IR 05000244/1979016

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IE Insp Rept 50-244/79-16 on 791023-26.Noncompliance Noted: Failure to Follow Ignition Source Procedure & Failure to Complete Required Mods
ML17249A563
Person / Time
Site: Ginna Constellation icon.png
Issue date: 11/21/1979
From: Ebneter S, Koltay P, Markowski R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17249A559 List:
References
50-244-79-16, NUDOCS 8002140371
Download: ML17249A563 (30)


Text

U.S.

NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No 50-244/79-16 Docket No.

50 244 License No.

DPR-18 Priority Category Licensee:

Rochester Gas and Electric Corporation 89 East AVenue Rochester, New York 14649 Facility Name.

R.

E.

Ginna Nuclear Power Plant, Unit

Inspection at:

Ontario, New York Inspection conducted:

October 23-26, 1979 Inspectors:

.

S.

Ko tay, eactor, ec or

-// /1 7l da e si ned u/g~gpp ar ows s, eac or nspec or date signed Approved by:

gg'.

D.

ne'ter, ie

,

ngineering Support Section No. 2, RC&ES Branch date signed

//-~i-rg date signed Ins ection Summar Iris ection on October 23-26 1979 Re ort No.

50-244 79-16 Areas Ins ected:

Routine, unannounced inspection of the Fire Prevention/Protection rogram including: assignment of functional responsibilities; implementation of administrative controls; fire brigade training; observation of the required completion of plant modifications; observation of ignition source control; observation of fire protection systems and components; and, review of surveillance test records associated with the fire control system.

The inspection also included the review of actions taken in response to IE Bulletins and Circulars, administrative controls associated with containment purging; and, observation of a site radiation emergency drill.

The inspection involved 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> on site by two NRC regional based inspectors. ~

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Results:

Of the 10 areas inspected no items of noncompliance were identified in 8 areas; two items of noncompliance were identified in two areas (Infraction-failure to follow ignition source control procedure, Paragraph 2.d; Infraction-failure to complete required modifications, Paragraph 3.d.(2)).

8 008148 Region I Form 12 (Rev. April 77)

DETAILS 1.

Persons Contacted C. Edgar, I&C Foreman

  • B. Hunn, Mechanical Engineer
  • M. P. Lilley, Mechanical Engineer R. Morill, Training Coordinator
  • J. T. St. Martin, Project Liaison Engineer
  • T. R. Schuler, gC Engineer
  • E. R. Smith, Fire Protection Engineer
  • B. A. Snow, Plant Superintendent

"J.

E. Straight, Fire Protection and Safety Coordinator

  • R.

W. Vanderweel, Project Manager

  • denotes those personnel who were present at the exit interview.

2.

Fire Protection/Prevention Pro ram Review a.

Functional Res onsibi lities The inspector reviewed the following licensee procedures, SC-3.3.1,

"Immediate Fire Notification," Revision 3, dated 12/4/78; and, SC-3.3.2,

"Offsite Notification of Fire," Revision 3, dated 8/21/79; and verified that the licensee has developed lines of communication for onsite and offsite organizations and assigned responsibilities for fire protection/prevention activities.

No items of noncompliance were identified.

b.

Administrative Controls The inspector reviewed the following licensee documents and procedures; Technical Specifications Section 6.5.2.8; A102. 1, "Administiative/Security Indoctrination," dated 5/1/79; A102.11,

"Emergency Plan Training Program

" dated 7/18/78; SC-3, "Fire Emergency Plan," Revision 10, dated 6/21/78;

and verified that the licensee has developed administrative controls which include:

(1)

Periodic audits; (2)

Indoctrination of contractor personnel and offsite licensee personnel to facility procedures which implement the fire protection/prevention program; (3)

Actions to be taken by individuals discovering a fire and subsequent actions by control room personnel; and, (4)

gualification of fire brigade members.

The inspector reviewed Audit No. 78-41:GS, dated ll/27-28/78, "Audit of Ginna Station Fire Protection."

The audit was conducted in accordance with requirements of Technical Specifications 6.5.2.8.G.

No items of noncompliance were identified.

Control of Combustibles The inspector reviewed the following licensee procedures:

A-54.5, "Bulk Storage of Combustible Materials and Their Use,"

Revision 2, dated 9/25/78; A-54.4, "Duty Engineers Responsibilities,"

Revision 10, dated 7/5/79; ahd verified that the licenseel<has.developed administrative controls which require:

(1)

Special authorization for use of combustibles, flammable or explosive materials in safety related areas; (2)

A prohibition of storage of combustibles, flammable materials or explosives in safety related areas; (3)

The removal of all waste, debris, rags, oil and other combustible materials resulting from work activity upon completion of that activity or at the end of each work shift, whichever is sooner; (4)

Requirement that all wood used in safety related areas be treated with flame retardent material; and, (5)

Periodic facility inspection for accumulation of combustibles.

