IR 05000220/1982009
| ML20062E819 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 07/23/1982 |
| From: | Beckman D, Paolino R, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20062E792 | List: |
| References | |
| 50-220-82-09, 50-220-82-9, NUDOCS 8208100333 | |
| Download: ML20062E819 (9) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-220/82-09 Docket No.
50-220 Category C
License No.
DPR-63 Priority
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Licensee:
Niagara Mohawk Power Corporation 300 Erie Boulevard West Syracuse, New York 13202 Facility Name:
Nine Mile Point Unit 1 Inspcction At:
Scriba, New York Inspection Conducted:
June 15-18, 1982 Inspectors: b 7/23 82-S. Richards, Reactor Inspector
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R.fiolino,.eactorInspector
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7!ZJf47 Approved by:
Ic ws wcm 1T. Beckman, Chief, Plant Systems Section aate'
Inspection Summary:
Inspection on June 15-18, 1982 (Report No.
50-220/82-09)
Areas Inspected:
-Routine unannounced inspection of the plant Fire Protec ion /
t Drevention Program in the areas of administration; maintenance, inspection and testing; training; and program implementation.
The inspection involved 62 inspector hours on site by two region-based inspectors.
Results: Of the four areas inspected, no violations were identified in three areas. One violation was identified in one area:
(Failure to follow procedure, paragraph 7 (a))
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8208100333 820723 PDR ADOCK 05000220
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DETAILS 1.
Persons Contacted D. Balduzzi, Supervisor Document Control
- J. Corcoran, Supervisor Fire Protection
- W. Drews, Technical Supervisor Nuclear Generation J. Gombas, Fire Brigade Chief
- S. Hudson, NRC Senior Resident Inspector D. Kehoe, Fire Brigade Chief J. Lynk, Director Niagara Mohawk Firefighting School F. McKineley, Modification Coordinator D. Neild, Station Shift Supervisor
- D. Palmer, Supervisor QA Nuclear Operations
- J. Pavel, Training Supervisor T. Perkins, General Superintendent Nuclear Generation
- R. Raymond, Fire Protection Supervisor
- T. Roman, Station Superintendent
- J. Scofield, Fire Training. Specialist - Nuclear
- G. VanGelder, Assistant Supervisor Fire Protection P. Volza, Emergency Planning Coordinator
- Denotes those personnel who were present at the exit interview.
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2.
Regulatory Requirements As stated in 10 CFR 50.48(b), the requirements of 10 CFR 50, Appendix R apply, except for those fire protection 'eatures proposed or implemented by the licensee which have been previously accepted by the NRC as satisfying the provisions of Branch Technical Position (BTP) 9.5-1, Appendix A as reflected in the NRC staff fire protection Safety Evaluation Report (SER). The Nine Mile Point Unit I SER, Fire Protection Review, was issued July 26, 1979, in conjunction with Technical Specification Amendment 33.
The inspectors noted that the licensee had established a full time professional fire brigade rather than assign this duty to existing staff members as a collateral function. This dedication of extensive resources reflects a substantial licensee commitment to fire prevention and protection. Transition of program functions to the new organization is in progress. Additional management attention to the transition and acceptable implementation of the fire prevention / protection program during the transition is discussed below.
3.
Action on Previous Inspection Findings (Closed) Unresolved Item (50-220/81-15-02):
Need for installation of rated fire dampers in the turbine oil storage tank room. The inspector verified that fire dampers have been installed in the ventilation openings for the turbine oil storage tank room. This item is closed.
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4.
Fire Protection / Prevention Program Administration a)
The inspector reviewed the following documents to verify that the licensee has developed adequate procedures consistent with Technical Specifications, the fire protection Safety Evaluation Report, Branch Technical Position 9.5-1 and 10 CFR15!, Appendix R:
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Site Administrative Procedure APN-2, Composition and Responsibilities of Site Organization, Rev. 4
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APN-2A, " Conduct of Operations and Composition and Responsibilities of Station or Unit Organization", Rev. 5
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APN-20, Station Fire Protection Program,.Rev. 3
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APN-11, Housekeeping and Cleanliness Control, Rev. 2
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Fire Protection Quality Assurance Program, Nine Mile Point Unit 1, dated March 25, 1979
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Emergency Plan Implementing Procedure No. EPP-2, Fire Fighting, Rev. 6
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Fire Fighting Preplans numbered 1-12 Chief Nuclear Firefighter Instructions dated May 7, 1982
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Fire Prevention Procedure No. N1-FP-2, Welding and Cutting,
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Rev. 3
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Procedure No. N1-FP-6, Fire Watch, Rev. 0
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Procedure No. N1-FP-7, Combustible Materials Storage Procedure, Rev. 0 Procedure No. N1-FP-3, Contractors and Subcontractors,
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Rev. 1 Procedure No. N1-FP-1, Supervisors Weekly Plant Tour, Rev.1
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Job Descriptions for various fire fighting positions NMP Unit 1 Technical Specifications related to fire protection
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Fire Protection Safety Evaluation Report for Nine Mile Point Unit 1
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Nine Mile Point Unit-1 Facility Modifications N1-81.35 (June 23,1982), N1-81.36 (June 2,1981), N1-82.03 (January 26,1982) inspected for evidence of licensee fire protection hazard review.
