ML18093A619
| ML18093A619 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 01/22/1988 |
| From: | Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18093A616 | List: |
| References | |
| 50-311-87-29, NUDOCS 8802030518 | |
| Download: ML18093A619 (36) | |
See also: IR 05000311/1987029
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-311/87-29
Docket No.
50-311
License No.
Licensee:
Public Service Electric and Gas Company
P. 0. Box 236
Hancocks Bridge, New Jersey 08038
Facility Name:
Salem Unit 2
Inspection At:
Hancocks Bridge, New Jersey
Inspection Conducted~ September 14-18, 1987 and December 15-18, 1987
Inspector: A~/f,WCf!?~ngineer
if!..'J../i/
Also participating in the inspection and contributing to the report were:
J. Petrosino, En~ineer, NRR, Vendor Inspection Branch
D. Kubicki, Fire Protection Engineer, NRR
R~ Hodor, Mechanical Systems Specialist, BNL
K. Sullivan, Electrical Systems Specialist, BNL
Approved by: cJ QL_
C. J.Anderson, Chief, Plant Systems
Section, EB, DRS
date
Inspection Summary:
Inspection on September 14-18, 1987 and December 15-18, 1987
(Report No. 50-311/87-29)
Areas Inspected:
A special, announced team inspection was conducted to verify
compliance with the requirements of 10 CFR 50, Appendix R, Section III.G, J, L
and 0 concerning fire protection features to ensure the ability to achieve and
maintain safe shutdewn in the event of a fire.
Results:
Four apparent violations and one deviation were identified. Three
items remained unresolved.
At the conclusion of the inspection the licensee
submitted to the NRC a justification for continuing operations in consideration
of the inspection findings.
See Attachment 1 for a Summary of Findings.
Additional commitments were made by the licensee during a management meeting
held at the Region I offices on October 7, 1987 to discuss the findings of
this inspection.
During the follow up inspection the inspector verified that
the commitments made by the licensee were being implemented adequately.
~80203051S 880126
GDR
ADDCK 05000311
.,
DETAILS
1.0 Persons Contacted
1.1
Public Service Electric and Gas (PSE&G)
- M. L. Bursztein, Principal Offsite Safety Review Engineer
- R. S. Miltenberger, Vice President, Nuclear Operations
- B. A. Preston, Manager, Licensing
- P. A. Moeller, Manager, Site Protection
- J. F. Kerin, Senior Nuclear Fire Protection Supervisor
- P. J. Eldreth, Nuclear Fire and Safety Manager
- R. Bashal, Senior Engineer
- C. P. Johnson, G.M., NQA
- J. M. Zupko, Jr., General Manager, Salem Operations
- L. A. Reiter, General Manager, Licensing and Reliability
J. T. Boettger, Assistant Vice President Nuclear
- L. K. Micca, Manager, Nuclear Engineering Services
- R. A. Burricelli, General Manager, Engineering and Plant
Betterment
- M. J. Pollack, Salem LER Coordinator
- D. A. Perkins, Manager, Station QA
- D. P. Shumaker, Plant Engineering
- J. S. Hodson, Offsite Safety Review Engineer
- R. B. Swartzwelder, Licensing, Senior Engineer
- G. A. Raggio, Station Licensing Engineering - Salem
- M. K. Gray, Licensing Engineer
R. Braddick, Fire Protection Staff Engineer
- C. Lambert, Nuclear Engineering Science Manager
W. M. Reiber, Senior Engineer
K. Ewell, Consultant (Vice President, Proto Power Company)
N. Fioravanti, Consultant, (Tenera Corporation)
R. Eberly, Consultant, (Tenera Corporation)
R. J. Diaz, Nuclear Systems
M. J. Cavalier, Site Representative (Ace Company)
1.2 Nuclear Regulatory Commission (NRC)
T. Kenny, Senior Resident Inspector
- K. Gibson, Resident Inspector
- E. C. Wenzinger, Sr., Branch Chief, Reactor Projects
- J. Durr, Deputy Director (Acting), Division of Reactor Safety
S. Pullani, Section Chief (Acting), Plant Systems Section
+R. Summers, Project Engineer
- Denotes those present at the exit interview on September 18, 1987.
+Denotes those present at the exit interview on December 18, 1987.
- Denotes those present at the exit interviews on September 18, 1987
and December 18, 1997 .
3
2.0 Purpose
This inspection was performed to ascertain licensee conformance with IO
CFR 50, Appendix R, Sections III.G, J, and L with the exemptions approved
by the Office of Nuclear Regulation (NRR).
3.0 Background
The licensee, by a License Condition, is required to comply with the
requirements of 10 CFR 50, Appendix R, Sections III.G, J, L, and 0. *
Section III.G of Appendix R requires that fire protection be provided to
ensure that one safe shutdown train remains available in the event of a
fire.
Section III.J requires that emergency lights are installed in all
areas required for safe shutdown purposes and Section III.L specifies the
requirements for alternate shutdown capability.
Section III.a requires
an oil collection system for the Reactor Coolant Pumps.
Licensee
compliance with'III.O was not reviewed during the course of this
inspection.
4.0 Post-Fire Safe Shutdown Capability
4.1 Systems Required for Safe Shutdown
The licensee has specified that the fol~owing systems will be used
for safe shutdown in the event of a fire concurred with loss of
offsite power.
Component Cooling Water (CCW)
Chemical and Volume Control (CVCS)
Containment Ventilation (Fan Coolers)
Diesel-Generators/Electrical Power Distribution
- .
Control Air (Emergency Air Compressor)
Primary System Instrumentation:
Steam Generator Level and Pressure
Pressurizer Level and Pressure
Reactor Coolant System Temperature and Pressure
Safe shutdown of the reactor is normally accomplished by the inser-
tion of control rods from the control room.
Control rod insertion
can also be accomplished by removing power to the motor generator
sets in the switchgear room.
Reactor coolant inventory and reactor
shutdown margin are maintained by one of three chemical and volume
control system (CVCS) charging pumps taking suction from the volume
4
control tank, boric acid tank or the refueling water storage tank
(RWST).
Primary system pressure can be maintained by the pressurizer
heaters and pressurizer spray or by use of the charging pumps
combined with letdown.
Decay heat removal can be accomplished by
releasing steam from the steam generators via the atmospheric dump
valves.