No items of noncompliance were identifie d.

Control of I nition Sources The inspector reviewed the following administrative procedures:

A-54.3,

"Open Flame Welding and Gri'nding Permit," Revision 12, dated 6/27/79; A-54.5, "Bulk Storage of Combustible Materials and Their Use,"

Revision 2, dated 9/25/78; and verified that the licensee has developed administrative procedures which include:

(1)

Requirements forspecial authorization for activities involving open flame, welding or other ignition sources and evaluation.

of nearby flammable materials, cable trays or critical process equipment; and, (2)

Prohibition of smoking in safety related areas except in specific areas designated by management.

e.

During a tour of the facility, the inspector observed a welding operation at elevation 253'3" of the Intermediate Building in the auxiliary feed water pump area.

The inspector noted combustible materials in the form of polystyrene foam used as a seismic gap sealant within five feet of the welding activity and an uncovered drum containing approximately ten gallons of lubricating oil located within twenty (20) feet of the welding operation.

Procedure A-54.3, Open Flame, Welding and Grinding Permit, Revision 12, dated 6/27/79, paragraph 3.4, states in part:

"The work area will be inspected by a foreman or supervisor...he will insure that...all movable combustible material...within a thirty-five (35) foot radius of the...welding...work has been removed.

All immovable combUstible material...within a thirty-five (35) foot radius has been.'..protected by flame proof covers."

The inspector notified the licensee that the welding dperation was conducted contrary to station procedure A-54.3.

This is an infraction level item of noncompliance (79-16-01).

Fire Fi htin Procedures The inspector reviewed the following licensee procedures:

SC-3, "Fire Emergency Plan," Revision 10, dated 6/21/78; SC-3.3.1,

"Immediate Fire Notification," Revision 3, dated 12/4/78; and verified that the licensee has developed administrative procedures which include:

(1)

Actions to be taken by the fire brigade; (2)

Coordination of fire fighting activities with offsite fire department; (3)

Actions taken by plant superintendent; and, (4)

Instructions for plant operators and general plant personnel during a fire.

No items of noncompliance were identified.

f.

Fire Bri ade Trainin The inspector reviewed the following licensee procedures; SC-3, "Fire Emergency Plan," Revision 10, dated 6/21/78; A-102.11,

"Emergency Plan Training Program,"

dated 7/18/79; and verified that the licensee has developed administrative procedures which include:

(1)

Requirements for announced and unannounced drills; (2)

A requirement that at least one drill per year be performed on a "back shift" for each fire brigade; and, (3)

A requirement that local offsite fire department participate in at least one annual drill.

No items of noncompliance were identified.

3.

Review of Fire Pro ram Im lementation a.

Fire Ins ections

.

The inspector reviewed the Loss Prevention Report dated May 18; 1979, prepared by the licensee's insurer, American Nuclear Insurers (ANI).

The licensee stated that the recormendations contained in the report are being evaluated and corrective action will be taken as necessary.

The recommendations did not involve safety related areas.

No items of noncompli ance were identi fied.

Emer enc Drills The licensee has conducted nine emergency fire drills during 1979.

The inspector reviewed the Fire Emergency Drill Critique Sheets SC-3.17.1, for each drill.

A fire drill involving the offsite Ontario Volunteer Fire Department is scheduled for October 28, 1979.

No items of noncompliance were identified.

Facilit Tours The inspectors examined the yard fire protection equipment including:

indicator valves; protection of valves and hydrants against vehicular a

m damage; and, the contents of hose houses.

The inspectors also examined fire alarm and fire suppression systems and fire barrier penetration seals in the control room complex, relay room, computer room, cable tunnel, battery rooms, diesel generator rooms, turbine building and the screen house.

The inspectors randomly checked tags of portable hand extinguishers for evidence of periodic inspections.

No deterioration of equipment was noted and the inspection tags attached to extinguishers indicated that monthly inspections were performed.

The inspectors verified that an adequate number of charged air bottles for use in emergency breathing apparatus were located in various strategic areas of the facility.

Utilizing system operating procedure SC-3.15.8, Fire System Locked Yalve Cycling, the inspectors verified that fire water suppression system valves required to be locked were locked and in the positions required.

No items of noncompliance were identified.

