IR 05000220/1988032
| ML17055E412 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/21/1988 |
| From: | Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17055E411 | List: |
| References | |
| 50-220-88-32, NUDOCS 8901050121 | |
| Download: ML17055E412 (18) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-220/88-32 Docket No.
50-220 License No.
DPR 63 Priority Category C
Licensee:
Niagara Mohawk Power Corporation ATTN:
Mr. C.
V. Mangan Senior Vice President 301 Plainfield Road Syracuse, New York 13212 Facility Name:
Nine Mile Point Unit
Inspection At:
Scriba, NY Inspection Conducted:
October 31 - November 3, 1988 p
'Inspectors:
rer Al"c>o o
/e~
Aristidis G. Krasopoulos, Reactor Engineer, Plant Systems Section, EB, DRS Approved by:
C. J. Anderson, Chief, Plant Systems Section Z.g 8'
date date Ins ection Summar
Ins ection on October 31 - November-3.
1988*
Re ort-Number 50"220/88-32 Areas Ins ected:
Routine unannounced inspection of the Fire Protection/Prevention rogram including:
program administration and organization; administrative control of combustibles; administrative control of ignition sources; other administrative controls; equipment maintenance, inspection and tests, fire brigade training; periodic inspections and quality assurance audits; and facility tours.
Results:
No violations 'were identified and one item remained unresolved.
85'01050121 I Si222 PDR ADOCK 05000220 Q
DETAILS 1.0 Persons Contacted Nia ara Mohawk Power Cor oration A. Andersen, Fire Protection Supervisor G. Montgomery, Regulatory Compliance A. Curran, Jr.
P. Finnerty, Fire Protection Outage Task Manager M. Berry, Fire Protection Engineer P. Nicholoson, Fire Protection Engineer N. Radamacher, Director of Compliance G. Gresock, Manager, Nuclear Engineering N. Chambers, QA Audits K. Dahlberg, Station Superintendent R. Randal, Operations Superintendent D. McNally, Fire Protection E. York, Fire Protection Coordinator T. Perkins, Fire Protection W. Connoly, QA 1.2 Nuclear Re ulator
.Commission NRC W. Cook, Sr~ Resident Inspector M. Banergee, Project Engineer 2.0 Follow u of Previous Ins ection Findin s
0 en Violation 88-15-01 A and B
Failure to install ade uate fire seals and failure to establish rom t corrective actions For item A of the violation the NRC determined that Technical Specification LCO 3.6. 10. 1 and Appendix R to
CFR 50 were violated when certain fire barriers were found to contain improperly sealed penetrations.
The corrective actions described by the licensee included:
a re-review of the Fire Barriers; a destructive examination of a number of penetrations to determine the percentage of acceptably sealed penetrations; and the issuance of a new procedure that would govern the administration of the'jre Protection Progra The inspector was unable to verify the licensee's corrective actions for violation 88-15-01 A and B due to the incomplete status of the subject activities.
The inspector noted that progress has been made towards resolution of the issues but significant portions were unavailable for review at the time of this inspection and will be reviewed during a later inspection.
The specific issues that require completion by the licensee and review by the NRC include:
(1) the statistical method used to demonstrate confidence that the penetration seals will perform as designed; (2) the program procedure that wi 11 address the fire protection program management and implementation; and, (3) Part B of the violation, the corrective actions that address the finding that audits were not promptly and permanently corrected.
Section 3.7.2 of this report discusses a
simi1ar finding'.
This item remains open pending completion of the licensee's corrective actions and review by the NRC.
Closure of these items is a condition for restart from the current outage.
Cl osed Viol ation 88-08-01 Failure to revent missed fire watches The NRC identified the concern that corrective measures taken to prevent missing fire watch patrols were ineffective.
This concern was generated
.after the licensee missed a fire watch in April 1988.
This occurred after three similar events in 1987.
The licensee explained that this violation occurred as a result of miscommunications rather than as a result of previous inadeqoate correc-tive actions.
The corrective measures to prevent a recurrence of this deficiency consisted of:
instructions to the shift supervisors; counseling of the individual involved; and issuance of a Lessons Learned transmittal to operations personnel.
These corrective actions were determined to be adequate.
This item is resolved.
3,0 Fire Protection/Prevention Pro ram The inspector reviewed the below listed.documents relating to the following areas of the program to verify that the licensee had developed and imple-mented adequate procedures consistent with the Fire Hazard Analysis (FHA),
Final Safety Analysis Report (FSAR),
and Technical Specifications (TS).