Makeup to the steam generators can be provided by the
auxiliary feedwater system, which takes suction from the auxiliary
feedwater storage tank.
Cold shutdown conditions can be achieved and maintained through the
use of the residual heat removal (RHR) system.
Cooling is provided
to the RHR heat exchanger by component cooling water which is in
turn, cooled by service water in the component cooling heat
exchanger.
Reactivity control during cold shutdown is maintained by
the eves.
4.2 Areas Where Alternate Shutdown is Required
The licensee has provided alternate shutdown capability in case of a
fire occurring either in the main control room or the relay room.
Abnormal operating procedure AOP-EVAC-2 entitled
11Control Room
Evacuation Due to a Fire in the Control Room or Relay Room
11 has been
developed by the licensee to implement safe shutdown from outside the
control room.
For shutdown from outside the control room the process monitoring
instruments to be used are the reactor Thot and Tcold temperature
indicators located at the Alternate Shutdown Process Rack, the Steam
Generator (SG) Level and Pressure indicators, the Pressurizer Level
and Pressure indicators and the Source Range monitors located at Hot
Shutdown Panel (HSD) 213.
The Auxiliary Feedwater (AFW) Tank and
RWST Tank Level Indication is located on a panel near each storage
tank.
The Nuclear Shift Supervisor controls alternate shutdown activities
from the HSD Panel.
The Auxiliary Feedwater is initiated locally at
the Turbine Driven Auxiliary Feedwater Pump Panel (Panel 207).
If
the Turbine Driv~n Pump is not available, the operator can start
either one of the two Motor Driven Pumps at their respective local
panels.
Charging flow can be initiated by starting the charging
pumps from the switchgear room.
Charging flow control is ac-
complishea from the charging system panel, 216, by manipulating
charging flow control valve CV55.
Other systems that are available for alternate shutdown are Component
Cooling (CCW), Service Water (SW), Containment Ventilation, Diesel
Generator (DG), Control Air (Emergency Air Compressor), and Residual
Heat Removal (RHR).
5
4.3 Remaining Plant Areas
All plant areas other than the Relay Room, the ceiling of the Cable
Spreading Room and the Control Room, for which alternate shutdown
capability has been provided, must comply with the requirements of
Section III.G.2 of Appendix R, unless an exemption request has been
approved.
A number of exemption requests from the Appendix R
requirements have been submitted and are under review by NRC.
5.0 Inspection Methodology
The inspection team examined the separation and protection of equipment,
cabling and associated circuits necessary to achieve and maintain hot and
cold shutdown conditions. This inspection sampled selected fire areas
which the licensee had identified as being in compliance with
Section III.G.
The following functional requirements were reviewed for achieving and
maintaining hot and cold shutdown:
Reactivity control
Pressure control
Reactor coolant makeup
Support systems
Process monitoring
The inspection team examined the licensee's capability to achieve and
maintain hot shutdown and the capability to bring the plant to cold
shutdown conditions in the event of a fire in various areas of the plant.
The examination included a review of drawings, safe shutdown procedures
and other documents.
Drawings were reviewed to verify electrical inde-
pendence from the fire areas of concern.
Procedures were reviewed for
general content and feasibility.
Also inspected were fire detection and suppression systems and the degree
of physical Sef)aration between redundant trains of Safe Shutdown Systems
(SSSs).
The team review included an evaluation of the susceptibility of
the SSSs to damage from fire suppression activities or from the rupture or
inadvertent operation of fire suppression systems.
The inspection team examined the licensee's fire protection features
provided to maintain one train of equipment needed for ~afe shutdown free
of fire damage. *Included in the scope of this effort were fire area
.
6
boundaries (including walls, floors and ceilings), and fire protection of
openings such as fire doors, fire dampers, and penetration seals.
The inspection team also examined the licensee's compliance with Section
III.J, Emergency Lighting.
6.0 Inspection of Protection Provided for Safe Shutdown Systems
The team reviewed all fire areas containing safety-related or safe
shutdown-related systems except the containment.
In addition, the fire
pump house and the turbine building were inspected.
This inspection
identified the following unacceptable conditions:
Potential Disabling of All Three Emergency Diesels Due to C02 Discharge
The team observed that a fire in the vestibule of the Diesel Generator
Control rooms or the Relay room fire area FA-AB-lOOA, and Fire Areas
FA-AB-1008 and FA-AB-lOOC has the potential to cause shorting of control
circuits associated with the carbon dioxide fire suppression system and
cause the simultaneous injection of carbon dioxide in all three Emergency
Diesel rooms and all three Diesel Control rooms.
This potential inad-
vertent actuation of the carbon dioxide system will cause the loss of the
three diesel generators required for shutdown.
This determination was
made by the review of a safety evaluation performed by the licensee titled,
"Diesel Operation in a carbon dioxide Environment" SGS/M-S_E-067 dated
- October 16, 1980.
This evaluation addressed the specific concern of the
ability of the diesels to function in a carbon dioxide atmosphere.
The
analysis concluded that a diesel should be declared inoperable if the
carbon dioxide system for the specific diesel discharged in the room
because the diesel may overheat under this condition.
The licensee in operating procedure IV-16.3.1, Emergency Power-Diesel
Operation, requires that the affected diesel be immediately stopped to
prevent overheating if a carbon dioxide actuation occurs during Diesel
Generator operation.
The licensee in the safety evaluation and in the
operating procedure referenced above, did not consider the possibility
that a simultaneous injection of carbon dioxide ~ould occur in all three
diesel generator rooms.
In addition to the diesels being declared inoperable because of overheat-
ing concerns, the team observed that the emergency shutdown procedure
requires that-an operator be in the Emergency Diesel Control room to start
and synchronize the Diesels in the event of a fire in the Relay room.
The carbon dioxide atmosphere will prevent operators from entering these
rooms and thus prevent the start of the Diesels.
7
The possible fire related loss of all three emergency diesels from
overheating or their loss due to inaccessibility represents a potential
violation of 10 CFR 50 Appendix R Section III.G which stipulates that fire
protection features shall be provided to safe shutdown systems so that at
least one train of systems necessary for safe shutdown remains free of
fire damage.