Modifications Re uired b

Amendment 24 to DPR-18 By observation and examination of records, the inspectors verified, on a sampling basis, that required modifications were completed as identified and scheduled in Tables 3.1 and 3.2 of the Fire Protection Safety Evaluation Report (SER), issued as Amendment 24, to the Provisional Operating License and paragraphs 3.1.1 through 3.1.49 and paragraphs 3.2.1 through 3. (1)

The following required modifications were verified to have been completed:

SER 3.1.4,"Curbs"- completed's per EWR 1834.

SER 3.1.6,"Computer Room Ceiling'

completed as per installation procedure SM-79-1837 F 1, Revision 0.

SER 3.1.13,'elocation of Gas Meter - completed as per EMR 1834.

SER 3. 1. 17, Turbine Oil Reservoir - completed as per EWR 2423.

SER 3. 1,23,'mergency Lights - observed installation in strategic areas.

SER 3.1.26, Exterior Hose Houses.

Four hose houses, containing the equipment specified in paragraph 3.1.26 of the SER, have been installe SER 3.1.27,"Special Purpose Fire Fighting Equipment - equip-ment listed in paragraph 3.1.27 of the SER was observed to have been installed.

SER 3.1.28,"Fire Fighting Equipment Storage - suitable fire fighting storage areas have been provided in the Turbine Building and the warehouse.

Ser 3.1.32,'ontrol of Combustibles"-

implemented through administrative procedures:

A-54.5,"Bulk Storage of Combustible Materials and Their Use," Revision 0, dated 6/25/78; A-54.4,"Duty, Engineer Responsibilities," Revision 10, dated 7/5/79; A-202,"

Ginna Staff Responsibilities for Fire Protection," Revision 0, dated 6/1/79.

SER 3.1.33, Control of Ignition Sources - implemented through administrative procedure A-54.3,"Open Flame, Melding and Grinding Permit,"Revision 12, dated 6/27/79.

SER 3. 1.38,"Fire Barriers"- implemented through the reduction of combustible materials in the computer room to a level where the hazards can be contained by the proposed fire barrier SER 3.1. 44, 'Exterior Hydrant Freeze Protection" - implemented through administrative procedure SC-3.15.9,"Exterior Hydrant Freeze Protection,~dated 10/19/79.

SER 3.2.7," Fire Pumps Performance'-

completed.

Fire pumps performance test results of'May 16, 1979 indicate that both pumps meet the performance requirements established in the Plant Technical Specifications.

However, the licensee also identified that both pumps performed below the manufacturer's rated capacities.

The licensee stated that the pump manu-facturer recommends the replacement/repair of the bowl assemblies of both fire pumps.

An NRC inspector will review records of fire pump tests sub-sequent to the planned maintenance activity (79-16-02).

(2)

The following modifications have not been completed as scheduled:

SER 3.1.20 - "Service Water Piping in Diesel Room," required to be completed by September 1979; and, SER 3.1.22 - "Exterior Hydrants," required to be completed by June 1979.

The inspector reviewed Amendment No.

24 to License No.

DPR-18 Section 2.(5) which states in part:. "...the licensee...is required to complete the modifications identified in Paragraphs 3.1.1 through 3. 1.49 of the NRC's Fire Protection Safety Evaluation (SE) dated February 14, 1979....These modifications will. be completed in accordance with Table 3. 1 of'he SE...."

Section 2.(5) of Amend-ment No.

24 also states in part: "...in the event these dates...

cannot be met, the licensee shall submit...a revised schedule...."

By direct observation, the inspector verified that, contrary to the aboye, the service water piping of the "8" diesel located in the

"A" diesel room has not been protected against the fire hazards in the room, item 3.1.20 "Service Water Piping in Diesel Room;"

and, the ground area surrounding hydrant No.

12, located in the southeast corner of the yard loop has not been graded to provide a

12 inch clearance between the ground and the center of the hydrant outlet port.

Present clearance is 6 inches.

Item No.

3.1.22 "Exterior Hydrants."

By review of records the inspector found that the licensee has not submitted a report explaining circumstances, together with a revised schedule for implementation.

This is an infraction 'level item of noncompliance (79-16-03).

4.

Followu on IE Circulars The inspector interviewed licensee personnel and observed facility equipment and components to verify that an adequate review was conducted by the licensee to determine the applicabi'lity of the circular's subject matter to the faci 1 ity.

The Circulars reviewed were:

IEC 79-12, Potential Diesel Generator Tuhbocharger Problem; and, IEC 79-13, Replacement of Diesel Driven Fire Pump Starting Contactors.

The licensee had determined that no corrective action was required.

The inspector observed that the diesel generators installed are Westinghouse Models HG-5 and the diesel driven fire pump utilized a Cummins Industrial Fire Pump Engine, series NH56-1F.

