ML033020031
| ML033020031 | |
| Person / Time | |
|---|---|
| Site: | Crystal River |
| Issue date: | 10/10/2003 |
| From: | Ogle C NRC/RGN-II/DRS/EB |
| To: | Young D Florida Power Corp |
| References | |
| FOIA/PA-2003-0358 IR-02-005 | |
| Download: ML033020031 (23) | |
See also: IR 05000302/2002005
Text
_'FA RED&
t;FUNITED
STATES
4
By
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NUCLEAR REGULATORY COMMISSION
M,,
A
{
REGION II
SAM NUNN ATLANTA FEDERAL CENTER
61 FORSYTH STREET SW SUITE 23TBS
ATLANTA, GEORGIA 30303-8931
Mr. Dale E. Young, Vice President
Crystal River Nuclear Plant (NA1 B)
ATTN: Supervisor, Licensing &
Regulatory Programs
15760 West Power Line Street
Crystal River, FL 34428-6708
SUBJECT:
CRYSTAL RIVER UNIT 3 - NRC INSPECTION REPORT 50-302/02-05
Dear Mr. Young:
On July 12, 2002, the Nuclear Regulatory Commission (NRC) completed a triennial fire
protection inspection at your Crystal River Unit 3 Plant. The enclosed report documents the.
results of this inspection which were discussed on July 12, 2002, with you and .other members
of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commission's rules and regulations and with the conditions of your license.
The inspectors reviewed elected procedures and records, observed activities, and interviewed
personnel.
,/ he ,4cs
4 ;
g
Based on the resul
of this inspectio
e inspectors identified orreunresolved item, with three
examples,
failure to ensure hat one of the redundant trains of a system necessary to
achieve and maintain hot shutdown conditions would be free of fire damage. The issue
remains unresolved pending NRC review of a technical analysis being performed by your staff
of local manual operator actions in response to a fire in these areas and subguont compIetien
ei fie si~cnncdztrminaticn p
In accordance with 10 CFR 2.790 of the NRC's 'Rules of Practice,' a copy of this letter and Its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRC's Document
1'
.
2
system (ADAMS). ADAMS is accessible from the NRC web site at http://www.nrc.gov/readinp-
rm/adams.html (the Public Electronic Reading Room).
Sincerely,
Charles R. Ogle, Chief
Engineering Branch 1
Division of Reactor Safety
Docket No.: 50-302
License No.: DPR-72
Enclosure:
NRC Inspection Report 50-302/02-05
w/Attachment
cc w/encl:
Daniel L. Roderick
Director Site Operations
Crystal River Nuclear Plant (NA2C)
Electronic Mail Distribution
-Jon A. Franke
Plant General Manager
Crystal River Nuclear Plant (NA2C)
Electronic Mail Distribution
S
.
Richard L. Warden
Manager Nuclear Assessment
Crystal River Nuclear Plant (NA2C)
Electronic Mail Distribution
R. Alexander Glenn
Associate General Counsel (MAC - BT15A)
Florida Power Corporation
Electronic Mail Distribution
Attorney General
Department of Legal Affairs
The Capitol
Tallahassee, FL 32304
(cc w/encl cont'd - See page 3)
- -
.1.
(cc w/encl cont'd)
William A. Passetti
Bureau of Radiation Control
Department of Health
Electronic Mail Distribution
Craig Fugate, Director
Division of Emergency Preparedness
Department of Community Affairs
.Electronic Mail Distribution
Chairman
Board of County Commissioners
_CitrusLCounty .___..
110 N. Apopka'Avenue
Inverness, FL 36250
3
Michael A. Schoppman
Framatome Technologies
Electronic Mail Distribution
- Distribution
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OFFICE
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RiI:DRS
RII:DRP
RII:DRS
ISIGNATURE
NAME
B1LLINGS
MERRIWEATIH-ER
SMITH
WISEMAN
PAYNE
OGLE
DATE
8 / 02
8/ /02
8/02
8/ /02
/ /02
/ /8/
02
E.MAIL COPY?
YES NO
YES
NO
YES
NO
YES
NO
YES
NO
UNFFICAL htCUMU -U T
LJULUMEN I NAdME:
b:RLJM~ng Branc I Vworm MerwIiirev-.wpa
Report Details
1.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems
1 R05 FIRE PROTECTION
.01
Systems Required To Achieve and Maintain Post-Fire Safe Shutdown (SSD) and Post-
Fire SSD Circuit Analysis
a.
Inspection Scope
The team evaluated the licensee's fire protection program against applicable rules and
requirements, including Operating License Condition 2.(C).9, Fire Protection; Title 10 of
the Code of Federal Regulations Part 50 (10 CFR 50), Appendix R; Appendix A of
Branch Technical Position (BTP) Auxiliary and Power Conversion Systems Branch
(APCSB) 9.5-1; 10 CFR 50.48; related NRC Safety Evaluation Reports (SERs); and the
plant Technical Specifications (TS).
The team used the licensee's Individual Plant Examination for External Events (IPEEE)
-
- ;
and in-plant walkdowns tooselecfour risk significant fire areas for inspection. The four
-
fire areas selected were: :
.
.<
-
Fire Area 102: Fire Area 102 is the hallway and remote shutdown room on the
108' 0" elevation of the Control Complex. The area extends from the 108' 0"
elevation to the 124'
elevation and is shown on drawing 213-005, level 28. No
automatic fire suppression system is provided in this area and ionization
detectors have been installed in the area to provide for warning of fire for fire
brigade response.
A fire in this area would involve shutdown of the unit from the Main Control Room
(MCR) using Train B SSD equipment.
Fire Area 106: Fire Area 106 is Battery Charger Room 3A in the Control
Complex. The area extends from the 108' 0" elevation to the 124' 0" elevation
and is shown on drawing 213-005, level 28. The walls, floor, and ceiling are of
concrete construction and are considered to be rated as three-hour fire barriers.
No automatic fire suppression system is provided in this area and ionization
detectors have been installed in the area to provide for early warning of fire for
fire brigade response.
A fire in this area would involve shutdown of the unit from the MCR using Train B
SSD equipment.