(50-311/87-29-01)
Lack of Fire Detection in Seven Locations
The licensee in the Salem Fire Hazard Analysis, dated September 11, 1987,
stated that automatic fire detectors have been installed throughout the
Reactor Plant Auxiliary Equipment area and the Radwaste Storage areas.
The team observed that in six locations of the reactor Plant Auxiliary
Equipment area and in the control console room of the Radwaste Storage
area, detectors were not provided.
The six locations not provided with detectors in the Reactor Plant
Equipment area are:
1.
East end of the corridor outside of the counting room;
2.
The corridor to the mechanical penetration area;
3.
The storage area behind the counting room;
4.
The ventilation room on elevation 113 ft. over the counting room;
5.
- The boric acid evaporator room; and
6.
The Inservice Inspection (ISI) calibration storage room.
The lack of detectors in the zones identified above represents a deviation
from the commitment in the Salem 2 Fire Hazard Analysis Report.
(50-311/87-29-02)
Fire Barrier Penetration Seals
The team reviewed the fire barrier penetration seal installation and
documentation and determined that for the seals installed in the relay
room and other fire areas, the licensee does not have fire test
documentation.
This documentation is required to assure seal adequacy.
The lack of the
fire test documentation is a concern that has been addressed by the
licensee.
The licensee performed an assessment of the as-found condition
of the seals and determined that in the absence of any obvious damage to
the seals, the seals are adequate to withstand a one-hour fire.
The
8
licensee placed fire watches in areas such as the relay room or where the
fire loading exceeded the capability to withstand a one~hour fire as a
compensatory measure.
In addition, the licensee is in the process of
performing a comprehensive review of the penetration seals to verify their
adequacy.
The licensee committed to provide the implementation schedule for the
penetration seal verification program within ~O days upon receipt of this
report.
This is an Unresolved Item (50-311/87-29-03).
7.0
Review of Fire Protection Appendix R Related Licensee Event Reports (LERs)
The licensee has employed a consultant firm to perform reviews and to
assist in the Appendix R Safe Shutdown program.
The reviews performed
jointly by the licensee and their consultant identified several non-conform-
ing conditions which the licensee promptly reported via three different
LERs.
The team reviewed the licensee's activities related to these LERs
which are 87-09 Revision 4 and 87-10 for Salem Unit 2.
Salem Unit 1 LER
87-10 was also reviewed since it identified a nonconforming condition at
Salem Unit 2.
The Salem Unit 2 LER 87-09, Revision 4, identified several
instances where the 10 CFR 50 Appendix R requirements were not met.
The
Salem Unit 1 LER-87-10 identified one example of a nonconformance with
10 CFR 50 Appendix A criterion 17 regarding a single failure causing the
loss of the onsite electric power supplies (in both units).
Salem Unit 2
LER 87-10 identified a deficiency of minor safety significance, involving
a personnel error.
Review of the licensee actions concerning the Unit 2
LER 87-10 did not identify any unacceptable conditions.
With regard to LER 87-09, the review identified that in the.following
areas, shutdown in the event of a fire could not be accomplished in
accordance with the 10 CFR 50 Appendix R requirements:
A)
There is a potential to lose all service water (SW) supply systems
if a fire were to occur in the SW pipe tunnel Fire Area FA-PT-84.
This is because cable trays Nos. 2PT01, 2PT03, 2PT05, 2PT07, 2PT10
and 2PT12 containing power and control cables for all six service
water pumps are located in this area.
The Service Water system is a
system required for safe shutdown because SW provides the cooling for
the Emergency Diesel generators. Therefore, loss of SW will cause
the loss of the Emergency A.C. power required for shutdown .
B)
Two out ~f three Emergency Diesel Generators are required to be
operable in the event of a plant fire to support the shutdown loads.
The power feeds from the Emergency_Diesel Generators 11811 and
11C11 to
the 4160 volt switchgear are both located in the Fuel Oil Storage
Room, Fire Area FA-AD-84D.
-
A fire in this area has a potential to damage both of these feeder
cables and disable diesels B and C, causing loss of the Emergency
-Power required for shutdown.
9
C)
A fire in the carbon dioxide Equipment Room, Fire Area FA-DG-84F, has a
potential to cause the loss of all Emergency AC Power required for
shutdown since a fire in this area could damage the power cables of
both diesel fuel oil transfer pumps A and B routed through this area.
These pumps are essential for safe shutdown because they are used to
transfer the diesel fuel oil from the main diesel fuel oil storage
tank to the individual diesel day tanks.
Each day tank has about one
hour of fuel capacity.
Therefore, if the transfer pumps become
inoperable, there is no assurance that the diesels would run for
more than one hour and the resultin~ loss of the emergency diesel
generators would prevent shutdown.
D)
The following inadequacies also have a potential to affect
safe shutdown equipment adversely.
1.
Redundant RHR room cooler cables are located on a common panel
in the Reactor Plant Auxiliary Equipment area, Elevation 64,
Fire Area 2FA-AB-64B.
A fire in this area has the potential to
damage damage these cables resulting in the loss. of both RHR
room coolers. Without the RHR room coolers, the operability of
RHR Pumps 21 and 22 cannot be assured because of the increased
ambient room temperatures.
The RHR pumps are required during
cold shutdown .
2.
In the Upper Electrical Penetration area, Fire Area 2FA-EP-100G,
there are redundant RHR room cooler cables and Charging Pump
Room cooler cables.
A fire in this area, has a potential to
cause the loss of the RHR room coolers and the charging pump
room coolers.
The room coolers ensure that the ambient room temperatures do
not exceed the RHR pump or charging pump design limits.
Regarding LER 87-10 of Units 1 and 2, the review of the installed systems
determined that in fire areas FA-06-1000-1, FA-DG-lOOE-1 and FA-DG-lOOF-1
a fire has the potential of disabling the fuel oil transfer pumps and
thus preventing shutdown.
The circuits and relays required for the operation of both pumps are
located in each of these areas without separation or protection. A fire
in such areas has a potential to cause a short in the circuitry and dis-
able both pumps.
These pumps are essential for shutdown because they
provide the fuel oil for the Emergency Diesel day tanks.
The day tanks
hold enough fuel for approximately one hour of diesel operation.
Thus
loss of the transfer pumps will cause the loss of the diesels after
about one hour of operation.
