
  +
The Auxiliary Building is a four story structure consisting of the
  +
244 ft. 6 in., 259 ft. 6 in., 274 ft. O in., and 291 ft. 10 in,
  +
elevations. The CCW and charging pumps are located on the 244 ft.
  +
6.in. elevation, with the CCW pumps in the main open floor area of
  +
this elevation. Two charging pumps and two CCW pumps are required
  +
to bring both units to cold shutdown (one charging hot standby and
  +
one CCW pump (cold shutdown) per unit). The charging and CCW pump
  +
cabling is located on the 244 ft. 6 in. and 259 ft. 6 in, eleva-
  +
tions of the Auxiliary Building.
  +
An inspection was made of the charging pumps and CCW pump areas to
  +
determine what separation and protection was provided the systems
  +
and components as described in the Fire Hazards and Safe Shutdown
  +
Analysis.
  +
The charging pumps are located side by side in separate cubicles
  +
in the 244 ft. 6 in. elevation with access availabie through an
  +
open hatch from the 259 ft. 6 in, elevation.
  +
The power feeds for the charging pumps rise out of their respec-
  +
tive cubicles and run in a northerly direction on the 259 ft.
  +
6 in. elevation prior to exiting Fire Area 11 through the north
  +
wall.
  +
The charging pump power cables are arranged such that tL9 three
  +
feeds for Unit 1 pumps rise up and run north on the easte'n side
  +
of the Auxiliary Building while the remaining Unit 2 power cables
  +
rise up and run north on the western side of the building. Once
  +
the power cables exit the pump cubicles, the three Unit 2 (Train A
  +
and B and swing) power cables approach within about one foot of
  +
each other near the Unit 2B (Train B) charging pump access open-
  +
ing. On the Unit I side, the pump IC (swing) power cable was to
  +
within about one foot of the IB (Train B) pump cable. These two
  +
cables run east until they near the pump 1A (Train A) power cable.
  +
In the vicinity of the access hatches, the Unit 2 and Unit 1
  +
cables approach to less than 20 foot separation.
  +
The licensee has provided a TSI Inc. one hour cable enclosure wrap
  +
for the Unit 1C (swing) charging pump power cable that extends
  +
from the exit point of the pump cubicle until it achieves approxi-
  +
mately 22 foot horizontal separation distance from the closest
  +
  +
.
  +
'
  +
. .
  +
15
  +
Unit 2A (Train A) charging pump power cable. Although this
  +
barrier application was not continuous throughout the fire area,
  +
the barrier included fireproofing of the load-bearing structural
  +
steel supports which support the cable fire bar.rier enclosure
  +
assembly. The completed fire barrier enclosure appeared to. be
  +
installed in accordance with the design limitations imposed on the
  +
TSI Thermolag Fire tested configurations.
  +
A fire in this area could result in the loss of the CVCS charging
  +
pumps and the suction. valves to the Refueling Water Storage Tanks
  +
(RWST), MOV-1115B and MOV-21158. The licensee proposes to use the
  +
manual cross-connect of the unaffected unit charging pumps. In
  +
the event of a fire tnat disables all charging pumps of one unit,
  +
the two normally closed cross-connect valves (1-CH-550 and
  +
2-CH-408) and alternate RWST suction valves (MOV-11158 and
  +
MOV-21158) are manually opened by an operator who re-enters the
  +
fire area within less than a one hour time frame. This alterna-
  +
tive shutdown capability is not fully physically or electrically
  +
independent of the fire area of concern.
  +
The licensee nas provided an engineering evaluation, for justifi-
  +
cation of these operator actions. Pending NRC/NRR review, this is
  +
identified as Unresolved Item (338,339/85-24-05), Re-entry Into
  +
Fire Areas to Perform Appendix R Hot Standby Shutdown Functions.
  +
The charging pump suction valves (MOV-11158 and MOV-21158), in the
  +
lines from the refueling water storage tank, may be lost due to a
  +
fire outside the charging pump cubicles. These valves are normal-
  +
ly closed and would be required to be open in order to perform a
  +
cooldown. However, the opposite unit's charging pumps are used
  +
for both units since they are cross-connected on the discharge
  +
side. The cabling for the Unit I valve (MOV-1115B) and the
  +
alternate Unit 2 valve (MOV-21158) is routed in opposite sides of
  +
the Auxiliary Building and is separated by greater than 20 feet.
  +
Both the valves and their cabling are located in areas of concen-
  +
trations of cabling on elevations 244'-6" and 259'-6" of the
  +
Auxiliary Building. Both valves and their cabling appear to be
  +
located within 20 feet of major aisles on each elevation. An
  +
automatic suppression and detection system is not provided in the
  +
fire area, room, or zone under consideration for these alternative
  +
shutdown cabling and components as required by 10 CFR 50,
  +
Appendix R, Section III.G.3. The licensee stated that a revised
  +
Exemption Request No. I would be submitted which will include a
  +
III.G.3 exemption from a suppression and detection system in these
  +
areas. Pending the submittal and review of the revised exemption
  +
request, this is identified as Unresolved Item, (338,
  +
339/85-24-06), Submittal and Review of an Exemption Request from
  +
Providing a Suppression and Detection System in the Area of Valves
  +
MOV-11158 and MOV-2115B in Fire Area 11.
  +
  +
. .
  +
16
  +
The inspectors reviewed the automatic sprinkler systems installa-
  +
tion on portions of 244'-6" and 259'-6" elevations of Fire Area 11
  +
around the charging pumps cables. These systems appear to provide
  +
adequate coverage except as noted above and appear to be free of
  +
obstructions.
  +
(6) Fire Area 12, Service Water Pump House
  +
Safe Shutdown Fire Train A Train B
  +
[ stem / Function Area / Zone Raceway / Conduit Raceway / Conduit
  +
Service Water
  +
System / Service Water
  +
Pumps
  +
1-SW-P-01A 12 10H0020B5
  +
1-SW-P-01B 12 1DH002PB5
  +
2-SW-P-01A 12 20H0020A5
  +
2-SW-P-01B 12 2DH003PA5
  +
A fire in this area could result in the loss of both trains of the
  +
Service Water Pumps. The service water system is common to both
  +
units. For a fire in this area, the Auxiliary Service Water Pumps
  +
located 'in a separate fire area (Fire Area 13) located in the
  +
intake -structure would be used to supply service water for safe
  +
shutdown. The inspectors verified that the alternative auxiliary
  +
service water pumps were both physically and electrically indepen-
  +
dent of Fire Area 12. In addition, the inspectors verified that
  +
automatic fire detection system was provided in Fire Area 12;
  +
however, no automatic fire suppression system is provided for this
  +
area. This is the subject of an exemption request. Refer to
  +
paragraph 5.b. of this report for a discussion of this item.
  +
(7) Fire Areas 14A-1 and 14A-2, Units I and 2 Turbine Driven Auxiliary
  +
Feedwater Pump Room; Fire Areas 148-1 and 14B-2, Units 1 and 2
  +
Motor Driven Auxiliary Feedwater Pump Rooms
  +
Safe Shutdown Fire Train A Train B
  +
System / Function Area / Zone Raceway / Conduit Raceway / Conduit
  +
Auxiliary Feedwater
  +
System / Motor Driven
  +
Feedwater Pumps
  +
1-FW-P-03A 14B-1 1CH9970A
  +
1-FW-P-03B 14B-1 1CH997PA
  +
IDH018PA1
  +
  +
.
  +
.
  +
17
  +
2-FW-P-03A 14B-2 2CH9970A
  +
2-FW-P-03B 14B-2 2CH977PA
  +
A fire in either Fire Area 14B-1 or 14B-2, the Motor Driven
  +
Auxiliary _ Feedwater Pump Rooms, could result in the loss of the
  +
Auxiliary Feedwater System Motor-driven pumps. A 100% capacity
  +
turbine driven auxiliary feedwater pump is provided for each unit
  +
on loss of the two motor-driven pumps. Alignment of the turbine
  +
driven pump, however, requires operator actions to be accomplished
  +
within 30 minutes within the fire affected motor driven auxiliary
  +
feedwater pump room. This alternative shutdown capability is
  +
therefore not independent of the fire affected area and also the
  +
- fi r'e area must be re-entered within 30 minutes time. This is
  +
another example of Unresolved Item 338, 339/85-24-05.
  +
In addition, manual operator actions may be - required in the
  +
turbine driven auxiliary feedwater pump room to establish venti-
  +
lation systems and monitor local indication of the feedwater
  +
suction pressure in order that monitoring of the emergency conden-
  +
sate storage tank level can be accomplished. The inspectors
  +
'terifiad that automatic fire detection systems were provided in
  +
the feedwater pump rooms and that each room was separated from
  +
cther areas by a three hour rated fire barrier.
  +
An Exemption Request (Nurber 5) has been submitted by the licensee
  +
for lack of a fixed fire suppression system in the motor driven
  +
aux liary feedwater pump rooms.
  +
(8) Fire Areas 15-1 and 15-2, Units 1 and 2 Quench Spray Pump Houses
  +
-
  +
and Safeguards Areas
  +
Safe Shutdown Fire Train A Train B
  +
_ System / Function Area / Zone Raceway / Conduit Raceway / Conduit
  +
Auxiliary Feedwater System /
  +
Motor Driven Auxiliary
  +
Feedwater Pumps
  +
1-FW-P-03A 15-1 1CH9430C
  +
1-FW-P-03B 15-1 1CH943PC
  +
2-FW-P-03A 15-2 2CH9430C
  +
l
  +
2-FW-P-03B 2CH943PC
  +
Process Monitoring System /
  +
Steam Generator Pressure
  +
:
  +
_ _ _ _ . _ . . _ _ _
  +
  +
.
  +
.
  +
18
  +
Instrument Cables
  +
Instrument Trans- 15-2 20X016W01
  +
mitter P4-2474 JB-1003-2
  +
2CX016WC
  +
A fire in this area could cause loss of the motor-driven auxiliary
  +
feedwater pumps. The 100% capacity turbine driven auxiliary
  +
feedwater pump is available for use as an alterrative shutdown
  +
capability. The turbine driven pump is located in a separate fire
  +
area. Also a fire in this area could disable the steam generator
  +
pressure transmitters for process monitoring in the control room
  +
and the auxiliary shutdown panel. The licensee proposes to use
  +
local pressure indicators located in a separate fire area, the
  +
Main Steam Valve House, Fire Area 17-1 and 17-2.
  +
A fixed fire suppression system is not provided in either Fire
  +
Area 15-1 or 15-2; however, the inspectors verified that automatic
  +
ionization type smoke detection is provided in both fire areas.
  +
Manual fire fighting capability must be provided by portable
  +
extinguishers and the external yard hydrants and hose houses. The
  +
inspectors reviewed the fire fighting strategy for the Unit 2 area
  +
(2-FS-QS-1 dated January 27, 1982), which indicates that manual
  +
fire hose streams will be accomplished by laying 24 inch hose from
  +
the yard hydrants to the entrance door and coupling a 1 inch hose
  +
for fire fighting inside the area. The licensee has submitted an
  +
Exemption Request #3 for the lack of a fixed fire suppression
  +
system in the Quench Spray Pumphouses. This is identified as
  +
another example of Unresolved Item (338, 339/85-24-09).
  +
(9) Fire Areas 17-1 and 17-2, Units 1 and 2 Main Steam Valve Houses
  +
Fire Areas 17-1 and 17-2 contain the Main Steam Power-0perated
  +
Relief Valves (PORVs) for Units 1 and 2, respectively, of North
  +
Anna Power Station. Each fire area is located in a separate
  +
structure adjacent to the Containment Building (Fire Areas 1-1 and
  +
1-2), the Quench Spray Pump House (Fire Areas 15-1 and 15-2), and
  +
the Cable Vaults and Tunnels (Fire Areas 3-1 and 3-2).
  +
A fire in either Main Steam Valve House can result in the loss of
  +
control of the Steam Generator Power-0perated Relief Valves
  +
(PORVs) from the control room. The licensee proposes to re-enter
  +
the fire area and manually operate the PORVs by handwheels. The
  +
inspectors verified that these fire areas were separated from the
  +
adjacent fire areas by equivalent three hour rated barriers except
  +
that a seismic space gap separates Fire Areas 17-1 and 17-2 from
  +
the Quench Spray Pump Houses (Fire Areas 15-1 and 15-2). This is
  +
another example of Unresolved Item (338,339/85-24-03). The
  +
inspectors verified that automatic fire detectors were provided in
  +
L
  +
  +
. .
  +
19
  +
Fire Areas 17-1 or 17-2; however, no fire suppression systems are
  +
provided for either-area. This is the subject of the licensee's
  +
Exemption Request #4.
  +
Within the areas inspected, no violations and one deviation were
  +
'
  +
identified.
  +
b. Modifications Required to Meet 10 CFR 50, Appendix R
  +
The North Anna 10 CFR 50, Appendix R Report - Volume II, Chapter 6,
  +
identifies a number of modifications required in order for the plant to
  +
meet the requirements of Appendix R, Section III.G. The following
  +
modifications were reviewed by the inspectors during this inspection:
  +
(1) Pressurizer Level Indication and Reactor Coolant System Wide Range
  +
Indication - Modifications I-1 and 2
  +
Pressurizer level transmitters LT-RC1000 and LT-RC2000 and reactor
  +
coolant system pressure transmitters PT-RC1000 and PT-RC2000 for
  +
Units 1 and 2 respectively were installed to provide instrumenta-
  +
tion at_the auxiliary monitoring panel in the fuel building. This
  +
instrumentation is redundant to the normal control room instrumen-
  +
tation. Within the containments, the cabling for the normal
  +
instrumentation and the instrumentation for the auxiliary monitor-
  +
ing panel is separated by less than 20 feet. Modifications
  +
consisting of radiant energy shields were provided within contain-
  +
ment to meet the separation protection requirements of Appendix R,
  +
Section III.G.2 between redundant cable raceways, transmitters,
  +
and associated junction boxes. These modifications were required
  +
to assure that pressurizer level instrumentation would be avail-
  +
able at either the remote panel or control room panel in the event
  +
of a fire within containment. The containment was not accessible
  +
during this inspection; however, the inspectors reviewed the
  +
following work packages and verified that the licensee's QC
  +
organization had accomplished the final QC installation inspection
  +
verification:
  +
Design Final QC
  +
Item Change Package Inspection
  +
Unit 1 Pressurizer Level DCP 84-19 8-15-84
  +
and Reactor Coolant System
  +
Pressure Instrumentation
  +
Unit 2 Pressurizer Level DCP 84-20 10-23-84
  +
Instrumentation
  +
Unit 2 Reactor Coolant DCP 84-25 10-23-84
  +
System Pressure Instrumentation
  +
  +
. .
  +
20
  +
Following installation of the above instrumentation devices, the
  +
pressurizer level instrumentation transmitter for the auxiliary
  +
monitoring panel was found to be inoperative. This device was
  +
tagged out of service on November 24, 1984, which was after the
  +
Unit 2 had started up from the 1984 refueling outage. For addi-
  +
tional information on this item, refer to paragraph 7.
  +
(2) Reactor Coolant System Hot Leg Temperature Indication -
  +
Modification I-3
  +
Reactor coolant system temperature indication was previously
  +
provided at the auxiliary monitoring panel in the fuel building.
  +
The temperature elements are din ctly off the main reactor
  +
coolant hot legs for loops 1 and 2. However, to meet Appendix R,
  +
Section III.G.2, radiant energy shields were required to separate
  +
the redundant cable raceways within containment to assure that hot
  +
leg temperature would be available either in the control room or
  +
auxiliary monitoring panel in the event of a fire within contain-
  +
ment. The containment was not accessible during this inspection,
  +
but the inspectors reviewed work packages DCP 84-23 for Unit 1 and
  +
DCP 84-24 for Unit 2 to verify that this work had been completed.
  +
Unit 1 modification work was completed and final QC installation
  +
inspection verification was conducted by the licensee on
  +
September 6, 1984. Unit 2 modification work was completed except
  +
one of the two hot leg temperature indicators (No. TE-2423) had
  +
not yet been installed. Temperature indication for Unit 2 was
  +
available frem the control room and the second indicator
  +
(No. TE 2413) on the auxiliary monitoring panel. Only one temper-
  +
ature element is required to meet the Appendix R shutdown require-
  +
ments. Temperature indication is available for the two Unit 1
  +
instruments on the auxiliary monitoring panel.
  +
(3) Emergency Communication Upgrade - Modification I-4
  +
Radio communication is used fer the North Anna Appendix R shutdown
  +
scheme. To assure availability of radio communications in the
  +
event of a fire, the communication system was upgraded by provid-
  +
ing three additional repeaters. Repeaters 2-B and 2-BE are
  +
located in the Unit I cable spreading room and Repeater 1-A is
  +
located in the auxiliary building which is a separate fire area.
  +
The licensee completed the functional tests and construction
  +
verification on January 22, 1985. The radio communication system
  +
proved to be satisfactory during the Appendix R shutdown drill
  +
conducted during this inspection.
  +
(4) Fire Damper Upgrade in Emergency Switchgear Room -
  +
Modification I-5
  +
Two I hour rated dampers in the three-hour fire barrier between
  +
the Unit I and Unit 2 switchgear rooms were replaced with three
  +
hour dampers by Engineering Work Request (EWR) 84-263. The
  +
a
  +
  +
,
  +
.. .
  +
21
  +
inspectors reviewed the purchase specification and vendors submit-
  +
tal data which indicated that the dampers were " certified" by
  +
Underwriters Laboratories, Inc. (UL) as having a three hour fire
  +
rating. However, the installed dampers are provided with a label
  +
which indicates.that the dampers are rated for only 1h hours. The
  +
licensee has contacted the vendor and the vendor stated that the
  +
installed dampers have been " certified" by UL as meeting both the
  +
lh hour and three hour fire resistant rating. The vendor is to
  +
provide appropriate documentation and correct the label discrep-
  +
ancy for the dampers. This is identified as Inspector Followup
  +
Item (338, 339/85-24-07), Verification of Fire Resistance Rating
  +
of Fire- Dampers Between Switchgear Rooms, and will be reviewed
  +
during a subsequent NRC inspection.
  +
(5) Auxiliary Building Sprinkler System Upgrade - Modification II-1
  +
The power cables for the charging and component cooling water
  +
pumps did not meet the separation requirement of Appendix R,
  +
Section III.G.2. The modification to correct this discrepancy
  +
consisted of providing the following: a one hour wrap for one
  +
train of the charging pumps and component cooling water pumps
  +
power cables until 20 feet of separation was achieved; solid metal
  +
tray covers and fire stops for the intervening cable trays between
  +
the pumps; extension of the sprinkler system on the 259h' eleva-
  +
tion of the auxiliary building; and, additional smoke detectors on
  +
the 244 ' and 259 ' elevations of the auxiliary building. The
  +
inspectors toured the auxiliary building and verified that these
  +
modifications were completed.
  +
(6) Residual Heat Removal Pump Radiant Energy Shields -
  +
Modification II-2
  +