Fire Protection audits of August-1, 1979, November 1980,
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March 16-20, 1981, September 21-23, 1981, and November 9-13, 1981 b)
Technical Specification Amendment 33 requires modifications to the fire protection program be completed as described by the fire protection SER. The SER requires administrative changes, including the development of fire fighting preplans, to be completed oy September 1, 1979. An NRC letter dated February 3, 1978 and BTP 9.5-1 provide guidelines for the preplans and require the following subjects to be addressed:
identification of combustibles in each plant zone, fire extinguishants best suited to fight the fire, strategies to follow to attack the fire, plant systems management to reduce damage potential, designation of vital heat-sensitive system components, fire brigade organization, identification of
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hazards in each plant zone, ventilation system operation requirements, and instructions for various plant personnel. The licensee committed to complete fire fighting preplans by June 29, 1979 in a letter dated January 2, 1979 to the NRC Director of Nuclear Reactor Regulation (NRR). The inspector reviewed the licensee's preplans and found they did not address all of the guidelines of BTP 9.5-1.
The plans consisted of 12 drawings indicating the location of major plant equipment, fire fighting equipment, and accesses to the areas. Discussions with licensee management indicate the fire preplans were found acceptable by an NRC inspection team providing input to the SER, however, the licensee agreed with the need to upgrade the preplans.
The licensee committed to rewrite the preplans by January 1,1983, and to train fire brigade leaders within 60 days and fire brigade members within 120 days of plan approval. The licensee committed to control the. preplans as approved documents and to address all guidelines of BTP 9.5-1 in either the preplans or the associated training.
This item is unresolved pending NRC review of licensee action. (50-220/82-09-01)
c)
The inspector noted that, in the following cases, existing procedural requirements do not specifically comply with the BTP 9.5-1 guidelines endorsed by Amendment 33.
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Administrative procedures to control combustibles do not govern the handling of and limitation on the use of combustibles, the limiting of transient fire loads, or the treatment of all wood in safety related areas with flame retardant.
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Combustibles are required to be removed at the end of work or as necessary, instead of at the end of work or at the end of each shift, whichever is sooner.
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Combustible material within 35 feet of welding or cutting is not required to be covered or removed from the area.
The licensee committed to review and revise procedures to specifically address guidelines of BTP 9.5-1 within 120 days of June 25, 1982.
This item is unresolved pending NRC review of licensee action.
(50-220/82-09-02)
d)
The Nine Mile Point Unit 1 fire brigade composition accepted by the SER consisted of a licensed opertor as brigade leader, two auxiliary operators, and two security guards.
In July 1981, the licensee informed the NRC that the brigade composition was changed to five professional firefighters augmented by a licensed operator to advise the brigade leader.
The licensee implemented this
composition in the fall of 1981 and has begun training the brigade
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members in plant systems to comply with the 10 CFR 50, Appendix R, requirement that the leader and two members of the brigade must be knowledgable in plant systems. While the brigade composition is not in strict compliance with Appendix R requirements, the i
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inspector considers it advantageous to man the fire brigade with professional fire fighters and that the licensee has displayed extraordinary initiative in establishing a large, full time brigade. -The licensee has committed to submit an exemption request responsive to 10 CFR 50.48 to NRR and to complete plant systems tr-ining for brigade members by January 1, 1983. This item is unresolved pending NRC review of licensee action. (50-220/82-09-03)
e)
During procedure reviews, the inspector identified the following procedures for which biennial QA review was overdue: Procedure Nos. APN-4, APN-8A, APN-10A, APN-108, APN-10C, APN-100, APN-13.