The items identified in the LERs and described above were determined to
be a violation of 10 CFR 50, Appendix R, Section III.G.l.a which requires
10
that Fire Protection features shall be provided for structures systems and
components important to safe shutdown, capable of limiting the fire damage
so that one train of systems necessary to achieve and maintain hot
shutdown conditions is free of fire damage.
(50-311/87-29-04)
8.0 Safe Shutdown Procedures
8.1 Procedures Review
The team reviewed Procedure No. AOP-EVAC-2, titled Control Room
Evacuation Due to Fire in the Control Room or Relay Room.
11
This
procedure provides instructions to maintain the unit in hot standby
or to proceed to cold shutdown in the event of a fire in the control
room or relay room. *
The scope of this review was to ascertain that the shutdown could be
attained in a safe and orderly manner, to determine the level of
difficulty involved in operating equipment, and to verify that there
was not dependence on repairs for achieving hot shutdown.
For review
purposes, a repair may include installing electrical or pneumatic
jumpers, wires or fuses, to perform an action required for hot
shutdown.
For cold shutdown, repairs are allowed using in place
procedures and materials available onsite with the provision that
cold shutdown be achievable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The procedure, which would be used in event of a fire in the control
room or the.cable spreading room, was issued on September 8, 1987 and
was not reviewed by the Station Operations Review Committee (SORC).
This lack of SORC review represents a violation of T.S. 6.5.1.6 .. e
which requires that the SORC shall be responsible for the review of
the Fire Protection Program and implementing procedures.
(50-311/87-29-05).
The procedure is written in a two-column format.
The first column
lists the operator actions and the second column provides comments
and contingency actions.
The comments in this column are mostly
references to the Fire Hazard Analysis Books which provide detailed
explanatio~s on how to perform the Emergency Equipment Operations.
The team observed that all of the references such as Fire Hazard
Analysis Book Number and Section Number included in this procedure
were in e-rror.
The licensee explained that this error occurred
during the editing of the procedure.
However, the operators using
the index of the Fire Hazard Analysis were able to find the ap-
propriate procedure references.
The team noted that reliance on the
operator to recognize the procedure errors and use the index to find
the proper references is inappropriate.
The inspector determined
that the licensee initiated an effort to correct this deficiency of
incorrect procedure references .
11
8.2 Procedure Walk-Through
The team observed a walk through by licensee operators of several
portions of procedure AOP-EVAC-2, "Control Room Evacuation Due to
Fire in the Control Room or Relay Room," to determine by simulation
that shutdown from outside the Control Room is possible in an orderly
and timely fashion.
The procedure implementation required the use of the Nuclear Shift
Supervisor (NSS), three Nuclear Control Operators (NCO) and an
Equipment Operator (EO).
Following a simulated reactor trip and
evacuation of the Control Room, the NSS took control of the plant
shutdown from the Hot Shutdown Panel.
From there, instructions were
given to the operators by the use of hand-held radios.
The team in observing the operators perform some steps in the
procedure determined that some of the operator actions are repairs by
NRC definition and, therefore, are not allowed during the hot shut-
down phase.
The repairs in question involve the use of pneumatic
jumpers to prevent spurious actuation of valves.
The licensee
explained that an alternative to the use of pneumatic jumpers exists
in the procedure but using the jumpers is the preferred way.
The
licensee also explained that the NRC has specifically reviewed the
use of jumpers and has found it acceptable.
This issue remains
unresolved pending review of the pertinent documentation to confirm
previous NRC approval of the use of jumpers.
(50~311/87-29-06)
During the procedure walk-through, the team also reviewed the
effectiveness of communications using hand-held radios, since
this is the communication method used by the licensee.
The operators
communicated effectively using the radios, despite the background
- noise levels.
The team also reviewed the availability of this type
of communication system for a fire in the control room or the relay
room.
This review determined that the 115VAC vital instrument bus
2A, which is the power source of the radio transmitter, is located in
the relay room and, therefore, a fire in this area could disable the
radio communications.
Reliable radio communication is ~ssential for
the orderly safe shutdown of the plant since the NSS must communicate
with the NCOs and EO to provide instructions for actions necessary
for safe shutdown of the plant.
The possi~le loss of all communications during the hot shutdown phase
represents a violation of the 10 CFR 50 Appendix R, Section III.L.3
requirement which stipulates that the alternative shutdown capability
provided for a fire area be able to achieve and maintain hot standby
conditions.
(50-311/87-29-07)
12
Other observations made during the procedure walk-through are:
A)
The licensee is using a toolchest to store tools, jumpers,
repair materials and manuals.
The team observed that the
organization of the items within the toolchest was poor in
that the items stored in the toolchest were in disarray.
The
licensee committed to improve the placement/storage of the
material and tools required for shutdown.
B)
The procedure steps, make reference to valve and instrument
numbers.
The team observed that some of the numbering tags on
the valves were missing and some were too small to read under
the existing lighting conditions and tag location.
Some valves
were also tagged using magic markers.
The licensee agreed to
review the equipment identification concern.
9.0 Protection for Associated Circuits
Appendix R,Section III.G requires that protection be provided for
associated circuits that could prevent operation or cause maloperation of
redundant trains of systems necessary for safe shutdown.
The circuits of
concern are generally associated with safe shutdown circuits in one of
three ways:
Common bus concern
Spurious signals concern
Common enclosure concern
The associated circuits were evaluated by the team for these concerns.
Power, control, and instrumentation circuits were examined on a sampling
basis for potential problems.
9.1
Common Bus Concerns
The common bus concern may be found in circuits, either
safety-related 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.
The team examined, on a sampling basis, 4160V, 460V, 230VAC, 120VAC,
125VDC and 28VDC bus protective relay coordination.
The licensee
presented- sample coordination curves dated September 4, 1987, at the
time of the audit.
The team also examined, on a sampling basis, the
protection for specific instrumentation, controls, and power cir-
cuits, including the coordination of fuses and circuit breakers.
The
licensee's schedule is to perform checks of relay settings at approxi-
mately 24-month intervals.
13
The review of the common bus concern identified the following
unacceptable condition:
Inadequate Circuit Breaker Coordination
The team reviewed the licensee's draft "Appendix R Breaker Coordination
Study" dated September 4, 1987, to evaluate the protective relaying
of the vital buses required for safe shutdown in the event of a
fire. Although the review of this study identified many examples of
unsatisfactory circuit breaker coordination on all distribution
buses, the team could not identify any instances where the lack of
breaker coordination of associated circuits could prevent shutdown.