The RHR pumps are located adjacent to each other in the contain-
  +
ment for each unit. To meet the separation criteria of
  +
Appendix R, Section III.G.2 radiant energy heat shields were
  +
-
  +
installed between the redundant pump motors. The containment was
  +
not accessible for inspection; however, the inspectors reviewed
  +
the work packages for this. modification accomplished by DCP 84-21
  +
and DCP 84-22 for Units 1 and 2, respectively. These modifica-
  +
tions were inspected by the licensee's QC organization and veri-
  +
fied to be completed on August 23, 1984 for Unit 1 and
  +
September 25, 1984 for Unit 2.
  +
(7) Emergency Lighting Upgrade - Modification II-3
  +
Extensive emergency lighting modifications have been accomplished.
  +
Refer to paragraph 8 for details on this item.
  +
  +
_
  +
. ,
  +
22
  +
(8) Diesel Generator Control Circuit Isolation - Modification 5
  +
Diesels 1H and 2H have been provided with control circuit isola-
  +
tion capability and the control panels have been incorporated into
  +
the plant shutdown procedures. Some of these procedures were
  +
reviewed during this inspection and found to be satisfactory.
  +
(9) Installation of Containment Cable Tray Bottom Covers and Fire
  +
Stops - Modification III-1
  +
Redundant instrumentation cables inside containment which are
  +
required for shutdown were not provided with the separation
  +
required by Appendix R, Section III.G.2. Bottom cable tray covers
  +
and fire stops were provided by this modification for some cable
  +
trays to provide protection. This work was not inspected since
  +
the containment was not accessible. However, the inspectors
  +
reviewed the work package, EWR 84-376 for Unit 1 and DCP 84-39 for
  +
Unit 2, which indicated that the work had been verified completed
  +
by the licensee's QC inspection organization on July 25, 1984 for
  +
Unit I and on September 25, la84 for Unit 2.
  +
(10) Replace Load Center Fuses - Modification II-2
  +
The electrical system coordination study identified certain fuses
  +
which were required to be replaced to provide proper coordination.
  +
The fuses for the control circuits to the 125V DC distribution
  +
system have been - replaced. This work was accomplished by
  +
EWR 84-328 and was verified completed by the licensee's QC organ-
  +
ization on September 4, 1984.
  +
The fuses associated with the 480/120V control power transformers
  +
are scheduled to be completed by the end of the 1986 refueling
  +
outages. This item is scheduled to be reviewed during a subse-
  +
quent NRC inspection.
  +
(11) Seal Charging Pump Cubicle Penetrations - Modification III-4
  +
Several piping and electrical penetrations in the walls separating
  +
the charging pumps were not sealed. This modification sealed the
  +
open penetrations. The inspectors reviewed work package
  +
EWR 84-331 which required the penetrations to be sealed and noted
  +
that the licensee's QC organization verified that the required
  +
work was completed on January 25, 1985.
  +
Modifications I-6 through I-13 have not yet been completed. An inspec-
  +
tion of these items will be made during a subsequent NRC inspection.
  +
This item is identified as Inspector Followup Item (338,339/85-24-08),
  +
NRC Review of Completed Appendix R Fire Protection Modifications.
  +
.
  +
  +
.. .
  +
23
  +
LWithin the areas inspected, no violations or deviations were
  +
identified,
  +
c. Exemption Requests From 10 CFR 50, Appendix R Requirements
  +
-The North Anna 10 CFR 50, Appendix R Report - Volume II, Chapter 7,.
  +
identifies 24 areas which deviate from the Appendix R requirements. A
  +
justification is provided for the deviation.s and requests for exemp-
  +
tions to the requirements have been made to the NRC. These items are
  +
to be reviewed by NRR. . Pending completion of this review, this is
  +
identified as Unresolved Item (338, 339/85-24-09), Review and Resolu-
  +
tion of Appendix R Exemption Requests,
  +
d. Technical Specifications (TS) For Appendix R Required Features
  +
The remote shutdown panel remote instrumentation, remote diesel genera-
  +
tor' control and instrumentation panel and related components are not
  +
included in the North Anna TS. This item is being referred to NRR and
  +
is . identified as Inspector Followup _ Item (338, 339/85-24-10),
  +
Appendix R, Plant Shutdown Components Are Not Included in the Technical
  +
' Specifications.
  +
e. -Audits of Appendix R Implementation Program
  +
The licensee contracted with Tenera Corporation-Findings to conduct an
  +
' independent audit of North Anna for compliance to Appendix R. Tenera's
  +
audit report of August 21, 1985, identifies six significant findings,
  +
.
  +
'
  +
11 findings, and nine minor findings. Corrective action has been
  +
completed on all of these items except as listed below:
  +
(1) Significant Findings
  +
(a) Emergency Lighting
  +
The audit identified the inadequate emergency lighting for
  +
the control room, filter room and charging pump cubicles.
  +
Exemption requests for these items have been submitted to the
  +
NRC. The -NRC review of these items will be handled by
  +
separate correspondence. This is another example of Unre-
  +
solved Item (338, 339/85-24-09).
  +
(b) Re-entry Into Fire Areas to Perform Hot Standby Functions
  +
;
  +
l- The licensee proposes to re-enter the charging pump cubicles
  +
i and auxiliary feedwater pump rooms within one hour.following
  +
L a fire to perform hot standby shutdown functions. In - the
  +
,
  +
past, the NRC has not permitted manual actions within a fire
  +
; area involved in fire until after at least one hour. This
  +
i
  +
item is to be forwarded to NRC for further evaluation and is
  +
identified as an example of Unresolved Item (338,
  +
339/85-24-05).
  +
l
  +
l
  +
. - , _ -
  +
- . - - , _ . . _ . . . - - - _ _ -
  +
- . - - - .
  +
  +
______ _____ -___ _ _
  +
'
  +
. ,
  +
24
  +
'
  +
,
  +
This item is discussed in paragraph 5 of this report.
  +
(c) Conduit Penetrating Fire Barriers Were Not Sealed
  +
.
  +
The conduit penetrations of fire barriers were identified by
  +
Tenera as not being properly sealed to the fire rating of the
  +
barrier. The licensee has developed criteria to apply to the
  +
conduits which penetrate the plant's fire barriers. This
  +
criteria appears satisfactory. However, sufficient plant
  +
inspections by the licensee has not yet been accomplished to
  +
determine the significance of this finding.
  +
Pending completion of the licensee's evaluation, this item is .
  +
identified as Unresolved Item (338, 339/85-24-11), Licensee's
  +
Re-evaluation of Conduit Penetration of Fire Barriers To -
  +
Determine if Penetrations Are Properly Sealed.
  +
(2) Findings
  +
(a) Substandard Fire Barrier Penetration Seals
  +
The installed fire barrier. penetrations seals using Dow
  +
Corning foam do not meet the design of the installation
  +
configurations which were tested by the Underwriters Labora-
  +
tories Inc. In addition, the fire tests performed on the
  +
installed penetration seal configurations by Virginia
  +
Electric and Power Company (VEPC0) did not include ~ all the
  +
test's acceptance criteria required of Underwriters Labora-
  +
tories. The North Anna penetration seals and fire tests are
  +
described in the Fire Protection Systems Review of April 1,
  +
1977 and Supplement 1 of December 15, 1977 and appear to
  +
have been reviewed and found acceptable by .the NRC/NRR Fire
  +
Protection Safety Evaluation Report (SER) of February 1979.
  +
This item is to be forwarded to NRC/NRR for further evalua-
  +
tion and is identified as' Unresolved Item (338, 339/85-
  +
24-12), Substandard Fire Barrier Penetration Seals, pending
  +
completion of this reevaluation.
  +
(b) Seismic Gap Seal in Fire Barriers
  +
The joint seal in the seismic gap of fire barriers does not
  +
appear to afford three hour fire resistant protection between
  +
safe shutdown components. This item is addressed in the
  +
North Anna Fire Protection Systems Review (Question 16), but
  +
does not appear to be covered by the Fire Protection SER.
  +
This is another example of Unresolved Item (338,
  +
339/85-24-03).
  +
  +
.
  +
-
  +
25
  +
(3) Minor Findings
  +
(a) Smoke Detector Sensitivity Check
  +
The current inspection and test program for the smoke detec-
  +
tor systems does not require the sensitivity for each detec-
  +
tor to be calibrated. The installation code, NFPA-720,
  +
Proprietary Protective Signaling Systems, does not clearly.
  +
specify this calibration and it is not included as a require-
  +
~
  +
ment of the Technical Specifications. The licensee is
  +
reviewing this item to determine the appropriate corrective
  +
action. This is identified as Inspector Followup Item (338,
  +
339/85-24-13), Sensitivity Calibration Is Not Included As
  +
Part of Smoke Detector Maintenance Program, and will be
  +
reviewed during a subsequent NRC inspection.
  +
(b) Fire Brigade Operations
  +
The fire brigade pre-fire plans do not address inadvertent
  +
application of suppression agents to redundant equipment.
  +
These plans are currently being revised to address the
  +
cautions regarding safe shutdown equipment in_ common areas of
  +
the auxiliary building. Completion of these revisions ~ is
  +
scheduled for November 1, 1985. This is identified as
  +
Inspector Followup Item (338,339/85-24-14), Licensee to
  +
Revise Pre-Fire Plans to Address Inadvertent Application of
  +
Suppression Agents to Redundant Equipment, and will be
  +
reviewed during a subsequent NRC inspection.
  +
6. Protection of Associated Circuits
  +
The inspection was conducted to verify compliance with associated circuit
  +
provisions of 10 CFR 20, Appendix R, Sections III.G. and III.L. The empha-
  +
sis 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 non-
  +
safety-related, where there is a common power source with shutdown
  +
equipment and the power source is not electrically protected from the
  +
circuit of concern.
  +
  +
-
  +
.
  +
.
  +
26
  +
The' licensee evaluated the fuse. breaker coordination for the Emergency
  +
Power System which consisted of:
  +
(1) 4KV power distribution and emergency generators
  +
-
  +
(2) 480V AC load centers and motor control centers (MCC)
  +
(3) 120V AC instrument panels and inverters
  +
(4) 125V DC distribution buses, emergency batteries and chargers.
  +
The licensee advised that in some cases, coordination between the 4160V
  +
switchgear supply breakers and the down stream 480V load center supply
  +
breakers could not be obtained. The licensee advises that on the loss
  +
of the 4160V Feeder (Emergency Switchgear Room Fire), the affected unit
  +
can be crosstied with the opposite unit piping to use the charging
  +
system of the unaffected unit to safely shut down the damaged unit.
  +
The inspectors reviewed the emergency procedures which cover the loss
  +
of the emergency switchgear room and they appeared adequate.
  +
The inspectors examined the various fuse / breaker coordination studies
  +
-of other portions of the Emergency Power System to verify fuse / breaker
  +
coordination for the worst case fault for each of the 480V load centers
  +
and MCCs, the 120V AC instrument panels and inverters and the 125V DC
  +
distribution buses, batteries and chargers.
  +
The licensee's study resulted in a finding that required changing of
  +
various fuses throughout the system. The inspectors reviewed Electri-
  +
-cal Maintenance Procedure EMP-C-TSR-1, Trouble-shooting and Repair of
  +
Electrical Circuits, and Administrative Procedure ADM-4.0, Procurement
  +
. Document Control which control the replacement and ordering of replace-
  +
ment parts to insure that like parts are used as replacements.
  +
IE Information Notice 85-09, Isolation Transfer Switches and Post-Fire
  +
Shutdown Capability, was issued January 31, 1985. This Notice identi-
  +
fies a potential problem concerning fuses in control circuits that are
  +
common for operation of equipment from the Control Room and Alternate
  +
Hot Shutdown area. A fire in the Control Room could cause these common
  +
fuses to blow before transfer is made to the Alternate Hot Shutdown
  +
area. If the control circuit is needed at the Alternate shutdown area
  +
to energize a piece of equipment and if the fuse (s) blew before trans-
  +
r fer, equipment would not be operable without replacing the blown
  +
fuse (s).
  +
The licensee has completed the engineering modifications for isolation
  +
and transfer to meet the intent of IE Information Notice 85-09. The
  +
following Design Change Packages (DCP) have been developed.
  +
* DCP 84-62 - Service Water, Component Cooling Water, Residual
  +
Heat Removal Circuit Isolation for Units 1 and 2.
  +
' DCP 84-64 - Switchgear Room Ventilating Equipment Isolation
  +
DCP 83-23 - Diesel Generator Isolation Unit 1
  +
'
  +
  +
r- .
  +
.
  +
.
  +
27
  +
* DCP 83-24 - Diesel Generator Isolation Unit 2
  +
DCP 84-63 - Auxiliary Building Fan Modification Units 1 and 2
  +
The installation of the changes required by these DCPs will be complet-
  +
ed by the end of each units' forthcoming refueling outage.
  +
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 nonsafety-related compo-
  +
nents that would adversely affect shutdown capability
  +
(e.g;, RHR/RCS Isolation Valves).
  +
The licensee developed a list of potential spurious operations which
  +
could affect high/ low pressure boundaries. The inspectors reviewed the
  +
licensee's actions for resolving the spurious actuation of the follow-
  +
ing high/ low pressure interface valves:
  +
PCV-1455 Pressurizer PORV
  +
* PCV-1456 Pressurizer PORV
  +
* MOV-2700 RHR Suction Isolation
  +
* MOV--2701 RHR Suction Isolation
  +
* PCV-MS101A-C Steam Generator PORVs
  +
A random selection of valves located in various pump suction and
  +
discharge paths were reviewed for methods of control / protection from
  +
spurious operations. The following valve schematic, logic diagrams, or
  +
piping drawings were examined:
  +
* MOV 1267A&B Charging Pump Suction Header Isolation
  +
M0V 1269A&B Charging Pump Suction Header Isolation
  +
* M0V 1270A&B Charging Pump Suction Header Isolation
  +
* MOV 1115B&D Charging Pump Suction Isolation to RWST
  +
* M0V 1115A&C Charging Pump Suction Isolation to VCT
  +
* MOV 1286A,B,C Charging Pump Discharge Valves
  +
MOV 1289A&B Charging Pump Discharge Header MOV
  +
* FCV 1122 Charging Flow Control Valve
  +
* TV MS111A&B Turbine Driven FW Pump Steam Admission Valves
  +
* PCV MS101A,B,C Steam Generator A, B, and C PORV
  +
MOV FW100A,B,C Auxiliary Feedwater MOV Header to Steam
  +
Generator A, B, and C
  +
  +
~
  +
.
  +
.
  +
28
  +
The licensee has developed procedures for taking manual control of
  +
these valves or removing power from them to prevent spurious movement
  +
or cause them to move to their fail safe position. In certain instanc-
  +
es, the power is removed from various feeder boards to prevent spurious
  +
fire induced operations. In certain instances, additional switches
  +
have been designed into the system to permit removal of power from
  +
those valves that are in high-low pressure interface situations. The
  +
switches will be located in areas remote from the feeder board loca-
  +
tions. The licensee has analyzed the spurious operation of valves that
  +
could impact on safe shutdowr. and has developed a plan of action that
  +
should enable either unit to safely shutdown in the event of a fire.
  +
c. Common Enclosure Concern
  +
The common enclosure concern is found when redundant trains are routed
  +
together with a nonsafety circuit which crosses from one raceway or
  +
enclosure to another, and the nonsafety circuit is not electrically
  +
protected or fire can destroy both redundant trains due to inadequate
  +
fire protection means.
  +
The licensee advised that the removal of power from equipment to
  +
prevent spurious signal operations also supports part of the protection
  +
provided for the common enclosure concern. The power interruotion is
  +
accomplished either by breakers, fuses, or opening of supply breakers.
  +
Power and control cables are sized and rated for 600 volts, in which
  +
case a fault should trip the protective device prior to cable jacket
  +
overheating or self-igniting. The licensee has committed to control
  +
intervening combustibles, install fire stops between safe shutdown
  +
cable trays and conduits, and seal all electrical penetrations for safe
  +
shutdown cables through their wall penetrations with fire stops equal
  +
to that required for the wall.
  +
d. Damage Control Measures
  +
Appendix R, Sections III.G.1.b and III.L.5 require fire protection
  +
features to be provided for structures, systems and components impor-
  +
tant to safe shutdown and to be capable of limiting fire damage so that
  +
systems necessary_ to achieve and maintain cold shutdown are 'ree of
  +
fire damage or can be repaired such that the equipment can be made
  +
operable and cold shutdown achieved within 72 hours. Materials for
  +
such repairs are required to be readily available on site and proce-
  +
dures are to be in effect to implement such repairs.
  +
The licensee has in place Emergency Electrical Maintenance Procedures
  +
#EEMP-C-RH-01, Installation of Emergency Temporary RHR Motor Feeder
  +
Cable and EEMP-C-EP-11, Rigging of Emergency Ventilation.
  +
The materials required by the above listed procedures are set aside in
  +
a controlled area of the warehouse. The RHR cables are on reels and
  +
!
  +
  +
_ ._
  +
.. .
  +
29
  +
have been lugged to expedite the making of the connections at the
  +
motor, penetration, and breaker. Due to the location of the RHR pumps,
  +
it is .necessary to have two different lengths of cables. The inspec-
  +
. tors examined the storage area. A box containing the required termi-
  +
nating and installation tools and materials is enclosed in a cage with
  +
the cable reels.
  +
The emergency ventilating procedure identifies breakers which may be
  +
used to power the emergency ventilation fans. The fans and the port-
  +
able ducts (elephant trunks) are stored in the special area of the
  +
warehouse also. The fan motors have cables connected so that it will
  +
only be necessary to connect the other cable end to the breaker. The
  +
inspector walked the route that the cable reels and materials will be
  +
taken through the turbine auxiliary buildings. The plan appears to be
  +
well thought out and adequate.
  +
7. Alternative Shutdown Capability
  +
The inspectors reviewed operating personnel training, shift staffing and the
  +
use of abnormal operating and surveillance procedures, as these activities
  +
relate to the alternative shutdown capability. These areas were reviewed to
  +
determine if the licensee's 10 CFR 50, Appendix R Reanalysis contains the
  +
elements described in Section III.L of Appendix R for achieving and main-
  +