Fire Area 107: Fire Area 107 is the 3B 4160 Volt Engineered Safeguard (ES)
switchgear room in the Control Complex. The area extends from the 108' 0'
elevation to the 124' 0" elevation and is shown on drawing 213-005, level 28. No
automatic fire suppression system is provided in this area and ionization
I F.1i
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No:
License No:
50-302
Report No:
Licensee:
Facility:
Location:
50-3/2/02-05-
Florida Power Corporation (FPC)
Crystal River Unit 3
15760 West Power Line Street
Crystal River, FL 34428-6708
L . .
.
.
-
i:
'
Dates:
Inspectors:
June 24 - July 12, 2002
... . .
. ...
Accompanying
Personnel:
Approved by:
D. Billings, Resident Inspector, Oconee Nuclear Power Plant
N. Merger, Senior Reactor Inspector, Region II
G.
edanire Protection Inspector, Region II
C. Sfnith'P. E.J Senior Reactor Inspector, Region II (Lead Inspector)
M. K
dR
nt Inspector, V.C. Summer
N. Staples, Nuclear Safety Intern, Region II
C. Payne, Fire Protection Team Leader, Region II
Charles R. Ogle, Chief
Engineering Branch 1
Division of Reactor Safety
Enclosure
I
7W
SUMMARY OF FINDINGS
IR 05000302-02-05, Florida Power Corporation, on 06/24/2002 - 7/12/2002, Crystal River Unit
3, triennial baseline inspection of the fire protection program.
The inspection was conducted by three regional inspectors and the Oconee resident inspector.
The inspection identified one unresolved item. The significance of issues is indicated by their
color (Green, White, Yellow, Red) using IMC 0609 "Significance Determination Process" (SDP).
Findings for which the SDP does not apply may be "Green" or be assigned a severity level after
NRC management review. The NRC's program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process,"
- ------ Revision-3,-dated July 2000.
Inspector Identified Findings
-Cornerstone: Mitigating Systems
TBD. An unresolved item was identified for failure to ensure in three fire areas that one
of the redundant trains of a system necessary to achieve and maintain hot shutdown
4'
conditions would be free of fire damage. Redundant electrical cables for redundant
O
U
makeup system valves MUV-23, 24, 25, and 26 were located in fire areas CC-108-102
and CC-108-107 without adequate spatial separation or fire barriers in accordan
withl0 CFR 50, Appendix R,Section III.G.2. In the event of a severe fire intharea
fire damage to the unprotected cables could prevent opening of the valves from the
main control room which would require local manual operators actions to establish
adequate injection flow to the reactor coolant system and reactor coolant pump seals.
Also, redundant electrical cables for redundant emergency diesel generators (EDG).1A
and 1 B and makeup pumps 1 A,1 B, and 1 C were located in fire area CC-108-106
without adequate spatial separation or fire barriers. In the event of a severe fire in this
area, fire damage to these unprotected cables could prevent starting a makeup pump
from the main control room which would require local manual operator action to
establish adequate injection flow to the reactor coolant system and reactor coolant
pump seals. In addition, a fire in this area could result in a loss of both EDGs. This
finding is unresolved pending NRC review of a technical analysis being performed by
the licensee of local manual operator actions p response to a fire in these areas.
oubsequet comnplotion of the oig,ificnco 'termnatkn prees. The finding affects
the mitigating systems cornerstone only. (Section 1R05.01)
1-.
2
detectors have been installed in the area to provide for warning of fire for fire
brigade response.
A fire in this area would involve shutdown of the unit from the MCR using Train A
SSD equipment.
Fire Area 121: Fire Area 121 is the Control Complex heating, ventilation and air
conditioning (HVAC) area and is divided into four fire zones: 121A, 121 B, 121C
and 121D. The area extends from the 163' 0 elevation to the 186' 0' elevation
and is shown on drawing 213-005, level 28.
Ionization detectors are installed in
zones 121A, 121B, and 121C to provide for warning of fire for fire brigade
response. No detection is provided in zone 121D.
-
-Afire in this-area would involve alternate safe shutdown (ASD) of the unit from
the Remote Shutdown Panel Room and the redundant switchgear rooms using
Train B SSD equipment.
For a selected sample of SSD systems, components, and plant monitoring instruments,
the team reviewed the CR3 Appendix R Fire Study, applicable fire protection related
SERs, and system flow diagrams to evaluate the completeness and adequacy of the
CR3 Appendix R Fire Study and.the systems relied upon to mitigate fires in the selected'- -
fire areas. The inspection included review of the post-fire SSD capability and of the fire
protection features to-ensure that at least one post-fire SSD success path was
maintained free of fire damage.
'
?
- -
~~.7,
^
..
.
- .
..
The team examined cable routing, raceway drawings, the actual configuration of the
circuits, fire detection and alarm systems, manual fire suppression equipment, and the
electrical raceway fire barrier system (ERFBS) for conformance to applicable NRC
requirements and National Fire Protection Association (NFPA) standards. In addition,
the team walked down these fire areas to verify that the licensee's documentation
reflected the as-built configuration.
On a sample basis, the team reviewed the licensee's CR3 Appendix R Fire Study to
determine whether redundant trains of components or circuits required for SSD were
located in the same fire area. From this review, the team selected makeup system
valves MUV-23, MUV-24, MUV-25, and MUV-26; makeup pumps MUP-lA, 1B, and C;
and emergency diesel generators EDG-1 A and 1 B to review the routing and installation
of the associated power and control cables. The team reviewed the cables to verify that
adequate spatial separation or proper fire barrier protection features were installed in
accordance with the design requirements of 10 CFR 50, Appendix R. Specifically, the
inspectors assessed whether fire-induced faults (e.g., hot shorts, open circuits, and
shorts to ground) could prevent safe shutdown.
Additionally, the team reviewed electrical coordination and protection data (e.g., circuit
breaker trip characteristics, fuse melt characteristics, and relay trip characteristics) for a
sample of SSD components to assess the adequacy of electrical protection provided
from non-essential cables or loads which share a common power source or enclosure
with cables of equipment required to achieve and maintain SSD conditions. Specific
.1;
3
components examined included: emergency feedwater valves EFV-1 1 and EFV-32;
pressurizer power actuated relief valve RCV-10; makeup system valves MUV-9 and
MUV-49; makeup pump MUP-C; air handling fans AHF-22C and AHF-22D; service
water pump SWP-1 C; and emergency diesel generator EDG-1 B.
b.