The team, however, informed the licensee that such a possibility
exists in areas housing safe shutdown components from one division
and associated circuits of concern from the redundant division. A
fire in such an area could cause the loss of the safe shutdown equip-
ment located therein and in addition cause the loss of the redundant
train because the vital buses of the redundant train located else-
where are not electrically protected from their associated circuits
located in this fire area.
The licensee agreed with the team that
this possibility may exist given the fact that proof to the contrary
could not be found.
The licensee reported this finding to NRC via LER 87-11 and
immediately established interim compensatory measures.
These
measures were described to NRC in a letter dated September 18,
1987.
Within this letter the licensee also committed to meet with
the Region I management to discuss this and the other findings of
this inspection.
The licensee committed to provide the NRC with either the conclusions
of the study undertaken to verify that the breaker coordination "as
found" was acceptable or a description of the modifications made to
the associated circuits to achieve compliance with Appendix R within
60 days upon receipt of this report.
Pending completion and review of this study, the breaker coordination
issue as it relates to Appendix R is unresolved.
(50-311/87-2.9-08)
9.2 Spurious Signals Concern
Spurious ~ignals are a concern because of the following:
Fire initiated grounds, short or open circuits can cause false
motor control and instrument indications, such as those en-
countered during the 1975 Browns Ferry fire .
- .
14
Spurious operation of safety-related or non-safety-related
components can occur that would adversely affect shutdown
capability (e.g., RHR/RCS isolation valves).
The team examined, on a sampling basis, the fdllowing areas to
ascertain that no spurious signal concern exists:
Current transformer secondaries
High/low pressure interfaces
General fire instigated spurious signals
For the current transformer secondaries review, the team selected the
current transformers associated with the Emergency Diesel Generators.
The current transformer circuits reviewed were found to have their
secondary circuits protected from the effects of fire by the instal-
lation of Westinghouse
11teleductor
11 transducers on the current trans-
former secondaries.
A review of the manufacturers literature found
these devices to provide ample isolation in the event of a fire
induced open circuit on the current transformer secondaries.
The high/low pressure interface control method, the controls for fire
instigated spurious signals, and common enclosures will be the subject
of a future NRC inspection.
10.0 Emergency Lighting
10 CFR 50, Appendix R, Section III.J, requires that emergency lighting
units with at least an 8-hour battery power supply shall be provided in
all areas needed for operation of safe shutdown equipment and in access
and egress routes thereto.
The team examined the plant emergency lighting systems to ascertain the
licensee 1s compliance with the above requirements.
The team observed that
the licensee in their most recent surveillance of the lights had
identified a number of lights as degraded or inoperable.
The licensee stated that the reason repairs to these lights were not made
was the long lead time required to obtain parts from the manufacturers.
During the follow up inspection on December 15-18, 1987, the inspector
verified that these degraded lights were made operable.
Except for the above licensee identified concerns, the review of the
emergency lights did not identify any other unacceptable conditions.
15
11.0 Unresolved Items
Unresolved items are matters for which more information is required in
order to ascertain whether they are acceptable, violations, or deviations.
Unresolved items are discussed in Sections 6.0, 8.2 and 9.1.
12.0 Exit Interview
The inspection team met with the licens~e representatives, denoted in
Section 1.0, at the conclusion of the inspection on September 18, 1987,
and the team leader summarized the scope and findings of the inspection at
that time.
Licensee management made a commitment to provide the NRC a
justification for continuing operations with compensatory measures and a
commitment to meet with Regional Management to discuss the findings
identified in the report.
At no time during this inspection was written material provided to the
licensee by the'team.
13.0 Management Meeting
A Management Meeting was held on October 7, 1987 at the NRC Region I
offices between NRC and the licensee's management representatives. A list
of attendees at the meeting appears as Attachment 2 to this report.
This meeting was held because some of the findings described in this
report were significant enough to require that the licensee submit to the
NRC a Justification for Continued Operation (JCO).
Also, the licensee
via a letter transmitted to NRC committed to interim actions prior to the
issuance of the JCO to provide assurance of safe operation.
The interim
actions committed to by the licensee included the posting of continuous
and roving fire watches, the monitoring at the containment temperature,
provisions to detect fires in high radiation areas where posting of fire
watches is not possible, and reduce any backlog of maintenance requests on
fire protection equipment.
The JCO was transmitted to the NRC via a letter dated October 1, 1987,
subject
1110 CFR 50 Appendix R, Safety Evaluation Salem Generating Station,
Unit Nos. 1 and 2, Docket No. 50-272/50-311. 11
The purpose of the meeting was to discuss the contents of the JCO,
deficiencies itlentified during the inspection, the adequacy of interim
compensatory measures and the licensee's long-term plans for full
compliance.
16
The major deficiencies identified are described in detail in Sections
6.0, 7.0. 8.2 and 9.1 of this report.
They are the deficiencies
described in LERS 87-09 and 87-10, the lack of breaker coordination and
the possible loss of all communications required during hot shutdown if a
fire occurred in the Relay Room.
While all aspects of the JCO were discussed at the meeting, the major
topic was the lack of breaker coordination when offsite power is lost for
the 460V loads and lower voltage levels and the lack of documentation to
assure that breaker coordination exists when offsite power remains
available at the 4KV level.
The licensee made a presentation explaining why the deficiencies occurred.
The licensee's presentation material is included as Attachment 3 to
this report.
During the meeting the licensee made the following commitments:
1)
The licensee would resubmit a JCO by October 16, 1987.
This
submittal would include the assurance that breaker coordination of the
4KV vital buses exists when the offsite power remains available and
that non-safety-related associated circuits have either been
physically or electrically protected.
2)
The licensee would transmit to the NRC by November 20, 1987 a letter
with the schedule for the implementation of the corrective actions
for the deficiencies identified in LERs 87-09 and 87-10.
3)
As a result of questions probing beyond the scope of Appendix R,
the licensee committed to submit to the NRC by October 23, 1987
another JCO addressing breaker coordination with respect to external
- and internal hazards.