The documents reviewed, the scope of review, and the inspection findings for each area of the program are described in the following section.1 Pro ram Administration and Or anization The inspector reviewed the following licensee documents:
Technical Specifications, Section 6, Administrative Controls Administrative Procedure AP-3.5, Station Fire Protection Program The scope of review was to ascertain that:
a.
Personnel were designated for implementing the program at the site; and, b.
gualifications were delineated for personnel designated to implement the program.
No unacceptable conditions were identified.
3.2 Administrative Control of Combustibles The inspector reviewed the following licensee documents; Administrative Procedure AP-7.2 Control of Material Storage Areas, Revision 2.
Procedure S-FDP-7 Controlled and Storage of Combustible and Flammabl'e Materials, Revision 0; The scope of review was to verify that the licensee had developed'dministrative controls which included:
a.
Special authorization for the use of combustible, flammable or explosive hazardous material in safety-related areas; b.
Prohibition on the storage of combustible, flammable or explosive hazardous material in safety-related areas; C.
d.
The removal of all wastes, debris, rags, oil spills or other combustible materials resulting from the work activity or at the end of each work shift, whichever is sooner; All wood used in safety-related areas to be treated with flame retardant; e.
Periodic inspection for accumulation of combustibles; Transient combustibles to be restricted and controlled in safety-related areas; and
g.
Housekeeping to be properly maintained in areas containing safety-related equipment and components.
No unacceptable conditions were identified.
3.3 Administrative Control of.I nition Sources The inspector reviewed the following licensee documents:
Cutting, Welding, Grinding Permit Procedure No. S-FDR-2, Revision 0.
The scope of review was to verify that the licensee had developed administrative controls which included:
a
Requirements for special author'ization (work, permit). for activities involving welding, cutting, grinding, open flame or other ignition sources and that they are properly safeguarded in areas containing safety-related equipment and components; and, b.
Prohibition on smoking in safety-related areas,except where
"smoking permitted" areas had been specifically designated by plant management.
No unacceptable conditions were identified, however, the inspector observed that the licensee does not have an Administrative Procedure governing the use of ignition sources.
The licensee in a letter dated April 10,'978, committed to have such controls.
The inspector observed that even though such a procedure was missing, all aspects of these re-quirements were observed by the use of a hot work permit procedure.
The licensee committed to issue an Administrative Procedure to govern use of ignition sources.
3.4 Other Administrative Controls The inspector reviewed the following licensee documents:
Technical Specifications, Section 6, Administrative Controls AP 3.5 Station Fire Program AP 6.0 Procedure for Modifications AP 6.2 Procedure for Minor Modifications AP 9.0 Administration of Training The scope of review was to verify that the licensee had. developed administrative controls which require that:
a.
Work authorization, construction permit or similar arrangement is provided for review and approval of modification, construction and maintenance activities which could adversely affect the safety of the facility;
b.
Fire brigade organization and qualifications of brigade members are delineated; c.
Fire reporting instructions for general plant personnel are developed;,
d.
Periodic audits are to be conducted on the entire fire protection program; and, e.
Fire protection/preventation program is included in the licensee's gA Program.
No unacceptable conditions were identified.
3.5 E ui ment Maintenance Ins ection and Tests The inspector reviewed the following documents to determine whether the licensee had developed adequate procedures which establish maintenance, inspection, and testing requirements for the plant fire protection equipment:
Fire Damper Operation and Inspection, Nl-FST-FPP-C002-5 FPW System Flow.Test, N1-FST-FPN-3A001 LP C02 System Functional Test Nl-FST-FPL-SA-008-11 Fire Hydrant Inspection System Flush Nl-FST-FPW-SA001-6 HALON "Puff".Testing Nl-FST-FPG-A001-12 Electric/Diesel Fire Pump Functional Test N1-FST-FPN-C001-5 r
In a'ddition to reviewing the above documents, the inspector reviewed the maintenance/inspection/test records of the items, to verify compliance with Technical Specifications and established procedures.
In reviewing the survei llances mentioned above the inspector observed that a Fire Damper inspection determined that'ome fire dampers were inoperable'he inspector questioned whether the licensee posted a fire watch in the affected areas as required by the Technical Specifications.
The licensee stated that fire watches were not posted specifically for the inoperable fire dampers because of personnel error.
The error
.
occurred when the Fire Department Chief responsible for reviewing the results of the surveillance procedure failed to recognize that certain dampers were found inoperable and did not post a fire watch.
A second review of these results identified that a mistake had been made.
The licensee ultimately did not post a fire watch in the affected area for the inoperable dampers becau'se the area was already being surveilled by fire watches placed there for other reasons.
Since the area was already protected, the licensee determined that reporting this event was not a
requiremen The inspector also reviewed the maintenance request list to determine the operational status of the fire protection equipment.