Findings
An unresolved item (URI) with three examples was identified, in that, some control
cables for components associated with the makeup pumps, EDGs, and selected valves
in the makeup flow path in three fire areas had not been protected from fire damage as
required by 10 CFR 50, Appendix R. This finding is unresolved pending NRC review of
a technical analysis being performed by the licensee of lgc6al manual operator actions in
response to a fire in these areas and zubsoquent corme!tin of tho cignificano
dotorminotizn procoss.
10 CFR 50.48, "Fire Protection," and Appendix R to 10 CFR 50, Fire Protection
Program for Nuclear Power Facilities Operating Prior to January 1, 1979,' establish
specific fire protection features required to satisfy General Design Criterion 3,
Fire
Protections (GDC 3, Appendix Ato 10 CFR 50).Section III.G of Appendix R requires
fire protection features be provided for equipment important to safe shutdown. An
acceptable level of fire protection may be achieved by various combinations of fire
protection features (barriers; fire suppression systems, fire detectors, and spatial
.
separation of safety trains) delineated in Section III.G.2. For areas of the plant where
compliance with the technical requirements of Section III.G.2 can not be achieved, the.
licensee must either seek an exemption or deviation from the specific requirement(s) or.-
provide an ASD capability in.accordance with Sections lIl.G.3 and Ill.L of the regulation.
The use of local manual operator actions is not specifically addressed in Section II.G.2
as being an acceptable alternative method for meeting the requirements of this section.
The team found that the 108' 0" level of the Control Complex area contained cables for
redundant trains of SSD equipment. Because these redundant cables were located in
close proximity o each other, compliance with the fire protection requirements of
Appendix R, S/ction III.G.2 was required. The licensee had originally used Thermo-Lag
wraps
- Wa pt to meet these requirements. But later when that material could not be
qualified for the appropriate fire rating, the licensee chose not to protect certain cables
in this area. Instead, the licensee developed an alternate fire response strategy which
procedurally directed local manual operator actions should control of the equipment be
lost from the MCR. The licensee did not develop an A
ethodology for this area.
Based on a review of cable routing informat provided by the licensee, the inspection
team determined that redundant electric
ables for redundant makeup system valves
MUV-23, 24, 25, and 26 were locatedj fire areas CC-108-102 [Example 1] and
CC-1 08-107 [Example 2]. While th
icensee considered the cables associated with this
equipment to be necessary for ac ieving and maintaining hot shutdown conditions, the
team identified that the licensee did not provide adequate spatial separation or fire
barriers in accordance with 10 CFR 50, Appendix R, III.G.2. Hence, in the event of a
severe fire in these areas, fire damage to the unprotected cables could prevent opening
of the valves from the MCR and challenge the operators' ability to establish adequate
injection flow to the reactor coolant system and reactor coolant pump seals.
im
1*
4
licensee creditedlocal mralat6-nsof theakeup~ systemvalvesp-ted in the
-Auxiliary.Building to throttle valves-MUV-23;-24':25-and 26to pr
man;p
TX
H
h,
es
The team also found that redundant electrical cables for redundant EDG-1A and 1 B and
makeup pumps MUP-lA, B, and 1C were located in fire area CC-108-106 [Example 3]
without adequate spatial separation or fire barriers installed in accordance with 10 CFR 50, Appendix R, III.G.2. In the event of a severe fire in this area, fire damage to these
unprotected cables could prevent starting a makeup pump from the MCR and
subsequently challenge the operators' ability to establish adequate injection flow to the
reactor coolant system and reactor coolant pump seals. The licensee credited local
manual actions to restore makeup pump 1 C by operating the pump rpotor circuit breaker
at the switchgear (4KV ES Bus 31). In addition, a fire in this ar a c uld result in a loss
on both EDGs.a-ed , 4
X
This finding had a credible impact on safety, in that, during a fire that required shutdown
from the MCR, local manual operator actions would have to be performed in the plant in
order to achieve and maintain safe shutdown conditions. These actions have not been
reviewed or approved by the NRC as being acceptable for meeting the III.G.2 criteria of
10 CFR 50, Appendix R. Nor have these actions been fully analyzed by the licensee for
timeliness, complexity, quantity, availability of manpower, human performance under
. .^. i.
high stress or risk. This finding only affects the mitigating system cornerstone.
A
.
Prior to the NRC's triennial fire protection inspection, the licensee conducted the
triennial assessment of its fire protection program in May 2002 (NAS Assessment C-FP-
02-01.) This evaluation identified that "some manual actions contained in OP-880A,
Appendix R Post-Fire Safe Shutdown Information, may not be in conformance with the
current NRC position regarding the use of manual actions to satisfy the requirements of
10 CFR 50, Appendix R." The licensee stated its position that changes to the approved
fire protection program could be made under 10 CFR 50.59 per CR-3 Operating Licence
Condition 2.(C).9 and that this was an industry-wide concern. The NRC and Nuclear
Energy Institute (NEI) have corresponded and met on several occasions to define this
issue and attempt to resolve it in a mutually agreeable manner. The licensee is tracking
the issue until the need for corrective action is furthei clarified.
The licensee also identified an issue involving the rigor/adequacy of the safety analyses
used to justify the addition of manual actions for certain Thermo-Lag protected circuits in
lieu of the circuit protection or separation as specified in 10 CFR 50, Appendix R, III.G.2.
In general, the analyses lack sufficient information to determine if factors other than
emergency lighting and accessibility were considered in determining the acceptability of
the additional manual actions and that the changes would not adversely effect the
ability to achieve and maintain safe shutdown in the event of a fire" as required by the
CR-3 Operating License Condition 2.(C).9. These issues were entered into the
--- licensee's corrective action program in Non-Conformance Report (NCR) No. 61781.