Two of these items were identified by the licensee in the March, 1982 QA composite audit. The licensee was in the process of taking corrective action. This item is unresolved pending NRC review of licensee action.
(50-220/82-09-04).
5.
Maintenance, Inspection, and Testing a)
The inspector reviewed the following documents associated with maintenance, inspection, and testing of fire protection equipment to verify that procedures are adequate and consistent with regulatory requirements.
Operator Surveillance Test Proceduro No. N1-ST-W14, Fire
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Protection System - Weekly Operator Routine, Rev. 4
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Procedure N1-FST-A1, Fire Hose Hydrostatic Test, Rev.1
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Procedure N1-FST-W10, Weekly Fire System Valve Checkoff, Rev. 0
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Procedure N1-FST-W2, Suppression Gas Readings, Rev. 0
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Procedure N1-FST-A3, Hydrant Flushing and Valve Cycling, Rev. 0
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Procedure N1-FST-D1, Fire Door Inspection, Rev. 0
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Procedure N1-ST-A2, Hose Station Valve Operability Test, Rev. 0
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Procedure N1-ST-A1, Annual Valve Cycling for Fire Protection Systems, Rev. 2 Preventative Maintenance Procedure No. N1-PM-M2, Fire Protection
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i System - Monthly Operator Routine, Rev. 7 b)
When reviewiag completed data sheets associated with procedure N1-ST-W14, the inspector noted that the discharge pressure recorded for fire pump testing was consistently above the stated limit of 145 psi and that the test was completed satisfactorily with no explanation for the discrepancy. Although the fire pump appeared
to function properly, the inspector questioned the ability of' personnel to determine if the test was satisfactory. The
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licensee agreed to review the data sheets for proper acceptance criteria and revise them as necessary. This item is unresolved pending NRC review of licensee action.
(50-220/82-09-05)
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c)
During inspector review of fire protection surveillances, the licensee could not locate the following data sheets:
N1-ST-M10 for January and February 1982, and N1-FST-Al for September-December, 1981. Discussions with the licensee indicate that maintenance of the surveillance record files was recently reassigned to a new office and that difficulties with record filing have been previously identified by a licensee audit. The licensee committed to review their files for the missing data sheets.
This it?m is unresolved pending NRC review of the data sheets.
(50-220/82-09-06)
d)
Branch Technical Position 9.5-1 and the Nine Mile Point Unit 1 Fire Protection SER does not address surveillance requirements for fire doors. Appendix R to 10 CFR 50, section III.N, requires that self-closing fire doors be inspected semi-annually to verify operability of closing mechanisms. As required by 10 CFR 50.48(b),
the licensee must satisfy the Appendix R requirement.
The inspector noted that procedure N1-PM-C10 requires the actuating mechanisms on self closing fire doors be checked on an annual basis. The licensee committed to increase the procedure's inspection frequency to semi-annually. This item is unresolved pending NRC review of licensee corrective action.
(50-220/82-09-07)
6.
Fire Training a)
The inspector reviewed the following documents associated with fire brigade and employee training to verify that the licensee's training program is in compliance with regulatory requirements and licensee commitments.
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Site Administrative Procedure No. APN-10E, Fire Brigade Training, Rev. 2
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Fire Training Program Lesson Plan, " Fire Chemistry, Theory, and Physics", dated February 26, 1982
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Fire Training Program Lesson Plan, Rope and Rigging, dated April 9, 1982
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Fire Training Program Lesson Plan, " Fire Extinguishers",
dated April 30, 1982
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Report of Fire Brigade Activity / Drills dated April 19, 1982, and three reports dated April 28, 1982
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Ten Fire Brigade Training Weekly Reports
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Niagara Mohawk Corporation Firefighters Fitness Test, dated June, 1981
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Training Outline for Niagara Mohawk Fire Training School entitled, "Three Day Training Session" and "One Day Refresher Course"
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General Employee Fire Protection Training Outline dated January 19, 1981
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General Employee Training Lesson Plan, " Site Emergency Plan
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Implementing Procedures", dated May 20, 1981 Training Records for 2 Firefighters and I general employee
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Proposed procedure APN-10P, Nuclear Fire Fighter and Nuclear Fire Chief Training.
b)
Amendment No. 33 to the licensee's Technical Specifications and the fire protection SER founu that the licensee's training program
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satisfied the provisions of BTP 9.5-1, Appendix A,-based in part on the licensee's letters dated April 10, 1978 and October 6, 1978 to the Director of Nuclear Reactor Regulation.