~ taining the plant in hot standby conditions with the subsequent capability
  +
to cooldown the plant to cold shutdown conditions.
  +
a. Personnel Training and Shift Staffing
  +
The inspectors reviewed the licensee's_ program for conducting training
  +
on those plant abnormal procedures issued to operate the components,
  +
equipment, and systems designated for use as the alternative shutdown
  +
capability. The licensee has essentially completed initial training
  +
for senior reactor operators (SRO), reactor operators (RO) and
  +
auxiliary operators. Training on the abnormal procedures issued to
  +
operate the alternative shutdown capability includes lecture series,
  +
formal lesson plans, and simulator training. The inspector reviewed
  +
training records and held discussions with shift operating personnel to
  +
verify that training is being received. The licensee has also incorpo-
  +
rated training on these procedures into the on going licensed operator
  +
requalification training programs.
  +
The licensee's normal shift staffing was reviewed to verify that
  +
sufficient operating personnel are available to operate equipment and
  +
systems described in Abnormal Procedure AP-50.1, Control Room Fire.
  +
The review indicated that operating shift crew required by Technical
  +
Specification would be the personnel used to support AP-50.1
  +
operations.
  +
  +
E
  +
* .
  +
30
  +
The shift operating personnel provided to support the control room fire
  +
abnormal procedure are separate from the operating personnel assigned
  +
to the fire brigade. The licensee has ten other abnormal operating
  +
procedures designed to provide alternative shutdown capability for
  +
other plant area fires such as, emergency switchgear room, cable vault
  +
and tunnel, and auxiliary building. The staffing of operators for
  +
these fire areas would not require operating personnel beyond that
  +
required for a control room fire. Once the fire is extinguished,
  +
additional operating personnel would become available that were
  +
initially assigned to the fire brigade. In addition, the call-in of
  +
operating personnel would also be reporting to the plant as required by
  +
the station emergency plan. Adequate shift staffing was further demon-
  +
strated during a simulated drill of AP-50.1, which began in the main
  +
control room followed by manning the auxiliary shutdown panels in the
  +
switchgear rooms for Units 1 and 2 and other remote stations in the
  +
plant. The drill was concluded when the steps of the procedure
  +
achieved stable hot standby conditions.
  +
b. Abnormal Operating Procedures
  +
The inspectors reviewed several of the licensee's abnormal procedures
  +
designed to operate plant equipment and systems to achieve hot standby
  +
and subsequent cooldown of the plant to cold shutdown conditions. The
  +
procedures were reviewed to verify that Appendix R, Section III.L
  +
requirement as given below have been incorporated into these
  +
procedures.
  +
-
  +
Achieve and maintain hot standby conditions.
  +
-
  +
Achieve and maintain subcritical reactivity conditions in the
  +
reactor.
  +
-
  +
Provide decay heat removal capabilities.
  +
-
  +
Maintain reactor coolant inventory and steam generator inventory.
  +
-
  +
Achieve and maintain cold shutdown conditions.
  +
-
  +
Provide direct readings of the process variables necessary to
  +
control the above conditions.
  +
'
  +
The licensee reanalysis identified 12 fire areas in the plant where
  +
alternative shutdown capability is required and abnormal operating
  +
procedures have been issued for each of these fire areas. The inspec-
  +
tor selected the following procedures from the group for review:
  +
-
  +
AP-50, Revision 3, Fire Protection - Operations Response
  +
-
  +
AP-50.1, Revision 3, Control Room Fire
  +
-
  +
AP-50.2, Revision 2, Emergency Switchgear Room Fire
  +
. _ _ . _ _ _
  +
_ _ _
  +
.
  +
  +
. .
  +
31
  +
-
  +
AP-50.3, Revision 3, Cable Vault and Tunnel Fire
  +
-
  +
AP-50.4, Revision 2, Auxiliary Building Fire
  +
-
  +
AP-22.7, Revision 2, Loss of Emergency Condensate Storage Tank
  +
-
  +
EP-0, Revision 0, Reactor Trip or Safety Injection
  +
The review indicated that the abnormal procedures contain the necessary
  +
steps to achieve and maintain the plant in hot standby and also to take
  +
the plant to cold shutdown. AP-50.1, Control Room Fire was walked-
  +
through with the shift operating crew to verify that:
  +
-
  +
Communications between various operating stations are adequate and
  +
operable.
  +
-
  +
Identification plates installed on valves, components, and instrumen-
  +
tation agree with that called for in the procedure steps.
  +
-
  +
Lighting at operating. stations appears adequate.
  +
-
  +
Equipment and valves to be operated can be reached and are not
  +
obstructed.
  +
-
  +
Radio handsets, dedicated supplies, keys, hand held lanterns, and
  +
procedures to be used are readily available and the procedures
  +
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 has been received from NRR
  +
to use other means.
  +
Inspector comments identified as a result of reviewing the procedures
  +
and the walk-through of the Control Room Fire Procedures AP-50.1 have
  +
been incorporated into the appropriate procedures by issuing a revi-
  +
sion to the ' procedures. In addition, the licensee is preparing an
  +
administrative procedure that will inventory on a monthly bases the
  +
equipment stored in the Appendix R locker. This inventory will ensure
  +
that equipment is available and maintained in good condition.
  +
c. Surveillance Procedures
  +
As previously noted the licensee has selected normal plant equipment
  +
and systems to provide for the alternative shutdown capability. The
  +
routine surveillance and calibration programs are used to maintain
  +
I
  +
,. 1
  +
L I
  +
  +
. .
  +
32
  +
systems operable as well as the instrumentation and components in-
  +
stalled at the auxiliary shutdown panels in the emergency switchgear
  +
room and the auxiliary / remote monitoring panels located in the fuel
  +
building. Periodic Test (PT) 41.2.1 Auxiliary Shutdown Panel (ASP)
  +
Calibration (every 18 months) and PT 41.1 ASP Monitoring Channel Checks
  +
-(every 31 days) are the procedures used to implement the surveillance
  +
of these panels which is required by Technical Specification 4.3.3.5.
  +
The calibration of the instrumentation on the auxiliary / remote monitor-
  +
ing panels is scheduled through the Instrument Maintenance Procedures
  +
(IMP) Program which specifies the calibration frequency (two years) and
  +
which Instrumentation Calibration Procedure (ICP) is to be used. A
  +
recent revision to Auxiliary Building Log Procedure 1-Log-60 added a
  +
requirement to perform daily checks of the operability status on the
  +
instrumentation in the auxiliary / remote monitoring panels. The licen-
  +
see is also developing Administrative Procedure 20.45, Fire Protection
  +
Surveillance / Maintenance Program which addresses Appendix R require-
  +
ments and equipment.
  +
The auxiliary / remote monitoring panels were originally installed for
  +
10 CFR 50, Appendix A, General Design Criteria 3, Fire Protection
  +
L considerations and is presently used to monitor the process variable
  +
discussed in Appendix R, Section III.L.2.d for several fire areas.
  +
The review of the licensee surveillance / calibration programs and a
  +
visual ' inspection of instrumentation provided at the remote monitoring
  +
panels resulted in the following concerns:
  +
(1) App'endix R, Section III.L.2.d requires that the process monitoring
  +
function shall be capable of providing direct readings of the
  +
process variables that are being used. The NRC issued IE Notice
  +
84-09 dated February 13, 1984, which identified a list of the
  +
minimum monitoring capability for Alternative Shutdown. The
  +
licensee's source of makeup water to the reactor coolant system
  +
-for several fire areas is the refueling water storage tank (RWST).
  +
No direct reading of tank water level is provided outside the
  +
control room, at the remote monitoring panels, or locally at the
  +
tank. Until the licensee has reviewed and provided resolution,
  +
this matter remains an Unresolved Item (338, 339/85-24-15), Direct
  +
Reading of RWST Level Not Available Outside the Control Room.
  +
(2) The auxiliary / remote monitoring panels provide direct reading of
  +
RCS pressure, hot and cold leg temperature, pressurizer level,
  +
steam generator level and source range neutron flux for both
  +
units. During a walkthrough of the panels, it was noted that
  +
Unit 2 pressurizer level indicator LI-RC2000 was pegged high off
  +
scale. A tag on the instrument provided an out of service date of
  +
n
  +
  +
,
  +
..
  +
33
  +
November 1984. The following fire areas and procedures required
  +
the use of the auxiliary / remote monitoring panel and pressurizer
  +
level in particular:
  +
-
  +
AP-50.1 Control Room Fire
  +
-
  +
AP-50.2 Emergency Switchgear Room Fire
  +
-
  +
AP-50.3 Cable Vault and Tunnel Fire
  +
-
  +
AP-50.4 Auxiliary Building Fire
  +
-
  +
AP-50.5 Containment Fire
  +
The licensee identified the following compensatory measures that
  +
were considered to be in effect while the Unit 2 pressurizer level
  +
instrument has been out of service:
  +
-
  +
Fire watches have been maintained in the emergency
  +
switchgear room.
  +
-
  +
Continuous line type heat detection system is installed
  +
under cable trays inside containment that carry the
  +
control room pressurizer level instrument cables.
  +
-
  +
Fixed fire detection and suppression systems are in-
  +
stalled in the cable vault and tunnel area.
  +
The inspectors requested that the licensee review the operational
  +
consideration for conducting a safe shutdown without pressurizer
  +
level indication and the operator actions necessary to ensure that
  +
a water level is maintained in the pressurizer. The licensee
  +
developed an abnormal procedure AP-50.12. Basically, this proce-
  +
dure uses the (CVCS) charging pump and a combination of charging
  +
to the RCS through the normal charging path for a specified length
  +
of time followed by maintaining makeup to the RCS through the
  +
reactor coolant pumps seal injection lines (approximately 1%
  +
increase in level every ten minutes). A specific RCS pressure is
  +
maintained (2000 psig) by slowly controlling cooldown via the
  +
local operation of the steam generator pressure operated relief
  +
valves. The procedure has been evaluated and practiced on the
  +
plant simulator and has been approved for use by the Station
  +
Nuclear Safety and Operating Committee.
  +
On September 23, 1985, a conference call between Region II manage-
  +
ment and North Anna station management was held to discuss the
  +
licensee's compensatory measure concerning the Unit 2 out of service
  +
pressurizer ' level instrument on the auxiliary / remote monitoring
  +
panel. The licensee indicated that a letter would be sent to the
  +
Region, confirming the compensatory measures being taken and the
  +
date for returning Unit 2 pressurizer level instrument to service.
  +
Within the areas inspected, no violations or deviations were
  +
identified.
  +
I
  +
- _ _ _ . . .
  +
  +
. _ _ _ _ _ _ _ _ _ _ _ _ _ -
  +
e ..
  +
34
  +
8. Compliance to 10 CFR 50, Appendix R, Section III.J, Emergency Lighting
  +
Emergency lighting units equipped with at least an eight hour battery power
  +
supply are required to be provided in all areas required for operation of
  +
safe shutdown equipment and in access and egress routes thereto.
  +
The inspectors reviewed the licensee's emergency lighting modifications
  +
completed by Design Change No. 84-26. Over 200 additional emergency light-
  +
ing units have been installed throughout the plant. The licensee's opera-
  +
tion, site engineering office, QC, and advisory operations (startup testing)
  +
departments conducted walkdown inspections to verify that adequate emergency
  +
-lighting was provided throughout the plant. Each lighting unit was func-
  +
tionally tested to verify that the units would provide illumination for at
  +
least eight hours. The lighting units provided are Exide Model Nos. 100 and
  +
200, except some areas of the plant such as the emergency switchgear room
  +
are provided with up to approximately 28 lights supplied by an Exide "Cen-
  +
taurus" Model 1-1000 lighting system.
  +
A walkthrough inspection by the inspectors using shutdown procedure
  +
No.1-AP-50.1, Control Room Fire, to identify the required manual operator
  +
actions indicated that sufficient emergency lighting to meet Appendix R,
  +
Section III.J was provided in all areas, except for panel MCC 2H1-2N in the
  +
Unit 2 cable vault, access and egress routes to equipment outside the plant
  +
structures, use of portable lighting units in the seal water filter area and
  +
the use of lighting units in the control room, which are supplied by emer-
  +
gency diesel generators in lieu of battery packs. The lighting provided for
  +
panel MCC 2H1-2N was considered marginal, but the identification tags on the
  +
panel could still be read. To correct this situation, the licensee immedi-
  +
ately generated Engineering Work Request 85-_598 and the installation of
  +
additional lighting units is scheduled to be completed by September 30,
  +
1985. The other three items have been identified by the licensee and
  +
exemptions requests have been submitted to the NRC. The NRC review and
  +
approval of these exemption requests will be handled by separate correspon-
  +
dence. This is another example of Unresolved Item (338, 339/85-24-09).
  +
To assure that the lighting -units will remain functional, the licensee has
  +
implemented Procedures E-11-ELT/M-1 and E-21-ELT/M-2, Emergency Lighting,
  +
which require all of the eight hour emergency lighting units to be inspected and
  +
tested monthly. The procedures required that the lamps be checked for
  +
proper alignment and battery- units and lamps to be verified operable.
  +
Procedures E-11-ELT/C-1 and E-21-ELtT/C-2 are being developed to require
  +
all emergency battery units to be functionally tested for eight hours each
  +
month. These procedures are scheduled to be issued by November 1, 1985.
  +
Within the areas examined, no violations or deviations were identified.
  +
  +
c
  +
.- ,
  +
35
  +
9. Compliance to 10 CFR 50, Appendix R, Section III.0 011 Collection System for
  +
Reactor Coolant Pumps
  +
The reactor coolant pumps are required to be equipped with an oil collection
  +
system if the containment is not inerted during normal plant operations.
  +
The oil collection system is to be so designed, engineered, and installed
  +
such that failure will not lead to fire during normal or design basis
  +
accident conditions and .there is reasonable assurance that the system will
  +
withstand the " Safe Shutdown Earthquake." The system is to be adequately
  +
sized and capable of collecting lube oil from all potential leakage sites in
  +
the reactor coolant pump lube oil system. Leakage is to be collected and
  +
drained to a closed container sized to hold the entire lube oil system
  +
inventory. A flame arrester is required in the container vent if the flash
  +
point characteristic of the oil presents the hazard of fire flash back.
  +
The inspectors reviewed the design of the oil collection system for the
  +
reactor coolant pumps. An inspection of the system was not made since the
  +
plant was in operation and access to the containment was not possible.
  +
However, the work package for the oil collection system, Design Change
  +
No. 80-47, was reviewed. The design documents indicate that the system is
  +
seismically designed ano supported to function following a seismic event.
  +
The system is arranged to collect and temporarily store any lube oil which
  +
may leak out of the reactor coolant pump motor lube oil system. The follow-
  +
ing oil-bearing components are provided with oil collection enclosures:
  +
-
  +
011 lift pump and associated pressurized lines
  +
-
  +
Oil cooler and associated pressurized lines
  +
-
  +
Oil level indicators
  +
-
  +
Oil fill and drain points
  +
-
  +
Flanged connections for the oil reservoir
  +
-
  +
Sight glasses
  +
-
  +
All flanged oil-bearing connections
  +
An oil collection system is provided for each reactor coolant pump motor.
  +
Each system is connected to a drain tank of 265 gallon capacity which is the
  +
amount of oil in each pump motor. The tank vents are provided with flame
  +
arrestors and the drain lines from the oil collection enclosures to the tanks
  +
are sized to accommodate the largest potential oil leak.
  +
The licensee's QC inspection verification data was reviewed by the inspec-
  +
tors and the final QA/QC inspections on the Unit 1 and Unit 2 systems were
  +
noted to have been completed on March 23, 1981 and November 24, 1980,
  +
respectively.
  +
The oil collection systems for the reactor coolant pump motors appear to
  +
meet the requirements of Appendix R, Section III.0 and within the areas
  +
examined, no violations or deviations were identified.
  +
L.
  +
  +
r: -
  +
.-
  +
9
  +
36
  +
10. Inspector Followup Items (IFI)
  +
a. (Closed) IFI (338, 339/85-10-01), Review of Fire Fighting Equipment
  +
Inventory for Firefighting Equipment Inventory for Fire Hydrant Hose
  +
Houses. Procedure PT-105.3, Hose House Inspection, has been revised to
  +
require that the same quantity of fire fighting equipment be maintained
  +
in the hydrant hose houses as listed in the North Anna Fire Protection
  +
Plan. This item is closed.
  +
b. (Closed) IFI (338, 339/85-10-02), Position Verification and Position
  +
Control for Critical CO2 and Fire Suppression Water System Valves.
  +
Procedures PT-100.3, Fire Suppression Water System Valve Position
  +
Verification and PT-104.4, Low Pressure CO 2and Halon Systems Required
  +
Valve Lineup Verification have been revised to include all of the key
  +
fire protection valves. This item is closed.
  +
c. (Closed) IFI (338, 339/84-08-02), Correct Pump Curve for Fire Pumps.
  +
The motor and diesel driven fire pumps were subjected to a full flow ,
  +
performance test on June 28, 1985. The motor driven pump has recently
  +
been rebuilt; therefore,. during tnis test, additior.al flow and head
  +
pressure reading were obtained to develop a new pump test curve to be
  +
used as acceptance criteria for future tests. The test for both pumps
  +
exceeded the Technical Specification requirements, but the diesel
  +
pump's discharge flow and head pressure were slightly deficient from *
  +
the design pump curve. Work Ord2r No. 26610 has been issued to deter-
  +
mine the cause of the reduced flow and to make the necessary correc-
  +
tions. This problem will be reviewed during future NRC inspection;
  +
however, sufficient action has been taken to close this IFI.
  +
l
  +
;
  +
}}