(See section 1R05.11)
The examples in the finding described above represent situations where the licensee's
alternate fire response strategy could adversely affect the ability to achieve and maintain
safe shutdown of CR-3 in the event of a fire. While the licensee had identified which
circuits were not adequately protected and had specified c
pensatory manual operator
actions, there was no comprehensive safety or risk anal is confirming the adequacy
these changes. Additionally, no new enhanced or exp
ded safety analyses of manual
operator actions were provided or available to the ins ectors during this inspection. The
safety characterization of this finding has not yet be n finalized. Therefore7 this finding
is unresolved pending licensee completion and N
review of a technic ~l analysis of
local manual operator actions (in response to firee
SBP-review. This finding will be tracked as URI 50-302/02-05-01, Failure to Protect One
Train of Safe Shutdown Equipment From Fire Damage in Accordance with Appendix R,
-- Section-III.G.2((Three Examples).-
The team also identified a condition that could result in possible delay in fire brigade
response to a fire event and hence, increase the risk associated with a fire in Fire Areas
102, 106 and 107. Fire service valve FSV-257 must be opened to supply water to the
fire hose stations in the Control Complex. This may be accomplished either by operator
action from the MCR or local manual action at a pull station within the Control Complex. 3i
The team identified that a fire in the Control Complex could potentially damage the
control and power cables for FSV-257. If the actuation cables for FSV-257 were
damaged by fire, then manual action outside the MCR would be required to open
V.
e
257 to align fire fighting water to the Control Complex fire brigade hose stations.
he
delay in opening this valve could result in an overall delay of over three minutes in fire
brigade response to a fire event. .The licensee documented this finding in their
..
corrective action program as NCR No. 065526.
2
.
t
..-
..:02
. Fire Protection of SSD Capability
a.
Inspection Scope
The team reviewed selected portions of the sife Fire Protection Plan (FPP), the Fire
Hazards Analysis (FHA) and fire prevention/combustible hazards control procedures to
determine if the objectives established by the licensee's commitments, as established in
the fire protection licensing basis documents, were satisfied. Using procedure SP-809
the team, accompanied by the site fire protection specialist, toured the selected fire
areas to observe whether the licensee limited fire hazards in a manner consistent with
the fire prevention/combustible hazards control procedures. Fire brigade response and
emergency/incident reports from 1999 through 2002, as well as corrective action
program Action Requests (ARs) resulting from fire, smoke, sparks, arcing, and
equipment overheating incidents were reviewed. This review was conducted to assess
the effectiveness of .the fire prevention program and to identify any maintenance or
material condition problems related to fire incidents. Additionally, design control
procedures were reviewed to verify that plant changes were adequately reviewed for the
potential impact on the fire protection program, SSD equipment, and procedures as
required by fire protection program.
Team members also walked down the selected fire areas to compare the associated fire
fighting pre-fire plans and drawings with as-built plant conditions. This was done to
verify that fire fighting pre-fire plans and drawings were consistent with the fire
protection features and potential fire conditions described in the FHA. Additionally, the
team reviewed drawings and engineering flood analysis associated with the 164'
.9
6
elevation control building floor and equipment drain system to verify that those actions
required for ASD would not be inhibited by fire suppression activities or leakage from fire
suppression systems.
The team reviewed fire brigade response, training, and drill program procedures, drill
critiques, and drill records for the operating shifts from June 2001 through May 2002.
The reviews were performed to determine whether fire brigade drills had been
conducted in high fire risk plant areas and whether fire brigade personnel qualifications,
drill response, and performance met the requirements of the licensee's approved fire
protection program. -The team walked down the primary fire brigade staging and locker
area in the maintenance shop adjacent to the turbine building to assess the condition of
fire fighting and smoke control equipment. Fire brigade personal protective equipment
located in the fire brigade dress-out area and fire fighting equipment in the turbine
building fire brigade staging area were reviewed to evaluate equipment accessibility and
functionality.
The team toured the plant to determine if emergency exit lighting was provided for
personnel evacuation pathways to the outside exits as identified in the NFPA 101, Lfe
Safety Code. The team also checked if backup emergency lighting was provided for
access pathways to and within the fire brigade staging and dress-out areas in support of
fire brigade operations should power fail during a fire emergency. The firelbrigade self-
contained breathing apparatuses (SCBAs) were examined for adequacy as-well as the
availability of supplemental breathing air tanks.
b.
Findings
No findings of significance were identified.
.03
ASD Capability
a.
Inspection Scone
The team reviewed the licensee's ASD methodology to determine the adequacy
identified components and systems required to achieve and maintain SSD con itions for
a severe fire in fire area 121. A fire in this area would involve shutdown of ths ua+/-fror
the Remote Shutdown Panel Room and the redundant switchgear rooms us
GUrain B
SSD equipment.
_
l
The team focused its review on the adequacy of the systems and component
reactivity control, reactor coolant makeup, reactor heat removal, process monitoring,
and support system functions. The team reviewed electrical control schematics of
remote shutdown relays located in Remote Shutdown Relay Cabinets
B" and B-1 to
ensure that the control circuits of SSD equipment required to mitigate a fire in fire area
-
- -- CC-164-121 were provided a permissive by logic inputs from these relays upon
operation of control switch CS/ISB to the remote shutdown panel (RSP) position. The
team reviewed electrical control schematics of selected SSD equipment to determine if.
operation from Remote Shutdown Panel B was enabled by manipulation of selector
switches mounted on this cabinet. The 120 VAC and 125 VDC control circuits of safe
shutdown equipment were also examined to ascertain whether separate control fuses
- ..
S
7
were installed in the control circuit to ensure that a fire induced failure from a firethe
MCR would not defeat the capability of controlling SSD equipment from RSP B a er
placing control switch CS/ISB to the RSP position.prior to tho operation ataff'
iig the
MeR. The electrical control schematics of SSD equipment fed from the 4160 VAC ES
bus were also reviewed by the team to identify if logic inputs from the Remote Shutdown
Relay Cabinets defeated equipment operation fr
the MCR upon placing control switch
CS/ISB in the RSP position.
7
Th tnm" r'Aew alz SC~~ tldLupi paiYnroiw switchi CStIS1 i the RISP
Sia, oeraionof416
VA ss eq i~netlwc rqM itd to be peformd l
alt
thu' c~witchpenir hy rn~ni 'al operath.