Specifically:
The effects of moderate energy line breaks on Unit No. 1
The effects of high energy line breaks inside and outside
Containment
Confirm that breaker coordination exists at the 4KV level and
above
Address the potential hazards on associated circuits.
4)
The licensee would complete the breaker coordination study by December
31, 1987 ;-
5)
The licensee would provide a schedule for the completion of the
modifica.tions for the breaker coordination work by January 31, 1988
and complete the relay setpoint changes by April 1, 1988.
ITEM
87-29-01
Section 6.0
87-29-02
Section 6.0
87-29-03
Section 6.0
87-29-04
Section 7.0
87-29-05
Section 8.1
87-29-06
Section 8.6
87-29-07
Section 8.2
87-29-08.
Section 9.1
CATEGORY
Violation
Deviation
Unresolved item
Violation
Violation
Unresolved item
Violation
Unresolved item
ATTACHMENT 1
SUMMARY OF FINDINGS
ITEM DESCRIPTION
A Fire in Fire Areas FA-AB-lOOA, 1008
and lOOC may cause the inadvertent
actuation of the C02 system in all three*
diesel generator rooms thus degrading the
diesels and causing the loss of all
emergency power.
Lack of detection in locations identified
in the fire hazard as having detectors.
Lack of Fire test documentation for the
Penetration seals.
LER 87-09 Revision 4 and LER 87-10 Unit 1
and 2 identify several instances where a
fire could damage safe shutdown systems and
prevent a safe shutdown.
Lack of SORC review of the Control Room
Evacuation Procedure represents a
T.S. Violation.
The licensee is performing repairs during
hot shutdown as action normally not allowed.
The licensee st~ted that NRC has reviewed
these actions.
A fire in the Relay Room may cause the loss
of radio communications required to achieve
, Lack of adequate circuit breaker
coordination could prevent safe shutdown.
PSE&G
C. McNeill
J. Zupko, Jr.
J. Boettger
W. Gailey
W. Pa vi nci ch
L. Miller
B. Preston
R. Bashal
C. Lambert
R. Skwarek
USN RC
A. Krasopoul os
F. Rosa
D. Chopra
T. Koshy
W. Kane
W. Johnston
J. Durr
P. Swetland
T. Kenny
E. Wenzinger, Sr.
R. Keller
L. Bettenhausen
ATTACHMENT 2
MANAGEMENT MEETING ATTENDEE LIST
Senior Vice President Nuclear
General Manager, Salem
Assistant Vice President
Manager, Projects
Pri nci pa 1 Engineer
Manager, Nuclear Engineering Services
Manager, Licensing and Regulation
Principal Engineer
Manager, Engineering Sciences
Project Manager, Special Projects
Reactor Engineer
Branch Chief, SELB
SEL8, Rev i e\\'ter
Reactor Engineer
Director, Division of Reactor Projects
Director (Acting), Division of Reactor Safety
Deputy Director (Acting), Division of Re*actor Safety
Chief, RPS 2B, Region I
Senior Resident Inspector
Chief, Reactor Projects Branch 2, Region I
Chief, Operator Licensing Section
Chief, RPB 1, Region I
ATTACHMENT
3
Agenda
NRC/PSE&G Meeting
Appendix R and Electrical
October 7, 1987
1.
Opening Remarks
2.
Response to NRC questions on October 2,
Safety Evaluation
3.
Fire Protection Program status/schedule
4.
Maintenance/operational program
S.
Electrical
Internal/external hazards
Procedures
August 1986 electrical event and
resultant program
6.
Management Overview
Design Bases Programs
C. A. McNeill
C. w. Lambert
C. W. Lambert
L. K. Miller
C. w. Lambert
L. K. Miller
R. W. Skwarek
C. A. McNeill
SALEM GENERATING STATION
UNITS 1 & 2
FIRE PROTECTION
IMPROVEMENT PROGRAM
I ....
FIRE PROTECTION
IMPROVEMENT PROGRAM
PROJECTS
- Fire Protection Commitment Verification Program
- Update of Systems Interaction Analysis
- Re-verification of the Fire Hazards Analysis
- Appendix R - Breaker Coordination Program
- Fire Barrier Penetration Seal Program
- Incorporation of Hope Creek Documentation
FIRE PROTECTION
IMPROVEMENT "PROGRAM
PROPOSED PRODUCTS
- Control Procedure
- . ,
-
SALEM APPENDIX R
ACTION PLAN
MANAGEMENT TEAM
LYNN MILLER
MANAGER -
NUCLEAR ENGINEERING SERVICES
0
ENGINEERING
c. LAMBERT
R. BAS HALL
R. SKWAREK
L. CORLE TO
R. DIAZ
D. SHUMAKER
TENERA LP
~ SITE PROTECTION
J. KERIN
R. BRAD DICK
0 OPERATIONS
B. CONNORS
0
LICENSING
B. PRESTON
R. SWARTZWELDER
2/3
ACTIVITIES COMPLETED TO DATE
0
MANAGEMENT TEAM IN PLACE
DP2/2
° FIRE WATCHES ESTABLISHED IN BOTH UNITS
0
DETECTION/MONITORING/SURVEILLANCE FOR AREAS OF HIGH RADIATION
CONDITIONS ESTABLISHED
0
OUTSTANDING WORK ORDERS ON FIRE PROTECTION ITEMS MINIMIZED
0
EMERGENCY LIGHTING ASSOCIATED WITH APPENDIX R REPAIRED
0
SAFETY EVALUATION ADDRESSING MEASURES TO JUSTIFY SAFE OPERATION OF
SALEM UNITS 1 & 2 REGARDING APPENDIX R DEFICIENCIES COMPLETE
0 OPERATIONS DEPARTMENT COGNIZANT OF PROCEDURES/GUIDELINES TO BE
IMPLEMENTED WITH RESPECT TO RESTORATION OF VITAL POWER SUPPLIES
I
Page No.
1
1*0/07/87
"APPENDIX R" ACTION PLAN
CALENDER OF EVENTS
sorted by date
MILESTONE DESCRIPTION
KEY
DATE
STATUS
APPENDIX "R" FIRE PROTECTION EVALUATION
01/01/87 ON60IN6
PROGRAM
APPENDIX "R" NRC AUDIT
APPENDIX "R" TASK TEAM FORMED
ADDITIONAL COMPENSATORY MEASURES
IMPLEMENTED
09/13/87 COMPLETE
09/18/87 WORKING
09/18/87 COMPLETE
SUBMITTAL OF JUSTIFICATION FOR CONTINUED 10/01/87 COMPLETE
OPERATION <JCO>
MEETING WITH N.R.C.