Latest revision as of 02:23, 1 July 2020

Special Insp Repts 50-338/85-24 & 50-339/85-24 on 850909-13. Deviation Noted:Installed Fire Stop Penetration Shields Did Not Have Fire Seal Damming Matl in Place
ML20136J169
Person / Time
Site: North Anna Dominion icon.png
Issue date: 11/04/1985
From: Conlon T, Hunt M, Miller W, Taylor P, Wiseman G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20136J148 List:
References
Download: ML20136J169 (37)


See also: IR 05000338/1985024

Text

8

e

.

km atRg UNITE 3 STATES

o NUCLEAR REGULATORY COMMISSION

,

[ n REGION 11

g j 101 MARICTTA STREET, N.W.

  • t ATLANTA, GEORGI A 30323

%...../

Report Nos.: 50-338/85-24 and 50-339/85-24

i Licensee: Virginia Electric and Power Company

Richmond, VA 23261

Docket Nos.: 50-338 and 50-339 License Nos.: NPF-4 and NPF-7

Facility Name: North Anna 1 and 2

Inspection Conduct d: September 9-13, 1985

Inspectors: , g/ , //- /~ df

W. H. Miller (Teab-head sN Date Signed

G.

.

Wisema

b ld ~

}Ol3/lS.S

Date Signed

, - o, Ic) //y'!/f

/

P. A. Taylor / ~ ~ Da'te'Sfoned

llA T

M. V. 'Huiit

'

a~

-

ll lll$ T

Dat4 S'ignea

Approved by: fM

T. E. Conlon, Section Chief

/s/hff

D' ate Signed

Plant Systems Section

Engineering Branch

Division of Reactor Safety

SUMMARY

Scope: This special, announced inspection involved 140 inspector-hours on site

in the areas of fire protection and the licensee's actions regarding the imple-

mentation of the requirements of 10 CFR 50, Appendix R, Sections III.G. , III,J. ,

III.L. , and III.O.

- Results: Within the areas inspected, no violations were identified. One appar-

ent deviation was found - Installed Penetration Seals Are Not In Conformance With

App'aoved Tested Configuration, paragraph 5.a.(2).

8511250299 851114

PDR ADOCK 05000338

G FOR

-

.

..

REPORT DETAILS

1. Persons Contacted

Licensee Employees

  • E. Harrell, Station Manager
  • G. Smith, Assistant Station Manager
  • R. Hardwick, Manager, Nuclear Programs and Licensing
  • L. Silman, Station Quality Assurance
  • G. Flowers, Station Licensing
  • G. Mocarski, Station Loss Prevention Supervisor
  • R. Anderson, Station Procedures Coordinator

'*W. Stallings, Station Construction

S. Eisenhart, Station Licensing

  • R. Champagne, Project Engineer
  • R. Carroll, Project Engineer
  • L. Warnick, Fire Protection Engineer
  • B. Robbins, Fire Protection Engineer
  • J. Hegner, Nuclear Operations - Licensing
  • H. Carroll, Nuclear Engineer
  • J. Graf, Electrical Engineer

M. Phillips, Electrical Engineer

Other Organizations

  • W. Merritt, Engineering Planning and Management
  • A. Banerjee, Stone and Webster Energy Corporation
  • J. Bonner, C&GNA Energy Services,.Inc.
  • C. Sinopoli, TENERA Corporation

NRC Resident Inspector

  • M. Branch
  • Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on September 13, 1985,

with those persons indicated in paragraph 1 above. The inspectors described

the areas inspected and discussed in detail the inspection findings. No

dissenting comments were received from the licensee.

a. Unresolved Item 338, 339/85-24-01, Review of North Anna Power Station,

Appendix R, Reanalysis and Fire Protection Program, paragraph 5.

b. Unresolved Item 338, 339/85-24-02, NRC/NRR Review of North Anna Power

Station, Appendix R, -Fire Protection Safe Shutdown Methodology,

paragraph 5.a.(1).

a

-.

>

.

2

c. Unresolved Item 338, 339/85-24-03, Review of Seismic Gap Fire Barrier

Penetration Seals, paragraph 5.a.(1).

.

d. Deviation Item 338, 339/85-24-04, Installed Penetration Seals Are Not

In Conformance With Approved Tested Configuration, paragraph 5.a.(2).

e. Unresolved Item (338, 339/85-24-05), Re-entry Into Fire Areas to

Perform Appendix R Hot Standby Shutdown Functions, para' graph 5.a.(5).

f. Unresolved Item (338, 339/85-24-06), Submittal and Review of an Exemp-

tion Request from Providing a Suppression and Detection System in the

Area of Valves M0V.11158 and MOV 2115B in Fire Area 11, paragraph

5.a.(5).

g. Inspector Followup _ Item (338, 339/85-24-07), Verification of Fire

Resistance Rating of Fire Dampers .Between Switchgtar Rooms, paragraph

5.b.(4).

h. Inspector Followup Item (338, 339/85-24-08), NRC Review of Completed

Appendix R Fire Protection Modifications, paragraph 5.b.(11).

i. Unresolved Item (338, 339/85-24-09), Review and Resolution of

Appendix R. Exemption Requests, paragraph 5.c.

J. Inspector Followup Item (338, 339/85-24-10), Appendix R, Plant Shutdown

Components Are Not Included in the Technical Specifications,

. paragraph 5.d.

k. Unresolved Item . (338, 339/85-24-11), Licensee's Re-evaluation of

Conduit Penetration of Fire Barriers to Determine if Penetrations Are

Properly Sealed, paragraph 5.e.(1)(c).

,

1. Unresolved Item (338, 339/85-24-12), Substandard Fire Barrier Penetra-

tion Seals, paragraph 5.e.(2)(a).

m. Inspector Followup Item (338, 339/85-24-13), Sensitivity Calibration Is

Not Included As Part of Smoke Detector Maintenance Program, paragraph

5.e.(3)(a).

n. Inspector Followup Item (338, 339/85-24-14), Licensee to Revise Pre-

Fire Plans to Address Inadvertent Application of Suppression Agents to

Redundant Equipment, paragraph 5.e.(3)(b).

o. Unresolved Item (338, 339/85-24-15), Direct Reading of RWST Level Not

Available Outside the Control Room, paragraph 7.c.(1).

The licensee did not identify as proprietary any of the materials provided

to or reviewed by the inspectors during this inspection.

, ., _. _ - _

-

.

3

3. Licensee Action on Previous Enforcement Matters

a. '(Closed) Unresolved Item (338, 339/85-15-01), Battery Maintenance for

Remote Shutdown Instrumentation' Monitoring Panel in Fuel Building. The

batteries for the remote instrumentation panel are not required. Power

for this panel is supplied from an emergency bus of each unit and these

batteries are to be removed. This item is closed.

b. The following items were reviewed as part of this Appendix R inspection

and are considered resolved except as noted in paragraph 5:

(1) (Closed) Unresolved Item (338, 339/83-25-01), Re-evaluation of

Fire Protection Requirements for Charging Pumps.

(2) (Closed) . Unresolved Item (338, 339/83-25-02), Re evaluation of

Fire Protection Requirements for Component Cooling Pumps.

(3) (Closed) Unresolved Item (338, 339/83-25-03), Re-evaluation of

Fire Protection Requirements for Reactor Building.

(4) (Closed) Unresolved Item (338, 339/82-25-04), Repair Cable for RHR

Pumps Not Available.

c. (Closed) Unresolved Item (338/80-42-01 and 339/80-39-01), Fire Hose Not

Provided at Each Hose Connection Within Reactor' Building. The Techni-

cal Specifications have been revised to indicate that the hose connec-

tions within containment are not equipped with fire hose. Fire hose

and miscellaneous fire brigade equipment are stored in cabinets adja-

cent to the-personnel hatch for each containment. This item is closed.

d. (Closed) Unresolved Item (338/80-42-04 and 339/80-42-04), Substandard

Fire / Smoke Detector Installation. The licensee has either upgraded the

fire detection system to meet the requirements of NFPP-72E, Automatic

Fire Detectors, or provided an engineering justification to indicate

that the installed systems meet the intent of NFPP-72E or the NRC

guidelinos. This item is closed.

4. Unresolved Items

Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involvo violations or devia-

tions. New unresolved items identified during this inspection are discussed

in paragraphs 5.a, 5.b, 5.c, 5.e, and 7.c.

5. Compliance with 10 CFR, Appendix'R, Sections III.G. and III.L.

By letter dated June 22, 1982, Virginia Power provided their original

response to Appendix R for the North Anna facility. Additional information

was. submitted on September 30, 1982, and on this basis, the NRC issued a

Safety Evaluation Report (SER) dated November 18, 1982, for North Anna.

- .

4

Subsequent to the SER, the NRC issued Generic Lettar 83-33. In response to

this Generic Letter, Virginia Power commenced an Appendix R reanalysis. For

the North Anna Power Station this reanalysis consists of seven chapters

contained in two volumes. Volume I was submitted to NRC/NRR by letter dated -

March 8,1985 (Serial No.85-114). Volume II was submitted by letters dated

May 1, 1984 (Serial No. 231) and October 31, 1984 (Serial No. 2318).

Generic Letters 83-33 and Draft 85-01 and other interpretive documents were

used as guidance for their reanalysis effort. At the time of the inspec-

tion, the licensee's revised fire hazards and safe shutdown reanalysis had

not been reviewed or approved by NRR.

Pending review and aeproval of the licensee's revised fire hazard and safe

shutdown reanalysis by NRC/NRR, this item is identified as Unresolved Item

(338,339/85-24-01), Review of North Anna Power Station, Appendix R, Re-

analysis and Fire Protection Program.

Therefore, an inspection of the licensee's reanalysis and revised alterna-

tive shutdown methodology was conducted to determine if the protection

features provided for structures, systems, and components important to safe

shutdown at North Anna Units 1 and 2 were in compliance with 10 CFR 50,

Appendix R, Sections III.G. and III.L. The scope of this inspection deter-

mined if the fire protection features provided for identified essential safe

shutdcwn 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.