The team reviewed the electrical
control schematic of emergency diesel generator EDG-1 B to determine if logic inputs,
which ensure that electrical power required for achieving and maintaining hot shutdown
from outside the MCR, with or without offsite power, had been provided to the
emergency diesel generator EDG-1 B control circuit from Remote Shutdown Relay
Cabinet B. The team reviewed coordination curves of selected power supplies in order
to ensure that selective circuit breaker coordination had been established for power
supplies feeding SSD equipment.
The team also reviewed records of the latest surveillance and performance tests
performed on the remote shutdown panel instruments to ensure that instrumentation
.-
channels were operating within normal operating limits in accordance with the program
acceptance criteria delineated in the procedures.
b.
Findings.
No findings of significance were identified.
.04
Operational Implementation of ASD Capability
a.
Inspection Scone
The team reviewed the operational implementation of the ASD capability for a fire in the
selected fire areas to verify that (1) the procedures used for ASD were consistent with
the SSA methodology and assumptions; (2) the procedures were written so that the
operator actions could be correctly performed within the times assumed in the SSA; (3)
the training program for operators included alternative or dedicated SSD capability; (4)
the personnel required to achieve and maintain the plant in hot standby from outside the
control room could be provided from normal onsite staff, exclusive of the fire brigade;
and (5) the licensee periodically performed operability testing of the SSD
instrumentation and the transfer and control functions. The team walked down selected*
portions of AP-990 and EOP-02 to verify that the procedures could be performed within
the required times, given the minimum required staffing level of operators, with or
without offsite power. Operator and fire brigade staffing was reviewed to verify
compliance with the TS and conformance with the Fire Protection Program. The team
reviewed operator training lesson plans and job performance measures (JPMs), and
discussed the training with operators to determine if ASD activities were included in the
training program.
S
8
b.
Findings
No findings of significance were identified.
.05
Communications During Performance of ASD Functions
a.
Inspection ScoDe
The team reviewed the adequacy of the communication system to support plant
.- -.. ..
personnel in the performance of-ASD-functions and-fire brigade duties.--The licensee
credited the radio repeater systems for prompt fire brigade personnel response and
post-fire SSD MCR operator response. The inspectors reviewed the adequacy of the
radio communication system utilized by the fire brigade and to assess whether the
licensee's portable radio channel features would operate should the radio repeaters be
unavailable. The team walked down sections of the ASD procedures and inspected
selected shutdown equipment required for remote manual operator actions to evaluate if
adequate communications equipment would be available for the personnel performing
the procedures. The team also reviewed the periodic testing of the SSD radio repeater
systems and inventory surveillance of post-fire SSD operator equipment to assess
whether the surveillance test program for the radios was sufficient to verify proper
.
-
- '.' 9
operation of the system.
b.
Findings
No findings of significance were identified.
.06
Emergency Lighting During Performance of ASD Functions
a.
Inspection Scope
The team walked down the selected fire areas to observe whether battery pack
emergency lighting units (ELUs) were installed to allow operation of ASD equipment if
normal lighting was lost. In some cases, the installed ELUs were tested to demonstrate
functionality. The locations and identification numbers on the ELUs were compared to
design documents to confirm the as-built configuration. The team reviewed vendor
documentation to verify that the battery power supplies were rated for at least eight-hour
capacity. The team also reviewed licensee periodic tests to verify that the ELUs were
being maintained in an operable manner.
b.
Findings
No findings of significance were identified.
.07 - -- .Cold Shutdown ReDairs----..
a.
InsDection Scope
The team inspected plant procedures and equipment to ascertain if the licensee had
dedicated repair procedures, equipment, and materials to accomplish repairs of
9
damaged components required for cold shutdown, that these components could be
made operable, and that cold shutdown could be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The team
observed cold shutdown repair equipment and cables stored in nearby warehouses for
providing electrical power to pumps and valves if needed after a large fire. The team
checked to determine if the equipment was appropriately labeled and was maintained in
good condition. Also, the team walked down procedural actions and the projected route
for installing temporary cabling to power Decay Heat Pump B, Decay Heat Service
Water Seawater Pump, and a Decay Heat Closed Cycle Cooling Pump after a large fire.
The team evaluated whether the estimated manpower and installation time was
reasonable.
b.
Findings
No findings of significance were identified.
.08
Fire Barriers and Fire Area/Zone/Room Penetration Seals
a.
Ins ection Scope
The team walked down the selected fire areas to evaluate the fire resistance of barrier
enclosure walls, ceilings, floors, and structural steel support protection. This evaluation
also included fire barrier penetration seals, fire doors, fire dampers, and the MECATISS
ERFBS to ensure that at least one train of SSD equipment would be maintained free of
fire damage. The team observed the material condition and configuration of the
installed fire barrier features, as well as, reviewed construction details and supporting
fire endurance tests for the installed ERFBS. The team compared the observed fire
barrier penetration seal configurations to the design drawings and tested configurations.
The team also compared the penetration seal ratings with the ratings of the barriers in
which they were installed.
The team reviewed ASD procedures, selected fire fighting pre-plan procedures, and
HVAC systems to verify that access to remote shutdown equipment and operator
manual actions would not be inhibited by smoke migration from one area to adjacent
plant areas used to accomplish SSD. In addition, the team reviewed licensing
documentation, engineering evaluations of Generic Letter 86-10 fire barrier features,
and NFPA code deviations to verify that the fire barrier installations met design
requirements and license commitments.
b.
Findings
No findings of significance were identified.
.09
Fire Protection Systems. Features, and Equipment
a.
Inspection Scope
The team reviewed flow diagrams, cable routing information, periodic test procedures,
engineering evaluations for NFPA code deviations, and operational valve lineup
procedures associated with the fire pumps and fire protection water supply system. The
I.
10
review evaluated whether the common fire protection water delivery and supply
components could be damaged or inhibited by fire-induced failures of electrical power
supplies or control circuits. Additionally, team members walked down the fire protection
water supply system in selected areas to assess the adequacy of the system material
condition, consistency of as-built configuration with engineering drawings, and
operability of the system in accordance with applicable administrative procedures and
NFPA standards.