The inspector had no further questions regarding the circul.ars.

5. 'ollowu on IE Bulletins a.

Introduction The inspector reviewed facility records and interviewed licensee per-sonnel to verify that:

licensee management received and reviewed the bulletins in accordance with administrative procedures; information discussed in the licensee's bulletin response was accurate; corrective action was taken as discussed in the reply; and, the licensee's response was within the time period required.

No items of noncompliance were identified.

The following subparagraphs detail the bases of the inspector's findings and any fur ther actions which may be required.

b.

IEB 79-15, Dee Draft Pum Deficiencies In a letter dated September 7,

1979, to NRC:RI, the licensee identified the service water pumps and the fire service pumps as

"deep draft" and provided the requested historical dat The inspector reviewed, on a sampling basis, the Equipment Maintenance Recor d of A through D Service Water Pumps, data sheets of the monthly surveillance procedure; PT-2.7, Service Water System, covering the period November 1977 - September 1979, maintenance procedure M-11.10, Major Inspection of Service Water Pump, Revision 8 and the vendor manuals.

Based on the above review, the inspector determined that sand erosion was the major contributor to pump internals wear, that the present maintenance procedures and practices were consistent with the manu-facturer's recommendations and that no evidence of a high incidence of excessive vibration or loss of flow capacity was observed.

Paragraph 3.d.(l) discusses the review associated with the fire service water pumps.

This bulletin is closed.

IEB 79-14, Seismic Anal sis for As Built Safet Related Pi in S stems In letters dated July 31, 1979 and August 31, 1979, to NRC:RI, the licensee stated that the required inspection and evaluation program would be completed within 120 days of the original issuance of the bulletin (i.e. July 2, 1979).

During this inspection, the inspector was informed that the inspection of sections of the Chemical and Volume Control System would not be completed within 120 days as previously reported.

The sections of piping involved are the relief line between the outlet of relief valve 209 and the volume control tank, and the outlet line of the volume control tank between the volume control tank and check valve 266.

Approximately 10 supports and 60 feet of piping are involved.

The aforementioned piping sections are routed through the SBCOC:VeSin storage vault.

Presently, spent resi'n is stored in the vault and cannot be removed because an appropriately certified shipping cask could not be secured.

A survey has been performed in the vault and it has been calculated that 10-40 man-rem of exposure would be exper-ienced if the inspection was performed prior to removing the spent resins.

The inspector requested that an evaluation be performed based on the

"failure" rate experienced to date.

On October 29, 1979, the inspector was informed by telephone that:

approximately 1365 supports had been inspected; of these 1365 supports, approximately 15% had irequired further review to disposition nonconformances;

of these 1365 support, approximately 3.7X had been repaired t'o disposition identified nonconformances; analysis conducted under the purview of the Systematic Evaluation Program indicates that a failure of the piping sections involved would not prevent a safe shutdown of the plant.

By letter dated October 30, 1979, the licensee submitted the required 120 day report.

Pending further review of this report by the NRC, this item is unresolved (79-BU-14).

6.

Administrative Controls on Defeat of Safet Actuation Si nals Durin Containment Pur sn a.

References Letter, D.

Ziemann to L. White, Jr.,

Containment Pur in Durin Normal Plant 0 eration, November 29, 1978; Letters, L. White, Jr. to D.

Zi'emann, Containment Pur in Durin Normal Plant'0 eration, January 2, and July 2, 1979; Letters, L. White, Jr. to D. Ziemann, Review of Safet Actuation Circuits with Overrides, February 16 and March 30, 1979; S-23.2.2, Containment Purge Procedure, Revision 13; RD-2, Containment Purge Releases, Revision 5; and, Electrical Drawing llOE059, Safeguard System, Sheet 5, Revision 8.

b.

Revtew By letter dated November 29, 1978, the NRC:NRR requested that the following information be provided:

a justification for limited containment purging during operation; a commitment to limit purging to 90 hour0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br />s/year pending completion of NRC review of the justification; and, the results of the review of the design of all safety actoafionnsignal circuits which incorporate a,manual override feature.

During this inspection, the inspector reviewed the procedures and drawing referenced aboye and held discussions with licensee personnel and deter-mined the following:

the use of the reset feature would prevent automatic closure of the containment purge valves on receipt of a safety acutation signal or high containment activity; the use of the reset feature would prevent group closure of the valves utilizing the manual pushbuttons on the control panel; however, individual control switches are provided for each valve; administrative controls have been incorporated into the plant procedures referenced above to limit purging of the containment to 90 hour0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br />s/year while the reactor is critical or "operating" as defined in Technical Specification Section 1.2; the reset feature is not used for normal containment purging as performed by the procedures referenced above; and, during normal purging, subsequent to containment atmospheric sampling, the high radiation setpoints are lowered prior to the purge valve being opened and the automatic closure safety feature and manual closure feature is not defeated.