Safe Shutdown Capabilities

In order to ensure safe shutdown capabilities, where cables or equipment of

redundant trains of systems necessary to achieve and maintain hot standby

conditions are located within the same fire area outside the primary contain-

ment, 10 CFR 50, Appendix R, Section III.G.2 requires that one train of hot

standby systems be maintained free of fire damage by one of the following

means:

Separation of cables and equipment and associated nonsafety circuits of

redundant trains by a fire barrier having a three hour rating;

Separation of cables and equipment and associated nonsafety circuits of

reduadant trains by a horizontal distance of more than 20 feet with no

intervening combustibles or fire hazards. In addition, fire detectors

and an automatic fire suppression system shall be installed in the fire

area;

Enclosure of cables and equipment and associated nonsafety circuits

of one redundant train in a fire barrier having a one hour rating. In

addition, fire detection and an automatic fire suppression system

shall be installed in the fire area; or,

Where the protection of systems whose function is required for hot

standby does not satisfy the above requirements or Section III.G.2,

alternative or dedicated shutdown capabilities independent of cables,

- .

5

systems, or components in the area, room, or zone under consideration

shall be provided in accordance with 10 CFR 50, Appendix R, Section

III.G.3 and III.L. In addition, Section III.G.3 requires that fire

detection and fixed suppression be installed in the area, room, or zone

under consideration.

On the basis of the above ' Appendix R criteria, the inspectors made an

inspection of cabling and components associated with the Chemical Volume and

Control- System, Emergency Electrical Power Supply Systems, Auxiliary Feed-

water System, Main Steam System, Service Water System, Reactor . Coolant

System, Support Ventilation Systems, Plant Process Monitoring Instrumenta-

tions, and. Emergency Lighting / Communications Systems.

a. Separation / Fire Protection for Safe Shutdown Systems and Components

Based on the licensee's Appendix R Reevaluation, Virginia Power has

identified 47 fire areas at North Anna Power Station. These fire areas

are listed in Chapter 2, Table 2 of the Fire Protection Reevaluation

Report and illustrated in drawings 11715-FAR 200 through 214.

Within the above areas, the licensee has performed a cable separation

analysis for identified essential safe shutdown systems and components

required to achieve hot standby and cold shutdown. The licensee has

. identified 27 fire areas which contain safe shutdown equipment and/or

cables. .The results of the licensee's cable separation analysis

indicate that a fire in 12. plant areas could potentially cause damage

.to both trains of safe shutdown functions thus requiring alternative

shutdown capability. Alternative shutdown is required in the following

12 fire areas:

-

Fire Area 2, Control Room

-

Fire Area 3-1, Unit 1 Cable Vault and Tunnel

-

Fire Area 3-2, Unit 2 Cable Vault and Tunnel

-

Fire Area 6-1, Unit 1 Emergency Switchgear Room

-

Fire Area 6-2, Unit 2 Emergency Switchgear Room

-

Fire Area 11, Auxiliary, Fuel, and Decontamination Buildings

-

Fire Area 14B-1, Unit 1 Motor-Driven Auxiliary Feedwater Pump Room

-

Fire Area 14B-2, Unit 2 Motor-Driven Auxiliary Feedwater Pump Room

-

Fire Area 15-1, Unit 1 Quench Spray Pump House and Safeguard Area

-

Fire Area 15-2, Unit 2 Quench Spray Pump House and Safeguard Area

-

Fire Area 17-1, Unit 1 Main Steam Valve House

--

-

.

6

-

Fire Area 17-2, Unit 2 Main Steam Valve House

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 and III.G.3.

Included in the review was an evaluation of the acceptability of the

barrier or onclosure construction configuration as a fire rated barrier

as used in the plant to separate fire areas. 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, the cable routings for redundant safe

shutdown components / functions, alte native shutdown capabilities, and

the fire protection features afforded these areas were inspected:

(1) Fire Areas 3-1 and 3-2, Units 1 and 2 Cable Vault and Tunnel,

Elevation

Safe Shutdown Train A Train B

System / Function Fire Area / Zone Raceway / Conduit Raceway / Conduit

Chemical Volume and

Control / Makeup Charging

Charging Pumps

1-CH-P-01A 3-1 1AH9140A

1-CH-P-01B 3-1 ITC058P

1TC057P

2-CH-P-01A 3-2 2AH9140A

2-CH-P-01B 3-2 2AH914PA

Emergency Power / 3-1 IWC002P01 1CK0780B

Diesel Generator ICK036PA 1CK955PF

Fuel Oil Transfer

Pumps 3-2 2CK946PB1 2CK946PF

A fire in either of the Units' Cable Vault, and Tunnel area could

result in the loss of power and control cables for both trains of

the Chemical Volume and Control System (CVCS) Charging Pumps, the

charging pump suction valves from the Refueling Water Storage Tank

(RWST).and the emergency diesel generator fuel oil transfer pumps

for that respective affected unit. The licensee stated that the

CVCS has been designed with a manually operated cross connection,

_-

.

7

between the Unit 1 and Unit 2 charging pumps discharge manifolds.

This manual crosstie enables either set of pumps to feed both

units in case of a fire which may affect both trains of one unit

in the affected fire area. Likewise, the licensee stated that for

a fire .in Fire Area 3-1 (causing loss of all Unit 1 emergency

diesel- generators), the emergency diesel generators 2H and 2J

would be available to supply necessary power to the Unit 2 Emer-

gency Switchgear Room, thus providing power to the alternative

shutdown systems required to shut down Unit 1.

This alternate shutdown scheme for fire utilizing system crossties

and the unaffected units emergency power systems is included in

Virginia Power's revised Appendix R reanalysis submitted to

NRC/NRR by letter dated March 8, 1985. Pending NRC/NRR review of

this shutdown methodology,. this is identified as Unresolved Item

(338,339/85-24-02), NRC/NRR Review of North Anna Power Station,

Appendix R, Fire Protection Safe Shutdown Methodology.

The inspectors performed a walkdown of Fire Areas 3-1 and 3-2 and

verified that they were separated from adjacent fire areas by

equivalent three hour rated construction except that the fire

barrier walls between the Cable Vault and Tunnel areas and the

Auxiliary Building, Fire Area 11, at Elevation 259'-6" contain a

l space gap (to allow for seismic event movement) where it abuts the

containment. The filler material in the seismic gap appeared to

be combustible styrofoam. The vertical gap space is covered by an

angle iron attached to the wall. This configuration is typical

throughout the plant and may not provide the required three hour

fire tested barrier rating. The licensee provided an evaluation

addressing this item and identified the fire areas where these

configurations are located. This item is identified as Unresolved

Item (338, 339/85-24-03), Review of Seismic Gap Fire Barrier

Penetration Seals; pending NRR review of the revised North Anna

fire hazards analysis and evaluations.

In addition, the inspectors noted that the fire door frame assem-

blies to Doors 554-5 and 554-9 from the Unit 1 and Unit 2 cable

tunnels to the respective Emergency Switchgear Rooms (Fire Areas

6-1 and 6-2) were not labeled for fire door use. This item is the

subject of Exemption Request #16. Refer to paragraph No. 5.b. for

a discussion of this item.

The inspectors verified that early warning ionization type fire

detectors were provided in the area of Fire Areas 3-1 and 3-2.

Also, heat detectors are provided which actuate a total flooding

low pressure CO 2 system for the areas. In addition, the inspec-

tors verified that the sprinkler systems protecting these fire

areas provided full area coverage. The sprinkler systems protect-

ing these areas are a manual open head sprinkler system for

protection of cable trays in the high ceiling upper levels of the

rooms and a manual closed head sprinkler system in the lower area

c

.

.

8

to provide floor coverage. These systems are provided as manual

backup systems to the primary automatic carbon dioxide suppression

system.

(2) Fire Areas 6-1 and 6-2, Emergency Switchgear Rooms and Instrumenta-

tion Rack Rooms.

Safe Shutdown Train A Train B

. System / Function Fire Area / Zone Raceway / Conduit Raceway / Conduit

Chemical Volume and

Control System /

Charging Pumps

1-CH-P-01A 6-1 1AH9140A

ITC0330

1-CH-P-018 6-1 1AH914PB

ITC034P

-1-CH-P-01C 6-1 ICC0020D

2-CH-P-01B 6-2 2AH9140A

2TCC0330

'2TC0190

2-CH-P-01B 2AH914PA

2TC027P

2CC021PG

2-CH-P-01C 2AH947GA

Auxiliary Feedwater

-System / Motor-Driven

Auxiliary Feeowater

Pumps

1-FW-P-03A 6-1 1CH0030F

ICC03308

1-FW-P-038 6-1 1CC020PH

ICH946PA

2-FW-P-03A 6-2 2CH0020E

2CC0290E

2-FW-P-038 6-2 2CH947PC

2CC025PD

.. .

9

Emergency Power System /

_

(Diesel Generator Fuel

Oil Transfer Pumps)

1-EG-P-1HA 6-2 1CK9460E

'

1-EG-P-1JA 6-1 1CK946PB

1-EG-P-2HA 6-2 2CK946001

1-EG-P-2JA 6-2 2CK011PB'

2TK011P

2TK009P

2-EG-P-2HB 6-2 2DK0020A1

2-EG-P-2JB 6-2 2TK010P

2CK010PG

Service Water System /

Service Water Pumps

1-SW-P-01A 6-1 1DH0020B1

1CC0230C

1-SW-P-01A 6-1 IDH002PB1

ITC035P

-2-SW-P-01A 6-l' 2CC0300H

2-SW-P-018 6-1 2CC029PE

Auxiliary Service

Water Pumps

1-SW-P-04 6-1 1CH94600

1TC0340

2-SW-P-04 6-2 2CHC94700

2TC0270

2TC0260

A fire in either Fire Area 6-1 or 6-2 can result in the loss of

cabling .and functions affecting the CVCS charging pumps, motor

driven auxiliary feedwater pumps, and the emergency diesel genera-

tor power system for the affected Unit. The licensee has provided

. alternative shutdown methodology as described in previous para-

graph 5.a.(1) for the CVCS charging pumps and the diesel

generators.

I

.

l

.

l

_

10

A 100% capacity turbine-driven auxiliary feedwater pump is avail-

able on loss of the two motor driven pumps. The inspectors

verified that the turbine-driven auxiliary feedwater pumps located

in Fire Areas 14A-1 and 14A-2 are independent of the fire areas of

concern (Fire Areas 6-1 and 6-2). Manual throttling of the

turbine-driven auxiliary feedwater pump discharge flow valve is

required.

The inspectors reviewed the fire area boundaries provided to

separate Fire Areas 6-1 and 6-2 from each other and other adjacent

plant areas such as Fire Area 8 (Turbine Building) and Fire Areas

3-1 and 3-2 (Cable Vault and Tunnel). Section 8.3 of the North

Anna Power Station, FSAR states that, "Dow Corning Q3-6548 RTV

Silicone Foam is used for the fire stop seals. The foam is used

in conjunction with Johns Manville Cerafiber and Cerablanket or its

equal as the damming material and is left in place."

During their walkdown, the inspectors noted that the conduit fire

stop penetration seals identified as ICK0790I, ICK0790D, and

ICK050PF, located in the wall that separates Fire Area 6-1 from

Fire Area 8 did not have the fire seal damming materials in place.

In addition, the inspectors reviewed the licensee's Silicone Foam

penetration sealing specification No. NAS-1014 dated October 15,

1980. .Section 1, paragraph 9, line 6.36, states that the Cera-

fiber or Cerablanket material is not to be removed as it is part

of the permanent seal. This configuration does not conform to the

FSAR commitments to the NRC. This discrepancy was also noted in

other plant fire areas and is identified as Deviation Item (338,

339/85-24-04), Installed Penetration ~ Seals Are Not In Conformance

With Approved Tested Configurations. During the inspection, the

licensee reviewed the penetration seals in question and determined

that a minimum nine inch depth of RTV Silicone Foam was provided

in each seal. Based on this depth of foam, the seals can be

considered acceptable for protection for a limited fire condition.

Although the seal damming material was not in place, the seals are

not considered to be in a fully degraded condition, therefore, a

limiting condition for operation (LCO) was not issued at the time.

The licensee is to investigate this further and will take the

appropriate corrective action.

During the fire barrier walkdown for Fire Area 6-2, it was also

noted that no fire damper was installed in the main ventilation

duct which is routed through the fire area barrier wall from the

Unit 2 chiller room (Fire Area 8) to the Unit 2 Emergency Switch-

gear Room (Fire Area 6-2). The licensee stated that in lieu of a

barrier fire damper, the ventilation ductwork was enclosed in a

three hour fire barrier. The inspectors reviewed engineering

Design Coordin. . ion Report Nos. CED 10070-R-2 and 10070-T-2 for

the installation. The licensee's reports indicate that the fire

.- .-- .

-

.-

. .

11

barrier configuration for the duct enclosure is similar to Under-

writers Laboratories tested Design No. X306 for protection of

steel column assembly. The licensee stated that this item is

discussed in the North Anna SER dated February 1979 and is also

the subject of Exemption Request No.13. Refer to paragraph 5.b.

of this report for a discussion of this item.

In addition, the inspectors verified that early warning smoke

detectors and fixed manual Halon 1301 fire suppression system

were provided in Fire Areas 6-1 and 6-2. The inspectors reviewed

the licensee's design basis for the Halon suppression system, the

fire detector locations and the licensee's evaluation (No.11) and

.

justification for .the smoke detector locations in these area

which do not meet the specific requirements of NFPA 72E as related

to detector placement in ceiling structural beam pc kets. Howev-

er, based on the review of the licensee's design basis, detector

evaluations, and our walkdown of the fire areas, the fire detec-

tion and suppression systems provided for these areas appear

adequate.

(3) Fire Areas 9A-1, 9B-1, 9A-2, 9B-2, Emergency Diesel Generator

Rooms

Safe Shutdown Train A Train B

System / Function Fire Area / Zone Raceway / Conduit Raceway / Conduit

Emergency Electrical

Distribution System /

Emergency Diesel

Generators-(E.D.G.)

EDG-1H 9A-1 ITH0040

1DH001081

10H0010A1

EDG-1J 9B-1 ITH002P

IDH001PB3

IDH001PA3

EDG-2H 9A-2 2TH0010

2DH0010B2

2DH0010A2

EDG-2J 9B-2 2EGPCPH001

2DH001PB4

2DH001PAA

Emergency Diesel

Generator Fuel Oil

Transfer Pumps

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

.

12

9A-1 ITC0720

1CC9020B

1CC9020C

98-1 1CC903PD

ITC038P

ICC933PE

The inspectors performed a walkdown and verified that Fire Areas

9A-1, 9B-1, 9A-2, and 9B-2 were separated by equivalent three hour

rated construction from each other and from adjacent Fire Area 8

except that the fire doors from the four emergency diesel genera-

tor rooms to the turbine building are not of labeled construction.

These doors are the subject of exception request No.16. See

paragraph No. 5 b. for a discussion of this item.

(4) Fire Areas 10A and 108, Emergency Diesel Generator Fuel Oil Pump

Rooms

Safe Shutdown Train A Train B

System / Function Fire Area / Zone Raceway / Conduit Raceway / Conduit

Emergency Power System /

Emergency Diesel Generator

Fuel Oil Transfer Pumps

1-EG-P-1HA 10A 1DK001083

1-EG-P-1JA 10K003PB3

2-EG-P-2HA 2DK0020B3

2-EG-P-2JB 2DK004PB3

1-EG-P-1HB 10B 10K0010A3

1-EG-P-1JB 1DK003PA3

1-EG-P-2HB 20K0020A3

1-EG-P-2JB 2DK004PB3

A fire in either Fire Area 10A or 10B can result in loss of

cabling or equipment for both trains of a single set of emergency

diesel generator fuel oil transfer pumps. However, a redundant

alternate set of pumps and power cabling are provided in the other

unaffected fire area, thus providing the required emergency diesel l

generator power function for operation or shutdown of the affected '

unit.

The inspectors performed a walkdown of Fire Areas 10A and 10B and

verified that they were separated from each other by equivalent

three hour rated construction. The inspectors verified that early

l

- a

. .

13

warning ' heat and smoke . detection and a full area automatic high

pressure C0 2 fire suppression system were provided in each of the

fire areas.