The team examined the adequacy of installed fire protection features in accordance with
the separation and design requirements in 10 CFR 50, Appendix R, III.G.2. The team
walked down accessible portions of the fire detection and alarm systems in the four
selected fire areas to evaluate the engineering design and operation of the installed
configurations. The team also reviewed engineering drawings for fire detector spacing
and locations in the four selected fire areas for consistency with the licensee's fire
protection plan and the requirements in NFPA 72D.
The team reviewed the adequacy of the design, installation and operation of the manual
suppression standpipe and fire hose system for the Control Complex. The team
examined design calculations to verify that the required fire hose water flow and
sprinkler system density for each protected area were available. The team checked a
sample of manual fire hose lengths to determine whether they would reach the SSD
equipment. Additionally, the team observed placement of the fire hoses and
extinguishers to assess consistency with the fire-fighting pre-plans.
.
..
~.
.s
Findings
No findings of significance were identified.
.10
Comgensatorv Measures
a.
InsDection Scope
The team reviewed the licensee's Form 01 07-03, DCegraded Equipment Log, which
identified compensatory measures for all degraded structures, systems, and
components. The review was performed to verify that the risk associated with removing
fire protection and/or post-fire systems or components was properly assessed and
adequate compensatory measures were implemented in accordance with the approved
fire prot6ction program. The team also reviewed non-conformance reports generated
over the last 18 months as a result of any fire protection features that were not returned
to service within the time frames required.
b.
Findings
No findings of significance were identified.
,
~~~~~~~~~~~~~11
.11
Identification and Resolution of Problems
a.
Inspection Scope
The team reviewed a sample of action requests for fire protection equipment to
determine whether the licensee was identifying fire-related issues at an appropriate
threshold and entering those issues into the corrective action program. The team also
reviewed self-assessments and audits related to the fire protection and SSD programs
to assess whether the licensee was performing comprehensive audits of these
programs in accordance with the requirements set forth in Appendix A of BTP APCSB
9.5-1.
b.
Findings
No findings of significance were identified.
4.
OTHER ACTIVITIES
40A6 Meetings
Exit Meeting Summary..*
.
..
.
The team presented the inspection results to Mr. D. Young, Site Vice President arid
other members of licensee management and staff at the conclusion of the inspection on
July 12, 2002. The licensee acknowledged the findings presented. No proprietary
information is included in this report.
12
Partial List of Persons Contacted
Licensee
S. Barlofski, Supervisor, ElecJI&C Design
D. Brass, Superintendent, Prog., Proj. & Facility Svs.
J. Franke, Plant General Manager-CR3
C. Miller, Supervisor, ECCS Systems
H. Oates, Superintendent, Design Engineering
D. Porter, Superintendent, Operations Support
-- S. Powell,-Supervisor,-Licensing & Reg. Programs-=
P. Rubio, Lead Engineer, Design Engineering
D. Taylor, Manager, Site Support Services
R. Warden, Manager, Nuclear Assessment
R. Wiemann, Supervisor, Elec./l&C Systems...
D. Young, Vice President, Crystal River Nuclear Plant
NRC
D. D IIg-s,
Iesident
Inspector, Oconee Nuclear Poxyer Plant
7
ne
la
, FlPrtconlearn Leader,
egion II
\\
N. taples, lcorSft
ncn ci 1'a
S. Stewart, Senior Resident Inspector,.Crystal River
ITEMS OPENED AND CLOSED
'
Opened
URI 50-302/02-05-01
Failure)
rot
t
n
Safe Shutdown Equipr
Fire Damage n Accordanc with Appendix R, Section
(Three Exa pe
/
Closed
ient From
IIl.G.2
None
LIST OF DOCUMENTS REVIEWED
PROCEDURES
AP-880, Fire Protection, Rev 15
AP-990, Shutdown From Outside the Control Room, Rev 18
OP-880A, Appendix ORI Post Fire Safe Shutdown Information, Rev 00
EOP-02, Vital System Status Verification, Rev 07
MP-192, Post Fire Repair of decay Heat Closed Cycle Cooling Pump Motors, Decay Heat
Pump 1 B, Decay Heat Service Seawater Pump and Power Cables, Rev 07
MP-193, Temporary Cooling to Control Complex, Rev 04
_ ___A-I- 000,-Housekeeping/Material-Condition Program, Rev.-37------
Al-2001, Control of Combustible Chemicals, Rev. 9
Al-2100, Chemical Hygiene Plan and Safety Guidelines for Environmental and Chemistry Work
Areas and Activities, Rev. 8
Al-2200, Guidelines for Handling Use and Control of Transient Combustibles, Rev. 8
Al-2205, Administration of CR-3 Fire Brigade Organization and Duties of the Fire Brigade,
Rev. 17
Al-2210, Fire Watch Program, Rev. 8
Al-2215, Management of the CR-3 Fire Protection Program, Rev. 2
AR-801, Fire Service Annunciator Response, Rev. 17
CP-113B, Work Request Evaluation/Planning, Rev. 32
CP-1 18, Fire Prevention Work Request, Rev. 32
CP-1 37, Fire Barrier Breaches, Rev.16
MP-805, Sealing of Penetrations, Rev. 12
PM-175, Fire Door Maintenance, Rev., 3
PM-185, Diesel Fire Pump Engine Inspection and Maintenance, Rev. 5
SP-190D, Functional Test of Fire Detection Systems-Control Complex, Rev. 14
SP-802, Fire Hose Hydro Test and Hose Reel Inspections, Rev. 26
SP-804, Surveillance of Plant Fire Brigade Equipment, Rev. 32
SP-807, Surveillance of Mounted Emergency Battery-Powered Light Units, Rev. 16
SP-809, Weekly Inspection Fire Protection, Rev. 9
TPP-219, Nuclear Emergency Team Training Program, Rev. 2
95 MC 0011, MECATISS Operating Procedure for the Installation of MTS. 3 Three Hours Fire
Barrier System, Rev. B
95 MC 0020, MECATISS Detailed Sketches on MPF/MTS Installations, Rev. B
95 MC 0057, MECATISS Operating Procedure for the Installation of MPF-180 Three Hours Fire
Barrier System Over Thermo-Lag 330.1 Material, Rev. E
ob Performance Measures JPMs) and Lesson Plans
JPM 9818, Actuate Main Steam and Main Feed Line Isolation from Outside the Control Room
C<
JPM 017, Initiate EFW in Accordance with Ap-990
JPM 085, Manually Trip the Reactor in Accordance with AP-990
Lesson Plan OPS-4-16-LP, Remote Shutdown System
Lesson Plan OPS-5-31 LP, AP-990 Shutdown Outside Control room, Rev 00
Lesson Plan OPS-8-38, Shutdown From Outside Control room, Rev 02
Lesson Plan AP-880 Fire Protection, Rev 01
ATTACHMENT
2
Lesson Plan OPS-5-91LP, NLO Emergency and Abnormal Tasks, Rev 00
Simulator Exercise Guide LOR-1-08, Shutdown Outside the Control Room, Rev 00
Completed Surveillance Test Records
PT-315, Remote Shutdown Relay Operability, Rev 09
SP-338, Remote shutdown and Post Accident Monitoring Channel Check, Rev 41
DESIGN CRITERIA AND CALCULATIONS
Topical Design Basis Document for Appendix R, Rev 05
Enhanced Design Basis Document for the Fire Service System, Rev. 8
Design Basis Document for the Remote Shutdown System, Rev 06
DRAWINGS
FD-302-082, Emergency Feedwater
FD-302-601, Nuclear services Closed Cycle Cooling Water
FD-302-61 1, Nuclear Services and Decay Heat Seawater
FD-302-631, Decay Heat Closed Cycle Cooling Water
FD-302-641, Decay Heat Removal
.