The letter of April 10, 1978 verified Nine Mile Point-Unit I compliance with BTP 9.5-1, Appendix A, provisions for classroom instruction, practice sessions, and drills.
The letter of October 6, 1978 verified compliance with the provisions governing fire drills.
The inspector noted that the procedures for training are not completely consistent with the guidelines and licensee commitments in the following areas:
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Procedures do not require fire brigade members to repeat the classroom instruction program every two years Procedures do not require regular planned meetings every 3
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months Procedures do not require unannounced drills for each fire
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brigade at least once per year
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Procedures do not require assessment of each member's performance in drills The inspector observed that fire brigade training and drills, however, are being conducted on a regular basis in excess of that required by Appendix R and BTP 9.5-1.
Long term control and content of training could, however, be compromised with incomplete procedures. This item is unresolved pending NRC review of licensee corrective action.
(50-220/82-09-08)
c)
The inspector toured the Niagara Mohawk Fire Fighting School and observed a portion of a training exercise demonstrating various firefighting techniques. The school appeared to be well equipped and professionally conducted.
7.
Facility Tour and Observation of Work Activities a)
The inspector toured the plant facilities to verify implementation of the fire protection and prevention program.
The inspector
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noted that welding was being conducted in the Screen and Pump House with a proper welding and cutting permit posted. The inspector was unable to locate the fire watch who is required to be stationed by procedure N1-FP-2, " Welding and Cutting". A licensee representative attempted to locate a fire watch in the area but was also unsucessful.
Discussion with a supervisor indicated that the welder and fitter functioned as a team with i
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the fitter assigned duties as the fire watch. When questioned, the fitter indicated that he was not the fire watch and, although a fire watch had been designated, the watch had left the area.
This is a violation of 10 CFR 50, Appendix B, criterion V, the licensee's Fire Protection QA plan, and procedure N1-FP-2.
(50-220/82-09-01)
b)
During the tour, various fire fighting systems and equipment were inspected. The inspector identified the following fire hoses as having last been hydrostatically tested in November, 1980, as indicated by the date stenciled on the hose:
Fire hoses FS 110, 111, 127, 139.
Procedure N1-FST-Al requires fire hoses be hydrostatically tested on an annual basis. The inspector noted that the licensee Technical Specifications require the hoses to be tested at least every three years and that the licensee is in compliance with this requirement. The licensee stated difficulties had arisen due to the fire brigade reorganization and nrocedure revisions.
The licensee agreed to hydrostatically test the hoses immediately.
This item is unresolved pending future NRC inspection of this activity.
(50-220/82-09-09)
c)
The inspector noted that a run of cable tray outside the battery board room appeared to have insufficient coverage by sprinkler sytems. A licensee representative stated that the sprinklers normally spaced 10 feet apart and staggered so that the risers alternate the height of the sprinklers. The inspector noted that a baffle placed over each sprinkler head could prevent sufficient water coverage to the upper cable tray. The inspector also observed that the distance between sprinkler heads outside the battery board room is greater than the normal spacing. The licensee agreed to evaluate the problem. This item is unresolved pending NRC review of licensee action.
(50-220/82-09-10)
d)
The inspector observed.the following unattended combustible material during the tour:
3 large cans of lubricating grease and a can of motor oil in
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the diesel driven fire pump room.
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A bucket of resin in the turbine oil storage room
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A 1 gallon can of oil in the hydrogen seal unit room.
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A 1 gallon can of oil in the northwest corner of the reactor building by the stairwell on elevation 281.
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A 55 gallon drum stenciled " KEROSENE" located in the turbine building by the entrance to diesel board room 103 via fire door 117.
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Wooden crates, packing material, boxes, and wooden ladders at various points throughout the plant.
The inspector noted that the plant is in an extended outage period and the reactor is defueled. The licensee has agreed to
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review administrative procedures governing control of combustibles as discussed in paragraph 4 above.
8.
Unresolved Items Unresolved items are matters about which more information is_ required to ascertain whether they are acceptable items,_ violations or deviations.
Unresolved items disclosed during the inspection are discussed in paragraphs 4, 5, 6, and 7.
9.
Exit Interview The inspector met with the licensee representatives denoted in Details, paragraph I at the site on June 18, 1982 and summarized the purpose and scope and findings of the inspection.
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