(5) Fire Area 11, Auxiliary, Fuel, and Decontamination Buildings

Safe Shutdown Train A Train B

System / Function Fire Area Raceway / Conduit Raceway / Conduit

Chemical Volume 1

and Control System /

Charging Pumps

1-CH-P-01A 11 1AH9140A

1-CH-P-01B 1AH001PA

2-CH-P-01A 11 2AH9140A

2-CH-P-04.. 2AH914PA

Train C

Swingrumps Raceway / Conduit

1-CH-P-01C 11

1AH914GA

2-CH-P-01C 2AH947GA

(Suction Valves

e,o RWST)

H0V-1115B 11 1CK026PK

1TK026P

MOV-11150 11 1TK0680

MOV-2115B 2CK028PU

2CK028PU

2TK028P

'

Component Coolirg

Water System For

Cold Shutdown /

Component Cooling

Water Pumps

1-CC-P-01A 11 1AH9140B

1-CC-P-01B 1AH914PB

2-CC-P-01A 2AH9140B

2-CC-P-01B 2AH914PB

Fire Area 11 consists of the Auxiliary, Fuel, and Decontamination

Buildings which are common for both Units 1 and 2.

_ _ - _ - _ _ _ - _ _ _ _ _ _ _ _ _

.

,

I

'

14

The Fuel Building portion of Fire Area 11 contains the Auxiliary

Monitoring Panel which is to be utilized given fire in the Control

Room, Emergency Switchgear Rooms, or Cable Vault / Tunnel. No safe

-shutdown equipment is located in the Decontamination Building

portion of Fire Area 11.

The Auxiliary Building portion of Fire Area 11 contains six

charging pumps, four CCW pumps, and the associated cabling and

valves required for safe shutdown.

The Auxiliary Building is a four story structure consisting of the

244 ft. 6 in., 259 ft. 6 in., 274 ft. O in., and 291 ft. 10 in,

elevations. The CCW and charging pumps are located on the 244 ft.

6.in. elevation, with the CCW pumps in the main open floor area of

this elevation. Two charging pumps and two CCW pumps are required

to bring both units to cold shutdown (one charging hot standby and

one CCW pump (cold shutdown) per unit). The charging and CCW pump

cabling is located on the 244 ft. 6 in. and 259 ft. 6 in, eleva-

tions of the Auxiliary Building.

An inspection was made of the charging pumps and CCW pump areas to

determine what separation and protection was provided the systems

and components as described in the Fire Hazards and Safe Shutdown

Analysis.

The charging pumps are located side by side in separate cubicles

in the 244 ft. 6 in. elevation with access availabie through an

open hatch from the 259 ft. 6 in, elevation.

The power feeds for the charging pumps rise out of their respec-

tive cubicles and run in a northerly direction on the 259 ft.

6 in. elevation prior to exiting Fire Area 11 through the north

wall.

The charging pump power cables are arranged such that tL9 three

feeds for Unit 1 pumps rise up and run north on the easte'n side

of the Auxiliary Building while the remaining Unit 2 power cables

rise up and run north on the western side of the building. Once

the power cables exit the pump cubicles, the three Unit 2 (Train A

and B and swing) power cables approach within about one foot of

each other near the Unit 2B (Train B) charging pump access open-

ing. On the Unit I side, the pump IC (swing) power cable was to

within about one foot of the IB (Train B) pump cable. These two

cables run east until they near the pump 1A (Train A) power cable.

In the vicinity of the access hatches, the Unit 2 and Unit 1

cables approach to less than 20 foot separation.

The licensee has provided a TSI Inc. one hour cable enclosure wrap

for the Unit 1C (swing) charging pump power cable that extends

from the exit point of the pump cubicle until it achieves approxi-

mately 22 foot horizontal separation distance from the closest

.

'

. .

15

Unit 2A (Train A) charging pump power cable. Although this

barrier application was not continuous throughout the fire area,

the barrier included fireproofing of the load-bearing structural

steel supports which support the cable fire bar.rier enclosure

assembly. The completed fire barrier enclosure appeared to. be

installed in accordance with the design limitations imposed on the

TSI Thermolag Fire tested configurations.

A fire in this area could result in the loss of the CVCS charging

pumps and the suction. valves to the Refueling Water Storage Tanks

(RWST), MOV-1115B and MOV-21158. The licensee proposes to use the

manual cross-connect of the unaffected unit charging pumps. In

the event of a fire tnat disables all charging pumps of one unit,

the two normally closed cross-connect valves (1-CH-550 and

2-CH-408) and alternate RWST suction valves (MOV-11158 and

MOV-21158) are manually opened by an operator who re-enters the

fire area within less than a one hour time frame. This alterna-

tive shutdown capability is not fully physically or electrically

independent of the fire area of concern.

The licensee nas provided an engineering evaluation, for justifi-

cation of these operator actions. Pending NRC/NRR review, this is

identified as Unresolved Item (338,339/85-24-05), Re-entry Into

Fire Areas to Perform Appendix R Hot Standby Shutdown Functions.

The charging pump suction valves (MOV-11158 and MOV-21158), in the

lines from the refueling water storage tank, may be lost due to a

fire outside the charging pump cubicles. These valves are normal-

ly closed and would be required to be open in order to perform a

cooldown. However, the opposite unit's charging pumps are used

for both units since they are cross-connected on the discharge

side. The cabling for the Unit I valve (MOV-1115B) and the

alternate Unit 2 valve (MOV-21158) is routed in opposite sides of

the Auxiliary Building and is separated by greater than 20 feet.

Both the valves and their cabling are located in areas of concen-

trations of cabling on elevations 244'-6" and 259'-6" of the

Auxiliary Building. Both valves and their cabling appear to be

located within 20 feet of major aisles on each elevation. An

automatic suppression and detection system is not provided in the

fire area, room, or zone under consideration for these alternative

shutdown cabling and components as required by 10 CFR 50,

Appendix R, Section III.G.3. The licensee stated that a revised

Exemption Request No. I would be submitted which will include a

III.G.3 exemption from a suppression and detection system in these

areas. Pending the submittal and review of the revised exemption

request, this is identified as Unresolved Item, (338,

339/85-24-06), Submittal and Review of an Exemption Request from

Providing a Suppression and Detection System in the Area of Valves

MOV-11158 and MOV-2115B in Fire Area 11.

. .

16

The inspectors reviewed the automatic sprinkler systems installa-

tion on portions of 244'-6" and 259'-6" elevations of Fire Area 11

around the charging pumps cables. These systems appear to provide

adequate coverage except as noted above and appear to be free of

obstructions.

(6) Fire Area 12, Service Water Pump House

Safe Shutdown Fire Train A Train B

[ stem / Function Area / Zone Raceway / Conduit Raceway / Conduit

Service Water

System / Service Water

Pumps

1-SW-P-01A 12 10H0020B5

1-SW-P-01B 12 1DH002PB5

2-SW-P-01A 12 20H0020A5

2-SW-P-01B 12 2DH003PA5

A fire in this area could result in the loss of both trains of the

Service Water Pumps. The service water system is common to both

units. For a fire in this area, the Auxiliary Service Water Pumps

located 'in a separate fire area (Fire Area 13) located in the

intake -structure would be used to supply service water for safe

shutdown. The inspectors verified that the alternative auxiliary

service water pumps were both physically and electrically indepen-

dent of Fire Area 12. In addition, the inspectors verified that

automatic fire detection system was provided in Fire Area 12;

however, no automatic fire suppression system is provided for this

area. This is the subject of an exemption request. Refer to

paragraph 5.b. of this report for a discussion of this item.

(7) Fire Areas 14A-1 and 14A-2, Units I and 2 Turbine Driven Auxiliary

Feedwater Pump Room; Fire Areas 148-1 and 14B-2, Units 1 and 2

Motor Driven Auxiliary Feedwater Pump Rooms

Safe Shutdown Fire Train A Train B

System / Function Area / Zone Raceway / Conduit Raceway / Conduit

Auxiliary Feedwater

System / Motor Driven

Feedwater Pumps

1-FW-P-03A 14B-1 1CH9970A

1-FW-P-03B 14B-1 1CH997PA

IDH018PA1

.

.

17

2-FW-P-03A 14B-2 2CH9970A

2-FW-P-03B 14B-2 2CH977PA

A fire in either Fire Area 14B-1 or 14B-2, the Motor Driven

Auxiliary _ Feedwater Pump Rooms, could result in the loss of the

Auxiliary Feedwater System Motor-driven pumps. A 100% capacity

turbine driven auxiliary feedwater pump is provided for each unit

on loss of the two motor-driven pumps. Alignment of the turbine

driven pump, however, requires operator actions to be accomplished

within 30 minutes within the fire affected motor driven auxiliary

feedwater pump room. This alternative shutdown capability is

therefore not independent of the fire affected area and also the

- fi r'e area must be re-entered within 30 minutes time. This is

another example of Unresolved Item 338, 339/85-24-05.

In addition, manual operator actions may be - required in the

turbine driven auxiliary feedwater pump room to establish venti-

lation systems and monitor local indication of the feedwater

suction pressure in order that monitoring of the emergency conden-

sate storage tank level can be accomplished. The inspectors

'terifiad that automatic fire detection systems were provided in

the feedwater pump rooms and that each room was separated from

cther areas by a three hour rated fire barrier.

An Exemption Request (Nurber 5) has been submitted by the licensee

for lack of a fixed fire suppression system in the motor driven

aux liary feedwater pump rooms.

(8) Fire Areas 15-1 and 15-2, Units 1 and 2 Quench Spray Pump Houses

-

and Safeguards Areas

Safe Shutdown Fire Train A Train B

_ System / Function Area / Zone Raceway / Conduit Raceway / Conduit

Auxiliary Feedwater System /

Motor Driven Auxiliary

Feedwater Pumps

1-FW-P-03A 15-1 1CH9430C

1-FW-P-03B 15-1 1CH943PC

2-FW-P-03A 15-2 2CH9430C

l

2-FW-P-03B 2CH943PC

Process Monitoring System /

Steam Generator Pressure

_ _ _ _ . _ . . _ _ _

.

.

18

Instrument Cables

Instrument Trans- 15-2 20X016W01

mitter P4-2474 JB-1003-2

2CX016WC

A fire in this area could cause loss of the motor-driven auxiliary

feedwater pumps. The 100% capacity turbine driven auxiliary

feedwater pump is available for use as an alterrative shutdown

capability. The turbine driven pump is located in a separate fire

area. Also a fire in this area could disable the steam generator

pressure transmitters for process monitoring in the control room

and the auxiliary shutdown panel. The licensee proposes to use

local pressure indicators located in a separate fire area, the

Main Steam Valve House, Fire Area 17-1 and 17-2.

A fixed fire suppression system is not provided in either Fire

Area 15-1 or 15-2; however, the inspectors verified that automatic

ionization type smoke detection is provided in both fire areas.

Manual fire fighting capability must be provided by portable

extinguishers and the external yard hydrants and hose houses. The

inspectors reviewed the fire fighting strategy for the Unit 2 area

(2-FS-QS-1 dated January 27, 1982), which indicates that manual

fire hose streams will be accomplished by laying 24 inch hose from

the yard hydrants to the entrance door and coupling a 1 inch hose

for fire fighting inside the area. The licensee has submitted an

Exemption Request #3 for the lack of a fixed fire suppression

system in the Quench Spray Pumphouses. This is identified as

another example of Unresolved Item (338, 339/85-24-09).

(9) Fire Areas 17-1 and 17-2, Units 1 and 2 Main Steam Valve Houses

Fire Areas 17-1 and 17-2 contain the Main Steam Power-0perated

Relief Valves (PORVs) for Units 1 and 2, respectively, of North

Anna Power Station. Each fire area is located in a separate

structure adjacent to the Containment Building (Fire Areas 1-1 and

1-2), the Quench Spray Pump House (Fire Areas 15-1 and 15-2), and

the Cable Vaults and Tunnels (Fire Areas 3-1 and 3-2).

A fire in either Main Steam Valve House can result in the loss of

control of the Steam Generator Power-0perated Relief Valves

(PORVs) from the control room. The licensee proposes to re-enter

the fire area and manually operate the PORVs by handwheels. The

inspectors verified that these fire areas were separated from the

adjacent fire areas by equivalent three hour rated barriers except

that a seismic space gap separates Fire Areas 17-1 and 17-2 from

the Quench Spray Pump Houses (Fire Areas 15-1 and 15-2). This is

another example of Unresolved Item (338,339/85-24-03). The

inspectors verified that automatic fire detectors were provided in

L

. .

19

Fire Areas 17-1 or 17-2; however, no fire suppression systems are

provided for either-area. This is the subject of the licensee's

Exemption Request #4.

Within the areas inspected, no violations and one deviation were

'

identified.

b. Modifications Required to Meet 10 CFR 50, Appendix R

The North Anna 10 CFR 50, Appendix R Report - Volume II, Chapter 6,

identifies a number of modifications required in order for the plant to

meet the requirements of Appendix R, Section III.G. The following

modifications were reviewed by the inspectors during this inspection:

(1) Pressurizer Level Indication and Reactor Coolant System Wide Range

Indication - Modifications I-1 and 2

Pressurizer level transmitters LT-RC1000 and LT-RC2000 and reactor

coolant system pressure transmitters PT-RC1000 and PT-RC2000 for

Units 1 and 2 respectively were installed to provide instrumenta-

tion at_the auxiliary monitoring panel in the fuel building. This

instrumentation is redundant to the normal control room instrumen-

tation. Within the containments, the cabling for the normal

instrumentation and the instrumentation for the auxiliary monitor-

ing panel is separated by less than 20 feet. Modifications

consisting of radiant energy shields were provided within contain-

ment to meet the separation protection requirements of Appendix R,

Section III.G.2 between redundant cable raceways, transmitters,

and associated junction boxes. These modifications were required

to assure that pressurizer level instrumentation would be avail-

able at either the remote panel or control room panel in the event

of a fire within containment. The containment was not accessible

during this inspection; however, the inspectors reviewed the

following work packages and verified that the licensee's QC

organization had accomplished the final QC installation inspection

verification:

Design Final QC

Item Change Package Inspection

Unit 1 Pressurizer Level DCP 84-19 8-15-84

and Reactor Coolant System

Pressure Instrumentation

Unit 2 Pressurizer Level DCP 84-20 10-23-84

Instrumentation

Unit 2 Reactor Coolant DCP 84-25 10-23-84

System Pressure Instrumentation

. .

20

Following installation of the above instrumentation devices, the

pressurizer level instrumentation transmitter for the auxiliary

monitoring panel was found to be inoperative. This device was

tagged out of service on November 24, 1984, which was after the

Unit 2 had started up from the 1984 refueling outage. For addi-

tional information on this item, refer to paragraph 7.

(2) Reactor Coolant System Hot Leg Temperature Indication -

Modification I-3

Reactor coolant system temperature indication was previously

provided at the auxiliary monitoring panel in the fuel building.

The temperature elements are din ctly off the main reactor

coolant hot legs for loops 1 and 2. However, to meet Appendix R,

Section III.G.2, radiant energy shields were required to separate

the redundant cable raceways within containment to assure that hot

leg temperature would be available either in the control room or

auxiliary monitoring panel in the event of a fire within contain-

ment. The containment was not accessible during this inspection,

but the inspectors reviewed work packages DCP 84-23 for Unit 1 and

DCP 84-24 for Unit 2 to verify that this work had been completed.

Unit 1 modification work was completed and final QC installation

inspection verification was conducted by the licensee on

September 6, 1984. Unit 2 modification work was completed except

one of the two hot leg temperature indicators (No. TE-2423) had

not yet been installed. Temperature indication for Unit 2 was

available frem the control room and the second indicator

(No. TE 2413) on the auxiliary monitoring panel. Only one temper-

ature element is required to meet the Appendix R shutdown require-

ments. Temperature indication is available for the two Unit 1

instruments on the auxiliary monitoring panel.

(3) Emergency Communication Upgrade - Modification I-4

Radio communication is used fer the North Anna Appendix R shutdown

scheme. To assure availability of radio communications in the

event of a fire, the communication system was upgraded by provid-

ing three additional repeaters. Repeaters 2-B and 2-BE are

located in the Unit I cable spreading room and Repeater 1-A is

located in the auxiliary building which is a separate fire area.