X -.;
- ,
FD-302-661, Makeup and Purification
.
-;
FD-302-753, Control Complex
.
-
-
FD-302-769, Appendix R
-
A-107-013, Fire Barrier Penetrations, Rev. 10
B-208-031, Elementary Diagram, Fire Service System, Rev. 7
E-213-005, Appendix R Protected Raceways, Control Complex, Rev.7
E-213-012, Appendix R Protected Raceways, Control Complex El. 108', Rev. 12
E-215-204, Conduit Layout Fire Service, Control Complex, Rev. 29
EC-209-014, Electrical Interconnection Wiring Diagram, Communications System, Rev. 15
BS-311-653, Sewage Pump Discharge Thru Turbine Bldg., Control Complex Plan, Rev. 17
BS-311-714, Ventilation Systems, Control Complex Plan, Rev. 28
FD-302-753, sheets. 1-4, Flow Diagram Air Handling, Control Complex, Rev. 41
B-208-082, Elementary Diagram, Remote Shutdown Panel MB" Relay Actuation,
Sheet RS-05, Revision 3
Sheet RS-06, Revision 8
Sheet RS-07, Revision 11
-
--- Sheet RS-08, Revision-6
Sheet RS-12, Revision 7
Sheet RS-14, Revision 11
Sheet RS-16, Revision 13
Sheet RS-18, Revision 8
B-208-021, Elementary Diagram,
-
Sheet No. DH-10, Revision 21"B" LPI Flow Control Valve DHV-1 11,
Sheet No. DH-02, Revision 21, D.H. Removal Pump 3B, (DHP-1 B), 4160 V ES Bus 3B
MTSW-2E-3B 1
ATTACHMENT
.
2
Sheet No. DH-06, Revision 24, L.P. Injection Cont. sol. from DHP-1 B, DHV-6, ES MCC
381, MTMC-5.-
B-208-026, Elementary Diagram, Sheet No. EF-08, Revision 21, T.D. Emerg. Feed Pump 3B
EFP-2 and Aux. Feed Water Disch. so. To Steam Generator EFV-1 1
B-208-039 Elementary Diagram,
Sheet No. MS-09, Revision 23, Main Steam Supply so. to EFP-2 Turbine Drive MSV-56
Sheet No. MS-10, Revision 24, Main Steam Supply Iso. to EFP-2 Turbine Drive MSV-55
Drawing No. B-208-041, Elementary Diagram,
Sheet No. MU-03, Revision 19, Makeup and Purification Pump 3B (MUP-1B)
Sheet No. MU-17, Revision 18, HP Pp. Suction from Borated Water Storage Tank,
(MUV-58)
Electrical Block Diagrams Drawing No. SS-211 -008,
Sheet No. AS-01, Revision 16, Emergency Feed Pump Stop Valve ASV-5
Electrical Block Diagrams Drawing No. SS-211-026,
Sheet No. EF-08, Revision 10,T.D. Emerg. Feed Pump 3B & Aux. F. W. Disch. Isol. to
Steam Gen. EFV-1 1
Sheet No. EF-10, Revision 9, T.D. Emerg. Feed Pump 3B & Aux. F. W. Disch. Isol. to
Steam Gen. EFV-32
Sheet No. EF-1 1, Revision 10, Motor Driven Emerg. Feed pump 3A & Aux. F. W. Disch.
Isol. to Stm. Gen. EFV-33
Sheet No. EF-14, Revision 5, MOVs EFV-11,14, 32, 33" C' and "D" Power Supplies
Sheet No. EF-17, Revision 7, Emergency Feed water Valve EFV-55
.:.
.
Sheet No. EF-18, Revision 7, Emergency Feed water Valve EFV-56
Sheet No. EF-1 9, Revision 7, Emergency Feed water Valve EFV-57
Sheet No. EF-20, Revision 7, Emergency Feed water Valve EFV-58
- .
Electrical Block Diagrams Drawing No. SS-211-039,
Sheet No. MS-09, Revision 12, Stm. Gen. 3B to Emerg. Feed Pp. Isol. Vlv. (MSV-56)
Sheet No. MS-10, Revision 13 Stm. Gen. 3B to Emerg.. Feed Pp. Isol. Vlv. (MSV-55)
Electrical Block Diagrams Drawing No. SS-211-041,
Sheet No. MU-01, Revision 5, Makeup and Purification Pump 3A, MUP-1A
Sheet No. MU-04, Revision 3, Makeup and Purification Pump 3C, MUP-1 C
Sheet No. MU-05, Revision 2, M.U. & P. Pump 3A Main Oil Pump MUP-2A
Sheet No. 17, Revision 7, H. P. Pp. Suct. From Bor. Water Storage Tank MUV-58
Sheet No. MU-19, Revision 14, H. P. Inj. Cont. Viv. To React. Inlet Line Loop A,
(MUV-23).