10/07/87
BREAKER COORDINATION STUDY -
VITAL BUSS
10/30/87 WORKING
REMARKS
MTS. SET FOR
1:30 P.M.
OF APPENDIX "R" EXEMPTION
10/30/87 WORKING
REQUIRES NRR
INSPECTOR
WALKDOWN ON
SITE
BREAKER COORDINATION & LONS TERM
ELECTRICAL DISTRIBUTION STUDY COMPLETE
<BOP>
DCP MODIFICATIONS INSTALLED
12/31/87
I
I
TO BE
DETERMINED
FIRE PROTECTION
IMPROVEMENT PROGRAM SCHEDULE
FIRE HAZARDS ANALYSIS UPDATE
CONSISTENCY WITH PLANT CONFIGURATION
ADDITIONAL CHANGES PER DCPS, ETC.
REVISED EXEMPTION REQUESTS
NRR WALKDOWN
FORMAL SUBMITTAL
PENETRATION SEAL PROGRAM
BEGIN WALKDOWNS
COMPLETE PROGRAM (OUTAGE COORDINATION REQ'D.)
CLOSE OUT PAPERWORK
IMPROVEMENT PROGRAM
FINAL REPORT
FINALIZE UNIT 2 INTERACTION ANALYSIS-DRAFT REPORT
FINALIZE UNIT 1 INTERACTION ANALYSIS-DRAFT REPORT
FINAL REPORT
COMMITMENT VERIFICATION PROGRAM
PROGRAM PLAN
CONTROL PROCEDURE
BREAKER COORDINATION
VERIFY DRAFT REPORT
BALANCE OF PLANr-EVALUATIONS
10/31/8 7
12/31/87
LATE OCT. 1987
LATE NOV. 1987
12/4/87
JULY 1989
SEPT. 1989
10/28/87
12/1/8 7
11/2 5/8 7
12/31/87
10/31/87
11/15/8 7
12/1/8 7
10/31/87
12/31/87
APPENDIX R PLANT MODIFICATIONS
SUBJECT TO EXEMPTION
REQUEST APPROVAL
2/1
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INTERNAL AND EXTERNAL
HAZARD CONSIDERATIONS
0
EXTERNAL CONDITION
-
-
FLOOD
-
TORNADO
-
0
INTERNAL CONDITION
-
SEISMIC II/I
-
INTERNAL MISSILES
- -
(VALVE STEMS, CONTROL
ROD DRIVE MECHANISM, ETC)
MODERATE ENERGY PIPE
FAILURE (SPRAY/FLOOD)
-
(OUTSIDE CONTAINMENT)
-
HELB/LOCA
(INSIDE CONTAINMENT)
/5
BREAKER COORDINATION CONSIDERATION
-
NO IMPACT
-
NO IMPACT, WATERTIGHT EXTERNAL
ENCLOSURES
-
NO IMPACT
-
NO IMPACT, RISK ANALYSIS AND
INSPECTION PRECLUDE FAILURE
-
NO IMPACT, PLANT DESIGN MEETS
INTENT OF R.G. 1.29
-
NO IMPACT
~ NOT A LICENSE BASIS
-
UNIT 2 ANALYZED/PRO~ECTED SUCH
THAT SAFE SHUTDOWN CAPABILITY
IS NOT.JEOPARDIZED
-
LIMITED CONSIDERATION: EXTREMELY
LOW PROBABILITY OF OCCURRENCE
-
SAFETY RELATED ELECTRICAL
EQUIPMENT
QUALIFIED FOR CONDITION
-
HIGH ENERGY LINES ENCAPSULATED
IN VARIOUS COMPARTMENTS
-
YES: EXTREMELY LOW PROBABILITY OF
OCCURRENCE
-
EOP'S AND OPERATIONS PROCEDURES
FOR RESTORATION OF VITAL POWER
AVAILABLE
STATUS OF LOSS OF ALL AC POWER PROCEDURES
WESTINGHOUSE OWNERS GROUP EMERGENCY RESPONSE GUIDELINES (ERGs)
-
ERGs CURRENTLY REVISION 1 -
ISSUED SEPTEMBER 1, 1983
-
ERG UPGRADE TO REVISION lA -
ISSUED JULY 1, 1987
-
ERG REVISION 1 APPROVED BY NRC - JULY 1986
-
ERG REVISION lA
-
PRESENTLY BEING REVIEWED BY NRC FOR
APPROVAL
SALEM EMERGENCY OPERATING PROCEDURES (EOPs)
-
EOPs CURRENTLY REVISION 1 -
ISSUED JUNE 1, 1987
-
EOP REVISION 1 INCLUDED UPGRADE OF ERGS REV lA
EOPs ASSOCIATED WITH LOSS OF ALL AC POWER
LOSS OF ALL AC POWER
LOSS OF ALL AC POWER
RECOVERY/SI NOT REQUIRED
LOSS OF ALL AC POWER
RECOVERY/SI REQUIRED
CURRENT STATUS
- EOPs ARE CURRENT TO LATEST GUIDELINE
(
EMERGENCY OPERATING PROCEDURES
- REACTOR TRIP OR SAFETY INJECTION
- LOSS OF ALL AC POWER
- LOSS OF ALL AC POWER
RECOVERY/SI NOT REQUIRED
- LOSS OF ALL AC POWER
RECOVERY/SI REQUIRED
ABNORMAL OPERATING PROCEDURES
AOP-ELEC-4KV-A
AOP-ELEC-460/230V-A
AOP-ELEC-VIB-A
AOP-ELEC-125V-A
AOP-ELEC-28V-A
AOP-ELEC-4KV-B
AOP-ELEC-460/230V-B
AOP-ELEC-VIB-B
AOP-ELEC-125V-B
AOP-ELEC-28V-B
AOP-ELEC-4KV-C
AOP-ELEC-460/230V-C
AOP-ELEC-VIB-C
AOP-ELEC-125V-C
- LOSS OF 2A 4KV VITAL BUS
- LOSS OF 2A 460/230V VITAL BUS
- LOSS OF 2A llSV VITAL INSTRUMENT
BUS
- LOSS OF 2A 125VDC BUS
- LOSS OF 2A 28VDC BUS
- LOSS OF 2B 4KV VITAL BUS
- LOSS OF 2B 460/230V VITAL BUS
- LOSS OF 2B llSV VITAL INSTRUMENT
BUS
- LOSS OF 2B 125VDC BUS
- LOSS OF 2B 28VDC BUS
- LOSS OF 2C 4KV VITAL BUS
- LOSS OF 2C 460/230V VITAL BUS
- LOSS OF 2C llSV VITAL INSTRUMENT
BUS
- LOSS OF 2C 125VDC BUS
- LOSS OF 21 MAC llSV DISTRIBUTION
CABINET
- LOSS OF 22 MAC llSV DISTRIBUTION
CABINET
SEPTEMBER 1986
DECEMBER 1986
JANUARY 1987
FEBRUARY 1987
MARCH 1987
RS(l)l 2
ACTIONS TAKEN
0 DEVELOPED DETAIL EVALUATION TO
DEFINE ROOT CAUSE OF PROBLEM.