The licensee completed the functional tests and construction

verification on January 22, 1985. The radio communication system

proved to be satisfactory during the Appendix R shutdown drill

conducted during this inspection.

(4) Fire Damper Upgrade in Emergency Switchgear Room -

Modification I-5

Two I hour rated dampers in the three-hour fire barrier between

the Unit I and Unit 2 switchgear rooms were replaced with three

hour dampers by Engineering Work Request (EWR)84-263. The

a

,

.. .

21

inspectors reviewed the purchase specification and vendors submit-

tal data which indicated that the dampers were " certified" by

Underwriters Laboratories, Inc. (UL) as having a three hour fire

rating. However, the installed dampers are provided with a label

which indicates.that the dampers are rated for only 1h hours. The

licensee has contacted the vendor and the vendor stated that the

installed dampers have been " certified" by UL as meeting both the

lh hour and three hour fire resistant rating. The vendor is to

provide appropriate documentation and correct the label discrep-

ancy for the dampers. This is identified as Inspector Followup

Item (338, 339/85-24-07), Verification of Fire Resistance Rating

of Fire- Dampers Between Switchgear Rooms, and will be reviewed

during a subsequent NRC inspection.

(5) Auxiliary Building Sprinkler System Upgrade - Modification II-1

The power cables for the charging and component cooling water

pumps did not meet the separation requirement of Appendix R,

Section III.G.2. The modification to correct this discrepancy

consisted of providing the following: a one hour wrap for one

train of the charging pumps and component cooling water pumps

power cables until 20 feet of separation was achieved; solid metal

tray covers and fire stops for the intervening cable trays between

the pumps; extension of the sprinkler system on the 259h' eleva-

tion of the auxiliary building; and, additional smoke detectors on

the 244 ' and 259 ' elevations of the auxiliary building. The

inspectors toured the auxiliary building and verified that these

modifications were completed.

(6) Residual Heat Removal Pump Radiant Energy Shields -

Modification II-2

The RHR pumps are located adjacent to each other in the contain-

ment for each unit. To meet the separation criteria of

Appendix R, Section III.G.2 radiant energy heat shields were

-

installed between the redundant pump motors. The containment was

not accessible for inspection; however, the inspectors reviewed

the work packages for this. modification accomplished by DCP 84-21

and DCP 84-22 for Units 1 and 2, respectively. These modifica-

tions were inspected by the licensee's QC organization and veri-

fied to be completed on August 23, 1984 for Unit 1 and

September 25, 1984 for Unit 2.

(7) Emergency Lighting Upgrade - Modification II-3

Extensive emergency lighting modifications have been accomplished.

Refer to paragraph 8 for details on this item.

_

. ,

22

(8) Diesel Generator Control Circuit Isolation - Modification 5

Diesels 1H and 2H have been provided with control circuit isola-

tion capability and the control panels have been incorporated into

the plant shutdown procedures. Some of these procedures were

reviewed during this inspection and found to be satisfactory.

(9) Installation of Containment Cable Tray Bottom Covers and Fire

Stops - Modification III-1

Redundant instrumentation cables inside containment which are

required for shutdown were not provided with the separation

required by Appendix R, Section III.G.2. Bottom cable tray covers

and fire stops were provided by this modification for some cable

trays to provide protection. This work was not inspected since

the containment was not accessible. However, the inspectors

reviewed the work package, EWR 84-376 for Unit 1 and DCP 84-39 for

Unit 2, which indicated that the work had been verified completed

by the licensee's QC inspection organization on July 25, 1984 for

Unit I and on September 25, la84 for Unit 2.

(10) Replace Load Center Fuses - Modification II-2

The electrical system coordination study identified certain fuses

which were required to be replaced to provide proper coordination.

The fuses for the control circuits to the 125V DC distribution

system have been - replaced. This work was accomplished by

EWR 84-328 and was verified completed by the licensee's QC organ-

ization on September 4, 1984.

The fuses associated with the 480/120V control power transformers

are scheduled to be completed by the end of the 1986 refueling

outages. This item is scheduled to be reviewed during a subse-

quent NRC inspection.

(11) Seal Charging Pump Cubicle Penetrations - Modification III-4

Several piping and electrical penetrations in the walls separating

the charging pumps were not sealed. This modification sealed the

open penetrations. The inspectors reviewed work package

EWR 84-331 which required the penetrations to be sealed and noted

that the licensee's QC organization verified that the required

work was completed on January 25, 1985.

Modifications I-6 through I-13 have not yet been completed. An inspec-

tion of these items will be made during a subsequent NRC inspection.

This item is identified as Inspector Followup Item (338,339/85-24-08),

NRC Review of Completed Appendix R Fire Protection Modifications.

.

.. .

23

LWithin the areas inspected, no violations or deviations were

identified,

c. Exemption Requests From 10 CFR 50, Appendix R Requirements

-The North Anna 10 CFR 50, Appendix R Report - Volume II, Chapter 7,.

identifies 24 areas which deviate from the Appendix R requirements. A

justification is provided for the deviation.s and requests for exemp-

tions to the requirements have been made to the NRC. These items are

to be reviewed by NRR. . Pending completion of this review, this is

identified as Unresolved Item (338, 339/85-24-09), Review and Resolu-

tion of Appendix R Exemption Requests,

d. Technical Specifications (TS) For Appendix R Required Features

The remote shutdown panel remote instrumentation, remote diesel genera-

tor' control and instrumentation panel and related components are not

included in the North Anna TS. This item is being referred to NRR and

is . identified as Inspector Followup _ Item (338, 339/85-24-10),

Appendix R, Plant Shutdown Components Are Not Included in the Technical

' Specifications.

e. -Audits of Appendix R Implementation Program

The licensee contracted with Tenera Corporation-Findings to conduct an

' independent audit of North Anna for compliance to Appendix R. Tenera's

audit report of August 21, 1985, identifies six significant findings,

.

'

11 findings, and nine minor findings. Corrective action has been

completed on all of these items except as listed below:

(1) Significant Findings

(a) Emergency Lighting

The audit identified the inadequate emergency lighting for

the control room, filter room and charging pump cubicles.

Exemption requests for these items have been submitted to the

NRC. The -NRC review of these items will be handled by

separate correspondence. This is another example of Unre-

solved Item (338, 339/85-24-09).

(b) Re-entry Into Fire Areas to Perform Hot Standby Functions

l- The licensee proposes to re-enter the charging pump cubicles

i and auxiliary feedwater pump rooms within one hour.following

L a fire to perform hot standby shutdown functions. In - the

,

past, the NRC has not permitted manual actions within a fire

area involved in fire until after at least one hour. This

i

item is to be forwarded to NRC for further evaluation and is

identified as an example of Unresolved Item (338,

339/85-24-05).

l

l

. - , _ -

- . - - , _ . . _ . . . - - - _ _ -

- . - - - .

______ _____ -___ _ _

'

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24

'

,

This item is discussed in paragraph 5 of this report.

(c) Conduit Penetrating Fire Barriers Were Not Sealed

.

The conduit penetrations of fire barriers were identified by

Tenera as not being properly sealed to the fire rating of the

barrier. The licensee has developed criteria to apply to the

conduits which penetrate the plant's fire barriers. This

criteria appears satisfactory. However, sufficient plant

inspections by the licensee has not yet been accomplished to

determine the significance of this finding.

Pending completion of the licensee's evaluation, this item is .

identified as Unresolved Item (338, 339/85-24-11), Licensee's

Re-evaluation of Conduit Penetration of Fire Barriers To -

Determine if Penetrations Are Properly Sealed.

(2) Findings

(a) Substandard Fire Barrier Penetration Seals

The installed fire barrier. penetrations seals using Dow

Corning foam do not meet the design of the installation

configurations which were tested by the Underwriters Labora-

tories Inc. In addition, the fire tests performed on the

installed penetration seal configurations by Virginia

Electric and Power Company (VEPC0) did not include ~ all the

test's acceptance criteria required of Underwriters Labora-

tories. The North Anna penetration seals and fire tests are

described in the Fire Protection Systems Review of April 1,

1977 and Supplement 1 of December 15, 1977 and appear to

have been reviewed and found acceptable by .the NRC/NRR Fire

Protection Safety Evaluation Report (SER) of February 1979.

This item is to be forwarded to NRC/NRR for further evalua-

tion and is identified as' Unresolved Item (338, 339/85-

24-12), Substandard Fire Barrier Penetration Seals, pending

completion of this reevaluation.

(b) Seismic Gap Seal in Fire Barriers

The joint seal in the seismic gap of fire barriers does not

appear to afford three hour fire resistant protection between

safe shutdown components. This item is addressed in the

North Anna Fire Protection Systems Review (Question 16), but

does not appear to be covered by the Fire Protection SER.

This is another example of Unresolved Item (338,

339/85-24-03).

.

-

25

(3) Minor Findings

(a) Smoke Detector Sensitivity Check

The current inspection and test program for the smoke detec-

tor systems does not require the sensitivity for each detec-

tor to be calibrated. The installation code, NFPA-720,

Proprietary Protective Signaling Systems, does not clearly.

specify this calibration and it is not included as a require-

~

ment of the Technical Specifications. The licensee is

reviewing this item to determine the appropriate corrective

action. This is identified as Inspector Followup Item (338,

339/85-24-13), Sensitivity Calibration Is Not Included As

Part of Smoke Detector Maintenance Program, and will be

reviewed during a subsequent NRC inspection.

(b) Fire Brigade Operations

The fire brigade pre-fire plans do not address inadvertent

application of suppression agents to redundant equipment.

These plans are currently being revised to address the

cautions regarding safe shutdown equipment in_ common areas of

the auxiliary building. Completion of these revisions ~ is

scheduled for November 1, 1985. This is identified as

Inspector Followup Item (338,339/85-24-14), Licensee to

Revise Pre-Fire Plans to Address Inadvertent Application of

Suppression Agents to Redundant Equipment, and will be

reviewed during a subsequent NRC inspection.

6. Protection of Associated Circuits

The inspection was conducted to verify compliance with associated circuit

provisions of 10 CFR 20, Appendix R, Sections III.G. and III.L. The empha-

sis 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 non-

safety-related, where there is a common power source with shutdown

equipment and the power source is not electrically protected from the

circuit of concern.

-

.

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26

The' licensee evaluated the fuse. breaker coordination for the Emergency

Power System which consisted of:

(1) 4KV power distribution and emergency generators

-

(2) 480V AC load centers and motor control centers (MCC)

(3) 120V AC instrument panels and inverters

(4) 125V DC distribution buses, emergency batteries and chargers.

The licensee advised that in some cases, coordination between the 4160V

switchgear supply breakers and the down stream 480V load center supply

breakers could not be obtained. The licensee advises that on the loss

of the 4160V Feeder (Emergency Switchgear Room Fire), the affected unit

can be crosstied with the opposite unit piping to use the charging

system of the unaffected unit to safely shut down the damaged unit.

The inspectors reviewed the emergency procedures which cover the loss

of the emergency switchgear room and they appeared adequate.

The inspectors examined the various fuse / breaker coordination studies

-of other portions of the Emergency Power System to verify fuse / breaker

coordination for the worst case fault for each of the 480V load centers

and MCCs, the 120V AC instrument panels and inverters and the 125V DC

distribution buses, batteries and chargers.

The licensee's study resulted in a finding that required changing of

various fuses throughout the system. The inspectors reviewed Electri-

-cal Maintenance Procedure EMP-C-TSR-1, Trouble-shooting and Repair of

Electrical Circuits, and Administrative Procedure ADM-4.0, Procurement

. Document Control which control the replacement and ordering of replace-

ment parts to insure that like parts are used as replacements.

IE Information Notice 85-09, Isolation Transfer Switches and Post-Fire

Shutdown Capability, was issued January 31, 1985. This Notice identi-

fies a potential problem concerning fuses in control circuits that are

common for operation of equipment from the Control Room and Alternate

Hot Shutdown area. A fire in the Control Room could cause these common

fuses to blow before transfer is made to the Alternate Hot Shutdown

area. If the control circuit is needed at the Alternate shutdown area

to energize a piece of equipment and if the fuse (s) blew before trans-

r fer, equipment would not be operable without replacing the blown

fuse (s).

The licensee has completed the engineering modifications for isolation

and transfer to meet the intent of IE Information Notice 85-09. The

following Design Change Packages (DCP) have been developed.

Heat Removal Circuit Isolation for Units 1 and 2.

' DCP 84-64 - Switchgear Room Ventilating Equipment Isolation

DCP 83-23 - Diesel Generator Isolation Unit 1

'

r- .

.

.

27

  • DCP 83-24 - Diesel Generator Isolation Unit 2

DCP 84-63 - Auxiliary Building Fan Modification Units 1 and 2

The installation of the changes required by these DCPs will be complet-

ed by the end of each units' forthcoming refueling outage.

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 nonsafety-related compo-

nents that would adversely affect shutdown capability

(e.g;, RHR/RCS Isolation Valves).

The licensee developed a list of potential spurious operations which

could affect high/ low pressure boundaries. The inspectors reviewed the

licensee's actions for resolving the spurious actuation of the follow-

ing high/ low pressure interface valves:

PCV-1455 Pressurizer PORV

  • PCV-1456 Pressurizer PORV
  • MOV-2700 RHR Suction Isolation
  • MOV--2701 RHR Suction Isolation

A random selection of valves located in various pump suction and

discharge paths were reviewed for methods of control / protection from

spurious operations. The following valve schematic, logic diagrams, or

piping drawings were examined:

  • MOV 1267A&B Charging Pump Suction Header Isolation

M0V 1269A&B Charging Pump Suction Header Isolation

  • M0V 1270A&B Charging Pump Suction Header Isolation
  • MOV 1115B&D Charging Pump Suction Isolation to RWST
  • M0V 1115A&C Charging Pump Suction Isolation to VCT
  • MOV 1286A,B,C Charging Pump Discharge Valves

MOV 1289A&B Charging Pump Discharge Header MOV

  • FCV 1122 Charging Flow Control Valve
  • TV MS111A&B Turbine Driven FW Pump Steam Admission Valves

MOV FW100A,B,C Auxiliary Feedwater MOV Header to Steam

Generator A, B, and C

~

.

.

28

The licensee has developed procedures for taking manual control of

these valves or removing power from them to prevent spurious movement

or cause them to move to their fail safe position. In certain instanc-

es, the power is removed from various feeder boards to prevent spurious

fire induced operations. In certain instances, additional switches

have been designed into the system to permit removal of power from

those valves that are in high-low pressure interface situations. The

switches will be located in areas remote from the feeder board loca-

tions. The licensee has analyzed the spurious operation of valves that

could impact on safe shutdowr. and has developed a plan of action that

should enable either unit to safely shutdown in the event of a fire.

c. Common Enclosure Concern

The common enclosure concern is found when redundant trains are routed

together with a nonsafety circuit which crosses from one raceway or

enclosure to another, and the nonsafety circuit is not electrically

protected or fire can destroy both redundant trains due to inadequate

fire protection means.

The licensee advised that the removal of power from equipment to

prevent spurious signal operations also supports part of the protection

provided for the common enclosure concern. The power interruotion is

accomplished either by breakers, fuses, or opening of supply breakers.

Power and control cables are sized and rated for 600 volts, in which

case a fault should trip the protective device prior to cable jacket

overheating or self-igniting. The licensee has committed to control

intervening combustibles, install fire stops between safe shutdown

cable trays and conduits, and seal all electrical penetrations for safe

shutdown cables through their wall penetrations with fire stops equal

to that required for the wall.

d. Damage Control Measures

Appendix R, Sections III.G.1.b and III.L.5 require fire protection

features to be provided for structures, systems and components impor-

tant to safe shutdown and to be capable of limiting fire damage so that

systems necessary_ to achieve and maintain cold shutdown are 'ree of

fire damage or can be repaired such that the equipment can be made

operable and cold shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Materials for

such repairs are required to be readily available on site and proce-

dures are to be in effect to implement such repairs.

The licensee has in place Emergency Electrical Maintenance Procedures

  1. EEMP-C-RH-01, Installation of Emergency Temporary RHR Motor Feeder

Cable and EEMP-C-EP-11, Rigging of Emergency Ventilation.