Sheet No. MU-20, Revision 10, H. P. Inj. Cont. Vlv. To React. Inlet Line Loop A,
(MUV-24).
Sheet No. MU-22, Revision 10, H. P. Inj. Cont. Vlv. To React. Inlet Line Loop B,
(MUV-26).
Sheet No. MU-24, Revision 5, Makeup Pump Recirc. Viv. 3B (MUV-257)
Sheet No. MU-25, Revision 5, Makeup Pump Recirc. VIv. 3A (MUV-53)
APPLICABLE CODES AND STANDARDS
NFPA 13, Standard for the Installation of Sprinkler Systems, 1983 Edition.
NFPA 14, Standard for the Installation of Standpipe and Hose Systems, 1970 Edition.
NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection, 1969 Edition.
ATTACHMENT
3
NFPA 20, Standard for the Installation of Centrifugal Fire Pumps, 1970 Edition.
NFPA 72D, Standard for the Installation, Maintenance, and Use of Proprietary Protection
Signaling Systems, 1967 Edition.
NFPA 80, Standard on Fire Doors and Windows, 1970 Edition.
NFPA 90A, Standard on Air Conditioning and Ventilating Systems, 1981 Edition.
NUREG-1552, Supplement 1, Fire Barrier Penetration Seals in Nuclear Power Plants, dated
January 1999
Underwriters Laboratory, Fire Resistance Directory, January 1998
AR REPORTS, AUDITS, AND SELF ASSESSMENTS
AR 00063067:Transient Fire Loading Concerns on 163' Control Complex
NAS Assessment C-FP-02-01; Action Request 00061781, OP-880A Manual Actions
OTHER DOCUMENTS
UFSAR 1.4.3 - Criterion 3, Fire Protection
UFSAR 7.4.6 - Aux Control Stations (Remote Shutdown System)
UFSAR 9.7 - Plant Ventilation
UFSAR 9.8- Plant Fire Protection Program
Fire Hazards Analysis Fire Protection Program Description & Review Per App.A to BTP
APCSB 9.5-1
.
.
Crystal River Appendix R Fire study, Rev 11
Crystal River Unit 3 Fire Protection Plan, Rev. 19
Crystal River Unit 3 Flood Analysis Notebook, Rev. 0
Crystal River Unit 3 Individual Plant Examination of External Events, Rev. 1..
Safety Evaluation of MECATISS Fire Barrier Test Program, dated January 29,1997
Memorandum, NRC to Florida Power Corporation, Confirmatory Order for Completion of
Corrective Actions Regarding Resolution of Thermo-Lag 330-1 Fire Barriers, dated May 21,
1998
Pre-fire Plan No. CC-1 08-1, Battery Room Area and 4160 E. S. Buss Room, Inverter Rooms,
Control Complex, Elev. 108'
Pre-fire Plan No. CC-1 63-1, HVAC Equipment Room, Control Complex, Elev. 163'- 10", Rev 9
Pre-fire Plan No. CC-95-1, Radiation Protection Area, Control Complex, Elev. 95', Rev. 9
FPDS 5.10, Crystal River Nuclear Plant Fire Zone Combustible List, Rev 5
Crystal River Unit 3 Fire Brigade Drill Critiques, Operating shifts from June, 2001 through May,
2002.
Factory Mutual Research, Fire Endurance Test, Penetration Seal Systems in Precast Concrete
Floor Utilizing Silicone Elastomers, dated May 18, 1977
CECO Corporation, Certification for Underwriters Laboratories Labeled Fire Doors, dated
June 10, 1971
Exide Electronics, Emergency Lighting Unit Equipment, Rev. 1
ATTACHMENT
.I
- '
4
CORRECTIVE ACTION PROGRAM ITEMS 1NfTfEl3J~
_
I
N-
NCR 00065592:
Evaluate Work Planning Process and Transient Fire Loading process to
Ensure Risk Significance is Evaluated Prior to Work Performance
NCR 00065310:
Evaluate Differing Design Inputs for the FHA and IPEEE Documents and
Reconcile Differences
NCR 00061867:
Failed to Complete Identified Corrective Actions to Evaluate Need for
- .--Battery-Powered-Emergency Lighting to-lluminate Fire Brigade Dress-
Out Locker Room and Staging Areas
NCR 00065525:
Evaluate Potential Fire Damage to Control and Power Cables to Fire
Service Valve to Control Complex Fire Hose Stations
Discrepancies identified during cold shutdown repair walkdown of
licensee's pre-staged materials while using MP-1 92.( Appendix R repair
kit box)
-
NCR 00061321
NCR 00064207
Evaluate the plant modification process used for removing computer
cabinets (MUX) doors.
Review improved TS to determine if cleaning is required to be performed
during determination of cell operability.
Evaluate section 2.2.5.9 of the appendix R Topical Design Basis
Document concerning the use of u Post fire manual actions for meeting
the requirements of III.G.1 and III.G.2 fire areas.
Evaluate all fuse data associated with MAR97-03-02-01 to ensure that
the information is included in the EBD.
Revise drawing 208-082RS-06 to correct drawing error associated with
valvDHV-11l (DHV-1 10)
Evaluate procedure AP-880 concerning a need to actuate FSV-257 (with
contingencies) on confirmation of a fire in the control complex.
ATTACHMENT
z
'
.
(cc w/encl cont'd)
William A. Passetti
Bureau of Radiation Control
Department of Health
Electronic Mail Distribution
Craig Fugate, Director
Division of Emergency Preparedness
Department of Community Affairs
Electronic Mail Distribution
Chairman
Board of County Commissioners
Citrus County
110 N. Apopka Avenue
Inverness, FL 36250
Michael A. Schoppman
Framatome Technologies
Electronic Mail Distribution
Distribution w/encl:
B. Mozafari, NRR
RIDSNRRDIPMLIPB
PUBLIC
3
IOFFICE
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MRRIWEATHER
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DATE
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E-MAIL COPY?
YES NO
YES
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OFICIAL MRUCi-I COPY
DOC.UMENT NAME: S \\DRS\\Eng Branch
i\\crystaI river 0205 lire protection report~wpd
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