°CONTRACTED PTI TO DEVELOP TRANSIENT
VOLTAGE PROFILE.
RESULTS INDICATED RECOVERY VOLTAGE
AT 92.9% WORST CASE.
0 INSTALLED TEMPORARY FEED FROM HOPE
CREEK SUB-STATION TO REMOVE
APPROXIMATELY 6 MVA LOAD FROM EACH
SALEM UNITS ELECTRICAL DISTRIBUTION
SYSTEM.
THREE CIRCULATING WATER
PUMPS FROM EACH SALEM UNIT WAS
POWERED FROM THIS TEMPORARY FEED.
THIS ALLOWED TO RETURN TO 100%
POWER.
0 DEVELOPED SHORT TERM FIX TO ADJUST
SECOND LEVEL UNDER VOLTAGE
PROTECTION RELAY FROM 95% TO 92-6%.
THIS RESOLVED THE FLIP-FLOP
ISSUE~
0 TASK FORC~ DEVELOPED LONG TERM
PROGRAM TO ASSURE A SAFE AND
RELIABLE DISTRIBUTION SYSTEM.
SALEM GENERATING STATION
ELECTRICAL DISTRIBUTION SYSTEM IMPROVEMENT STUDY
GOAL:
ASSURE A SAFE AND RELIABLE ELECTRICAL DISTRIBUTION
SYSTEM
OBJECTIVES:
1)
DEVELOP A COMPREHENSIVE DESIGN BASIS INCLUDING:
A)
DESIGN DOCUMENTS
a)
CALCULATIONS
c>
PROCEDURES
o)
NRC LICENSING ISSUES
2)
ANALYZE SYSTEM DEFICIENCIES/WEAKNESSES
3)
DEVELOP FEASIBILITY STUDIES FOR SYSTEM IMPROVEMENT
oe_T10Ns
RSCI>l 1
VB15
SALEM ELECTRICAL DISTRIBUTION SYSTEM
IMPROVEMENT PROGRAM
PHASE 1
MARCH, 1 CJ87 (ACTUAU
DECEMBER, 1CJ87 IFORECASTl
o~---------------0
- DESIGN DATA COLLECTION
- VOLTAGE LEVEL EVALUATION
- CALCULATIONS
(SHORT CIRCUIT.VOLTAGE DROP,ETCJ
- COMPILE DATA
PHASE 2
- FURTHER ANALYSIS & EVALUATION
- DEVELOP CORRECTIVE ACTIONS
- DEVELOP MULTIPLE OPTIONS THAT
RESOLVE ACTIONS
PHASE 3
o RECOMMEND AND IMPLEMENT SELECTED
ALTERNATIVES
o DETAIL DESIGN
o PROCUREMENT ACTIVITY
o IMPLEMENT PHYSICAL MODIFICATION
\\!I
JANUARY, 1988 (FORECAST)
0----------9
OCTOBER, 1987 (ACTUAL!
w _____
____...,
0
,
JANUARY. 1988 (FORECASTl
<.
PHASE 1
DEVELOP A COMPREHENSIVE DESIGN BASIS INCLUDING:
0 DESIGN DATA COLLECTION
DRAWINGS
EQUIPMENT SPECIFICATIONS
EXISTING DESIGN CALCULATIONS
0 VOLTAGE SYSTEMS ANALYZED
25KV1 13KV1 4KV1 4801 2301 115vAc 2501 1251
28vnc <VITAL/NON VITAL>
°CALCULATIONS/COMPUTER PROGRAMS
VOLTAGE PROFILE
SHORT CIRCUIT
VOLTAGE DROP
COORDINATION
MOTOR STARTING
EQUIPMENT SIZING
°COMPILE DATA
RSCI>l 3
DEVELOP HARD COPY DATA BASE
-
IDENTIFY POTENTIAL DEFICIENCIES
IDENTIFY DRAWING DISCREPANCIES
PHASE 2
°FURTHER ANALYSIS AND EVALUATION REQUIRED
°CORRECTIVE ACTION REQUIRED
ANALYZE FOR IMPACT TO SAFETY SYSTEMS
(SAFETY EVALUATION>
0 DEVELOP OPTIONS TO ADDRESS LOAD GROWTH
PHASE 3
0 IMPLEMENT DESIGN OF APPROVED LONG TERM OPTION
DESIGN, PROCUREMENT, INSTALLATION
RSCl)l 4
PHASE I.
PHASE I
COMPLf.Tt-:
PHASE 2a
NO'ACTION
Rf:OUlRt:D
f:LEC'TRI C'AL POWF:R SYSTF:M ANALYSIS PROCESS
INf-'ORMATION .-..-----.
GATHERED
ADllITIONAJ.
r----ill~ INl-'ORMATION
Nt-:~:OF:D
NO SJGNlf-'IC'AN1
SAFETY
JMPACT
POTENTIAL
RfCOMMF.NDED
t------------t1-. CORRECT IV P.
AC'TION
NO
SAFF.TY
IMPACTt----~
EXISTS
NOTIFY PLANT
TO INITTATF.
INClllE:NT
EVENT Rf:POR1
- ' r;._
t---.. IMPLEMENTATIOtoi