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Pending further review and inspection by the NRC, this item is unresolved (79-SP-03).

Observation of Emer enc Drill The inspectors observed the following activities associated with a radiation emergency drill conducted on October 26, 1979:

Control room actions concerning detection and response to the simulated emergency conditions; Notification of plant personnel and offsite agencies; Dose assessment; Communications; and, Coordination and control of response activities.

The inspector determined that:

The licensee's response was generally in accordance with existing procedures; The response was coordinated and orderly;

The licensee used qualified persons to evaluate the organizational response; A critique was held shortly following the drill; and, The drill results and observer comments were documented for evaluation and the initiation of appropriate corrective actions.

The following summarizes specific items independently observed by the inspector and the licensee's drill observer in the control room which require further evaluation and improvement:

The role of the shift foreman during an emergency; The time necessary, during the drill, to assess and transmit plant status information to the Emergency Center; and, The use of operational emergency procedures during the drill.

The resolution of items identified as requiring improvement will be evaluated during subsequent NRC inspections.

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No items of noncompliance were identified.

8.

Review of Surveillance Test Records Associated with Technical S ecification

~RR. l The inspectors selected and reviewed the following records to verify that the associated required Fire Protection Program surveillances had been performed and that the acceptance criteria had been met.

PT-13, Fire Pump Operation and System Alignment, September 28, 1979; PT-13.3, Fire Pump Electrical Equipment Surveillance, September 24, 1979; PT-13. 1.10, Smoke Detector Test, July 10, 1979; PT-13. 1. 12, Containment Post Accident (Recirc) and/or Auxiliary Filter RTD Testing, September 28, 1979; PT-13.1.13, Star Corporation Heat Detector System Test, July 2, 1979; PT-13. 1. 14, Fire Barrier Penetration Seals, December 19, 1978; PT-13.4.4, 1A Diesel Generator Flood Yalve System Testing, Fire System

>4, June 4, 1979;

PT-13.4.5, 18 Diesel Generator Flood Valve. System Testing, Fire System 85, June 6, 1979; PT-13.4.6, Auxiliary Pump Lube Oil Reservoir Flood Valve System Testing, Fire System 86, June 1, 1979; and, PT-13.4.11, Cable Tunnel, June 26, 1979.

During this reivew, the inspector requested the procedure and results associated with the chemical analysis of the diesel driven fire pump';s fuel supply required by Technical Specification 4.15.2.e which became effective June 1, 1979.

The inspector reviewed test reports dated July 17 and October 25, 1979 which provided documentary evidence that fuel oil samples were collected and analyzed.

The sample collection was scheduled by ES-1:ll, Schedule, fnvironmental Samples and Parameters Analysis, Revision 0.

However, this schedule had not been formally revised.

The change was made by a pencil change to fS-1:11.

The licensee stated that the schedule would be formally revised.

Pending completion and review by RI, of:the above action, this item is unresolved (79-16-04)

9.

Review of Valve Ali nment Procedures and S stem Flow Dia rams Associated with the Fire Su ression Mater S stem The inspector performed a comparison of valve alignment procedures and system flow diagram to verify the adequacy of the procedures to specify the required position of fire suppression water system valves.

The following flow diagram and procedures were utilized:

T-32, Fire Service Water System, Revision 4; SC-3.15.8, Fire System Locked Valve Cycling, Revision 2; and, Drawing No. 33013-526, Fire Service Water Flow Diagram, Revision 3.

During this review, the inspector noted that the required position of manual valve 5131 which is the fuel supply valve to the diesel driven fire pump was not specified in the above referenced procedures.

The inspector inquired whether another procedure specified the required position.

'No other pro-cedure was provided prior to the end of the inspectio The licensee verified that the valve was opened as is required.

The licensee stated that the appropriate procedure would be revised to specify the required position of the valve.

Pending completion and review of the above action and review by RI this item is unr'esolved (79-16-05).

10.

Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable, items of noncompliance or deviations.

Unresolved items are discussed in paragraphs 5.c, 8 and 9.

11.

Exit Intervi ew The inspectors met with the licensee representatives (denoted in paragraph 1)

at the conclusion of the inspection on October 25, 1979.

Subsequent to the inspection, on October 29, 1979, a telephone call was conducted between Mr.

R. Markowski of this office and Mr.

M. Lilley.

The scope and findings of this inspection as documented in this report were presented during this.

meeting and subsequent telephone cal