The materials required by the above listed procedures are set aside in

a controlled area of the warehouse. The RHR cables are on reels and

!

_ ._

.. .

29

have been lugged to expedite the making of the connections at the

motor, penetration, and breaker. Due to the location of the RHR pumps,

it is .necessary to have two different lengths of cables. The inspec-

. tors examined the storage area. A box containing the required termi-

nating and installation tools and materials is enclosed in a cage with

the cable reels.

The emergency ventilating procedure identifies breakers which may be

used to power the emergency ventilation fans. The fans and the port-

able ducts (elephant trunks) are stored in the special area of the

warehouse also. The fan motors have cables connected so that it will

only be necessary to connect the other cable end to the breaker. The

inspector walked the route that the cable reels and materials will be

taken through the turbine auxiliary buildings. The plan appears to be

well thought out and adequate.

7. Alternative Shutdown Capability

The inspectors reviewed operating personnel training, shift staffing and the

use of abnormal operating and surveillance procedures, as these activities

relate to the alternative shutdown capability. These areas were reviewed to

determine if the licensee's 10 CFR 50, Appendix R Reanalysis contains the

elements described in Section III.L of Appendix R for achieving and main-

~ taining the plant in hot standby conditions with the subsequent capability

to cooldown the plant to cold shutdown conditions.

a. Personnel Training and Shift Staffing

The inspectors reviewed the licensee's_ program for conducting training

on those plant abnormal procedures issued to operate the components,

equipment, and systems designated for use as the alternative shutdown

capability. The licensee has essentially completed initial training

for senior reactor operators (SRO), reactor operators (RO) and

auxiliary operators. Training on the abnormal procedures issued to

operate the alternative shutdown capability includes lecture series,

formal lesson plans, and simulator training. The inspector reviewed

training records and held discussions with shift operating personnel to

verify that training is being received. The licensee has also incorpo-

rated training on these procedures into the on going licensed operator

requalification training programs.

The licensee's normal shift staffing was reviewed to verify that

sufficient operating personnel are available to operate equipment and

systems described in Abnormal Procedure AP-50.1, Control Room Fire.

The review indicated that operating shift crew required by Technical

Specification would be the personnel used to support AP-50.1

operations.

E

  • .

30

The shift operating personnel provided to support the control room fire

abnormal procedure are separate from the operating personnel assigned

to the fire brigade. The licensee has ten other abnormal operating

procedures designed to provide alternative shutdown capability for

other plant area fires such as, emergency switchgear room, cable vault

and tunnel, and auxiliary building. The staffing of operators for

these fire areas would not require operating personnel beyond that

required for a control room fire. Once the fire is extinguished,

additional operating personnel would become available that were

initially assigned to the fire brigade. In addition, the call-in of

operating personnel would also be reporting to the plant as required by

the station emergency plan. Adequate shift staffing was further demon-

strated during a simulated drill of AP-50.1, which began in the main

control room followed by manning the auxiliary shutdown panels in the

switchgear rooms for Units 1 and 2 and other remote stations in the

plant. The drill was concluded when the steps of the procedure

achieved stable hot standby conditions.

b. Abnormal Operating Procedures

The inspectors reviewed several of the licensee's abnormal procedures

designed to operate plant equipment and systems to achieve hot standby

and subsequent cooldown of the plant to cold shutdown conditions. The

procedures were reviewed to verify that Appendix R, Section III.L

requirement as given below have been incorporated into these

procedures.

-

Achieve and maintain hot standby conditions.

-

Achieve and maintain subcritical reactivity conditions in the

reactor.

-

Provide decay heat removal capabilities.

-

Maintain reactor coolant inventory and steam generator inventory.

-

Achieve and maintain cold shutdown conditions.

-

Provide direct readings of the process variables necessary to

control the above conditions.

'

The licensee reanalysis identified 12 fire areas in the plant where

alternative shutdown capability is required and abnormal operating

procedures have been issued for each of these fire areas. The inspec-

tor selected the following procedures from the group for review:

-

AP-50, Revision 3, Fire Protection - Operations Response

-

AP-50.1, Revision 3, Control Room Fire

-

AP-50.2, Revision 2, Emergency Switchgear Room Fire

. _ _ . _ _ _

_ _ _

.

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31

-

AP-50.3, Revision 3, Cable Vault and Tunnel Fire

-

AP-50.4, Revision 2, Auxiliary Building Fire

-

AP-22.7, Revision 2, Loss of Emergency Condensate Storage Tank

-

EP-0, Revision 0, Reactor Trip or Safety Injection

The review indicated that the abnormal procedures contain the necessary

steps to achieve and maintain the plant in hot standby and also to take

the plant to cold shutdown. AP-50.1, Control Room Fire was walked-

through with the shift operating crew to verify that:

-

Communications between various operating stations are adequate and

operable.

-

Identification plates installed on valves, components, and instrumen-

tation agree with that called for in the procedure steps.

-

Lighting at operating. stations appears adequate.

-

Equipment and valves to be operated can be reached and are not

obstructed.

-

Radio handsets, dedicated supplies, keys, hand held lanterns, and

procedures to be used are readily available and the procedures

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 has been received from NRR

to use other means.

Inspector comments identified as a result of reviewing the procedures

and the walk-through of the Control Room Fire Procedures AP-50.1 have

been incorporated into the appropriate procedures by issuing a revi-

sion to the ' procedures. In addition, the licensee is preparing an

administrative procedure that will inventory on a monthly bases the

equipment stored in the Appendix R locker. This inventory will ensure

that equipment is available and maintained in good condition.

c. Surveillance Procedures

As previously noted the licensee has selected normal plant equipment

and systems to provide for the alternative shutdown capability. The

routine surveillance and calibration programs are used to maintain

I

,. 1

L I

. .

32

systems operable as well as the instrumentation and components in-

stalled at the auxiliary shutdown panels in the emergency switchgear

room and the auxiliary / remote monitoring panels located in the fuel

building. Periodic Test (PT) 41.2.1 Auxiliary Shutdown Panel (ASP)

Calibration (every 18 months) and PT 41.1 ASP Monitoring Channel Checks

-(every 31 days) are the procedures used to implement the surveillance

of these panels which is required by Technical Specification 4.3.3.5.

The calibration of the instrumentation on the auxiliary / remote monitor-

ing panels is scheduled through the Instrument Maintenance Procedures

(IMP) Program which specifies the calibration frequency (two years) and

which Instrumentation Calibration Procedure (ICP) is to be used. A

recent revision to Auxiliary Building Log Procedure 1-Log-60 added a

requirement to perform daily checks of the operability status on the

instrumentation in the auxiliary / remote monitoring panels. The licen-

see is also developing Administrative Procedure 20.45, Fire Protection

Surveillance / Maintenance Program which addresses Appendix R require-

ments and equipment.

The auxiliary / remote monitoring panels were originally installed for

10 CFR 50, Appendix A, General Design Criteria 3, Fire Protection

L considerations and is presently used to monitor the process variable

discussed in Appendix R, Section III.L.2.d for several fire areas.

The review of the licensee surveillance / calibration programs and a

visual ' inspection of instrumentation provided at the remote monitoring

panels resulted in the following concerns:

(1) App'endix R, Section III.L.2.d requires that the process monitoring

function shall be capable of providing direct readings of the

process variables that are being used. The NRC issued IE Notice

84-09 dated February 13, 1984, which identified a list of the

minimum monitoring capability for Alternative Shutdown. The

licensee's source of makeup water to the reactor coolant system

-for several fire areas is the refueling water storage tank (RWST).

No direct reading of tank water level is provided outside the

control room, at the remote monitoring panels, or locally at the

tank. Until the licensee has reviewed and provided resolution,

this matter remains an Unresolved Item (338, 339/85-24-15), Direct

Reading of RWST Level Not Available Outside the Control Room.

(2) The auxiliary / remote monitoring panels provide direct reading of

RCS pressure, hot and cold leg temperature, pressurizer level,

steam generator level and source range neutron flux for both

units. During a walkthrough of the panels, it was noted that

Unit 2 pressurizer level indicator LI-RC2000 was pegged high off

scale. A tag on the instrument provided an out of service date of

n

,

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November 1984. The following fire areas and procedures required

the use of the auxiliary / remote monitoring panel and pressurizer

level in particular:

-

AP-50.1 Control Room Fire

-

AP-50.2 Emergency Switchgear Room Fire

-

AP-50.3 Cable Vault and Tunnel Fire

-

AP-50.4 Auxiliary Building Fire

-

AP-50.5 Containment Fire

The licensee identified the following compensatory measures that

were considered to be in effect while the Unit 2 pressurizer level

instrument has been out of service:

-

Fire watches have been maintained in the emergency

switchgear room.

-

Continuous line type heat detection system is installed

under cable trays inside containment that carry the

control room pressurizer level instrument cables.

-

Fixed fire detection and suppression systems are in-

stalled in the cable vault and tunnel area.

The inspectors requested that the licensee review the operational

consideration for conducting a safe shutdown without pressurizer

level indication and the operator actions necessary to ensure that

a water level is maintained in the pressurizer. The licensee

developed an abnormal procedure AP-50.12. Basically, this proce-

dure uses the (CVCS) charging pump and a combination of charging

to the RCS through the normal charging path for a specified length

of time followed by maintaining makeup to the RCS through the

reactor coolant pumps seal injection lines (approximately 1%

increase in level every ten minutes). A specific RCS pressure is

maintained (2000 psig) by slowly controlling cooldown via the

local operation of the steam generator pressure operated relief

valves. The procedure has been evaluated and practiced on the

plant simulator and has been approved for use by the Station

Nuclear Safety and Operating Committee.

On September 23, 1985, a conference call between Region II manage-

ment and North Anna station management was held to discuss the

licensee's compensatory measure concerning the Unit 2 out of service

pressurizer ' level instrument on the auxiliary / remote monitoring

panel. The licensee indicated that a letter would be sent to the

Region, confirming the compensatory measures being taken and the

date for returning Unit 2 pressurizer level instrument to service.

Within the areas inspected, no violations or deviations were

identified.

I

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. _ _ _ _ _ _ _ _ _ _ _ _ _ -

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34

8. Compliance to 10 CFR 50, Appendix R, Section III.J, Emergency Lighting

Emergency lighting units equipped with at least an eight hour battery power

supply are required to be provided in all areas required for operation of

safe shutdown equipment and in access and egress routes thereto.

The inspectors reviewed the licensee's emergency lighting modifications

completed by Design Change No. 84-26. Over 200 additional emergency light-

ing units have been installed throughout the plant. The licensee's opera-

tion, site engineering office, QC, and advisory operations (startup testing)

departments conducted walkdown inspections to verify that adequate emergency

-lighting was provided throughout the plant. Each lighting unit was func-

tionally tested to verify that the units would provide illumination for at

least eight hours. The lighting units provided are Exide Model Nos. 100 and

200, except some areas of the plant such as the emergency switchgear room

are provided with up to approximately 28 lights supplied by an Exide "Cen-

taurus" Model 1-1000 lighting system.

A walkthrough inspection by the inspectors using shutdown procedure

No.1-AP-50.1, Control Room Fire, to identify the required manual operator

actions indicated that sufficient emergency lighting to meet Appendix R,

Section III.J was provided in all areas, except for panel MCC 2H1-2N in the

Unit 2 cable vault, access and egress routes to equipment outside the plant

structures, use of portable lighting units in the seal water filter area and

the use of lighting units in the control room, which are supplied by emer-

gency diesel generators in lieu of battery packs. The lighting provided for

panel MCC 2H1-2N was considered marginal, but the identification tags on the

panel could still be read. To correct this situation, the licensee immedi-

ately generated Engineering Work Request 85-_598 and the installation of

additional lighting units is scheduled to be completed by September 30,

1985. The other three items have been identified by the licensee and

exemptions requests have been submitted to the NRC. The NRC review and

approval of these exemption requests will be handled by separate correspon-

dence. This is another example of Unresolved Item (338, 339/85-24-09).

To assure that the lighting -units will remain functional, the licensee has

implemented Procedures E-11-ELT/M-1 and E-21-ELT/M-2, Emergency Lighting,

which require all of the eight hour emergency lighting units to be inspected and

tested monthly. The procedures required that the lamps be checked for

proper alignment and battery- units and lamps to be verified operable.

Procedures E-11-ELT/C-1 and E-21-ELtT/C-2 are being developed to require

all emergency battery units to be functionally tested for eight hours each

month. These procedures are scheduled to be issued by November 1, 1985.

Within the areas examined, no violations or deviations were identified.

c

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35

9. Compliance to 10 CFR 50, Appendix R, Section III.0 011 Collection System for

Reactor Coolant Pumps

The reactor coolant pumps are required to be equipped with an oil collection

system if the containment is not inerted during normal plant operations.

The oil collection system is to be so designed, engineered, and installed

such that failure will not lead to fire during normal or design basis

accident conditions and .there is reasonable assurance that the system will

withstand the " Safe Shutdown Earthquake." The system is to be adequately

sized and capable of collecting lube oil from all potential leakage sites in

the reactor coolant pump lube oil system. Leakage is to be collected and

drained to a closed container sized to hold the entire lube oil system

inventory. A flame arrester is required in the container vent if the flash

point characteristic of the oil presents the hazard of fire flash back.

The inspectors reviewed the design of the oil collection system for the

reactor coolant pumps. An inspection of the system was not made since the

plant was in operation and access to the containment was not possible.

However, the work package for the oil collection system, Design Change

No. 80-47, was reviewed. The design documents indicate that the system is

seismically designed ano supported to function following a seismic event.

The system is arranged to collect and temporarily store any lube oil which

may leak out of the reactor coolant pump motor lube oil system. The follow-

ing oil-bearing components are provided with oil collection enclosures:

-

011 lift pump and associated pressurized lines

-

Oil cooler and associated pressurized lines

-

Oil level indicators

-

Oil fill and drain points

-

Flanged connections for the oil reservoir

-

Sight glasses

-

All flanged oil-bearing connections

An oil collection system is provided for each reactor coolant pump motor.

Each system is connected to a drain tank of 265 gallon capacity which is the

amount of oil in each pump motor. The tank vents are provided with flame

arrestors and the drain lines from the oil collection enclosures to the tanks

are sized to accommodate the largest potential oil leak.

The licensee's QC inspection verification data was reviewed by the inspec-

tors and the final QA/QC inspections on the Unit 1 and Unit 2 systems were

noted to have been completed on March 23, 1981 and November 24, 1980,

respectively.

The oil collection systems for the reactor coolant pump motors appear to

meet the requirements of Appendix R, Section III.0 and within the areas

examined, no violations or deviations were identified.

L.

r: -

.-

9

36

10. Inspector Followup Items (IFI)

a. (Closed) IFI (338, 339/85-10-01), Review of Fire Fighting Equipment

Inventory for Firefighting Equipment Inventory for Fire Hydrant Hose

Houses. Procedure PT-105.3, Hose House Inspection, has been revised to

require that the same quantity of fire fighting equipment be maintained

in the hydrant hose houses as listed in the North Anna Fire Protection

Plan. This item is closed.

b. (Closed) IFI (338, 339/85-10-02), Position Verification and Position

Control for Critical CO2 and Fire Suppression Water System Valves.

Procedures PT-100.3, Fire Suppression Water System Valve Position

Verification and PT-104.4, Low Pressure CO 2and Halon Systems Required

Valve Lineup Verification have been revised to include all of the key

fire protection valves. This item is closed.

c. (Closed) IFI (338, 339/84-08-02), Correct Pump Curve for Fire Pumps.

The motor and diesel driven fire pumps were subjected to a full flow ,

performance test on June 28, 1985. The motor driven pump has recently

been rebuilt; therefore,. during tnis test, additior.al flow and head

pressure reading were obtained to develop a new pump test curve to be

used as acceptance criteria for future tests. The test for both pumps

exceeded the Technical Specification requirements, but the diesel

pump's discharge flow and head pressure were slightly deficient from *

the design pump curve. Work Ord2r No. 26610 has been issued to deter-

mine the cause of the reduced flow and to make the necessary correc-

tions. This problem will be reviewed during future NRC inspection;

however, sufficient action has been taken to close this IFI.

l