This review did not identify any unacceptable conditions.
However, the inspector observed that repairs and maintenance to Emergency Lights are performed as "fill
.in" work for the electricians.
The inspector raised the concern that repairs to the Emergency Lights that are required to achieve shutdown may not get properly prioritized.
The licensee agreed with this concern and committed to address it promptly.
No unacceptable conditions were identified.
3.6 Fire Bri ade Trainin 3.6. 1 Procedure Review The inspector reviewed the following licensee procedures:
AP9.0 Administration of Training, Revision
NTP-5 Nuclear Fire Chief and Nuclear Fire Fighter Training Program Revision
The scope of review was to verify that the licensee had developed
. administrative procedures which included:
a.
Requirements for announced and unannounced drills; b.
Requirements for fire brigade tr'aining and retraining at prescribed frequencies; C.
Requirements'or at least one drill per year to be performed on a
"back shift" for each brigade',
'
Requirements for maintenance of training records.
No unacceptable conditions were identified.
3.6.2 Records Review The inspector reviewed training records of fire brigade members for calendar years 1987 to 1988 to ascertain that they had attended the, required quarterly training and participated in a quarterly drill, and received the annual hands-on fire extinguishment practice.
.During the plant tour, the inspector questioned the adequacy of training given to fire watches.
While the inspector was in Battery Board Room No.
11, a fire watchman entered the room and signed the Fire Watch room posting.
The fire watchman left without patrolling the room.
Because his view of the majority of the room was obstructed by the Battery Boards, the inspector asked the watchman whether he should have checked the entire
room.
The watchman was unsure of the specific actions required of him.
The inspector directed the watchman to the lessons plans which require that fire watchers patrol the area, not merely sign the room posting.
The licensee was appraised of the NRC inspector's concern.
No other unacceptable conditions, were identified, 3.7 periodic Ins ections and.
ualit Assurance Audits 3.7.'
Annual and Biennial Audit The inspector reviewed the report of audit No. 87026-RG/IN.
The scope of review was to ascertain that the audit was conducted in accordance with the Technical Specifications Sections 6.5.3 AS.g and 6. 13. 1.
3.7.2 Triennial Audit The inspector reviewed the report of triennial audit SY-RG-IN-86020.
The scope of review was to ascertain that the audit was conducted in accordance with the Technical Specifications Section 6. 13.2.
.The. inspector noted that in general the audits were comprehensive.
However, the audit findings are not always addressed'romptly or adequately.
The NRC previously issued a violation in this area which is currently being resolved by the licensee.
(See Section 2 of this report - violation 85-15-01B.)
The particular audit findings reviewed by the inspector that were not promptly addressed, were the lack of "panic" hardware on the Hain Steam Tunnel fire door and the disposition of the audit findings described in the violation quoted above.
No other unacceptable conditions were identified.
The inspector examined fire protection water systems, including fire pumps, fire water piping and distribution systems, post indicator valves, hydrants and the contents of hose houses. 'he inspector toured accessible vital and nonvital plant areas and examined fire detection and alarm systems, zutomatic and manual fixed suppression systems, interior hose stations, fire barrier penetration seals, and 'fire doors.
The inspector observed general plant housekeeping conditions and randomly checked tags of portable extinguishers for evidence of periodic inspections.
No deterioration of equipment was noted.
The inspection tags attached to extinguishers indicated that monthly. inspections were performe a The inspector observed, during the plant tour that energized electric cords in the Turbine Building were placed on top of the welding rod heating ovens.
The inspector raised the concern that this could cause both an electrical shock and a fire hazard, because the skin temperature
.of the ovens was hot to the touch.
The license removed the cords from the top of the ovens.
The inspector also observed that the licensee had placed large wooden crates on the floor of the Turbine Building on EL 26.0'.
Licensee Procedure AP-7.2 requires that an Engineering evaluation be performed prior to storing materials that weigh more than 1000 pounds.
This is required to assure that floor loading requirements are not exceeded.
At the time of the inspection, the licensee could not.produce this evaluation.
This item is unresolved (88-32-01).
4.0 Unresolved Items Unresolved items are matters about which more information is required to ascertain-whether they are acceptable items, violations or deviations.
One unresolved item disclosed during the inspection is discussed in Section 3.8.
5.0 Exit Interview The inspector met. with licensee management representatives ( see Section 1.0 for attendees)
at the conclusion of the inspection on November 3, 1988.
The inspector also confirmed with the licensee that the report will not contain any proprietary information.
The licensee agreed that the inspection report may be placed in the Public Oocument Room without prior licensee review for proprietary information (10 CFR 2.790).
At no time during this inspection was written material provided to the licens'ee by the inspector.