IR 05000245/1986002

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Insp Repts 50-245/86-02 & 50-336/86-02 on 860224-28.No Violation or Deviation Noted.Major Areas Inspected:Fire Protection/Prevention Program,Including Administration & Organization & Administrative Control of Combustibles
ML20154R907
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 03/17/1986
From: Anderson C, Pullani S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20154R887 List:
References
50-245-86-02, 50-245-86-2, 50-336-86-02, 50-336-86-2, NUDOCS 8603310239
Download: ML20154R907 (11)
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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-02 50-336/86-02 Docket N License N OPR-21 Priority -

Category C DPR-65 Licensee: Northeast Nuclear Energy Company P.O. Box 270 Hartford, Connecticut 06141-0270 Facility Name: Millstone I and 2 4 Inspection At: Waterford, Connecticut

Inspection Conducted
February 24-28, 1986 Inspectors: Du[Iam S.V. P 611ar " ire Protection Engineer 3//7/B6 d te I

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Approved by: ,), /

O//7 O C.J./ Anderson, Chief, Plant Systems Section date Inspection Summary:

Inspection on February 24-28, 1986 (Combined Report No. 50-245/86-02 and

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50-336/86-02)

Areas Inspected: Routine unannounced inspection of the Fire Protection / Pre-vention Program including: program administration and organization; admini-

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strative 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 tour. The inspection involved 44 inspector-hours on site and 8 in-spector-hours in office by one region based inspecto Results: Of the eight areas inspected, no violations or deviation were identi-fied.

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B603310239 860326 PDR ADOCK 05000245 G PDR

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i DETAILS

1.0 Persons Contacted

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1.1 Northeast Nuclear Energy Company (NNECO)

  • R. Bates, Assistant Engineering Supervisor-Unit 2 l P. Benyeda, Supervising and Control Operator-Unit 1 N. Bergh, Operations Assistant-Unit 1 l G. Closius, QA/QC Supervisor
  • F. Comstock, QA Specialist K. Deslandes, Engineer - Unit 2 l *J. Heg, Operations Assistant C. Libby, Supervisor - Operations QA l M. Mullin, Shift Supervisor - Unit 2 R. Palmieri, Operations Supervisor - Unit 1

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  • Romberg, Station Superintendent S. Scace, Superintendent - Unit 2
C. Shine, Shift Supervisor - Unit 1 J. Stetz, Superintendent - Unit 1 l 1.2 Northeast Utilities Service Company (NUSCO)

J. Nickerson, Fire Training Instructor L. Vara, Senior Fire Training Instructor

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1.3 Nuclear Regulatory Commission (NRC)

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  • J. Grant, Resident Inspector
  • J. Shediosky. Senior Resident Inspector
  • Denotes those present at the exit intervie ,

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2.0 Followup of Previous Inspection Findings

) (Closed) Unresolved Items (50-245/84-15-01) and (50-336/84-15-01) Storage

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of Flammable Liquids

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, These items pertain to the licensee commitment to revise Administrative

Control Procedure ACP-2.05B, Control of Combustible Materials, Flammable Liquids, Compressed Gases and Ignition Sources, Revision.8, to clarify the requirement of storing large quantities of flammable liquid in area farther

! than 50 feet from any permanent building or structure reflecting the

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licensee's actual practice. By revision 9 of the procedure, the licensee met the above commitment. The inspector reviewed the revised procedure and found it acceptable. These items are resolved.

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(Closed) Unresolved Items (50-245/84-15-02) and (50-336/84-15-02)

Additional Fire Watchmen in Areas Where Sparks and Molten Metal May Drop from Welding Operations Above These items pertain to the licensee commitment to revise ACP-2.05B, Re-vision 8, to clarify the requirement to have additional fire watchmen in areas where sparks or molten metal may drop several floors to areas con-taining significant quantities of combustible material By Revision 9 of the procedure, the licensee met the above commitment. The inspector reviewed the revised procedure and found it acceptable. These items are resolve (Closed) Violation (50-336/84-15-03) Failure to Perform Semiannual Surveillance Testing on Smoke Detectors (Unit 2 only)

This item pertains to the violation identified during the previous inspec-tion for failure to perform semiannual surveillance testing on smoke detectors between March 83 and May 84, in accordance with the requirements of Technical Specification 4.3.3.7.1. The inspector reviewed the correc-tive actions documented in the licensee response letter, dated August 30, 1984, and verified that they are completed. The inspector also reviewed the subsequent (after May 84) surveillance test records for the smoke detectors as performed in accordance with the implementing procedure SP2618C, Fire Protection Smoke Detector Test, Revision 5, and verified that the tests were done semiannually in accordance with TS 4.3.3. This item is closed.

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[Open) Unresolved Items (50-245/84-15-03) and (50-336/84-15-04) Annual Audit by Outside Firm These items pertain to the independence of Northeast Nuclear Service C (NUSCO) as an outside firm, in performing the annual audit in accordance with Technical Specification 6.5.4. By letter dated January 30, 1986, the licensee made a commitment to revise the Technical Specifications to meet the intent of Generic Letter 82-21 and the Standard Technical Spe-cification Generic Letter 82-21 gives detailed guidance on the annual, biennial, and triennial fire protection audits. Generic Letter 82-21 states that the annual audit may be performed by qualified utility per-sonnel who are not directly responsible for the site fire protection program or by an outside independent fire protection consultant where as the triennial audit must be performed by an outside independent fire protection consultant. The Technical Specifications, when revised; should address all the three types of audits to meet the intent'of Generic Letter 82-2 In the January 30, 1986 letter, the licensee also committed to do the triennial audit using an outside independent fire protection consultant, starting with the triennial audit scheduled to begin November 1986.

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These items remain open, pending completion of the revision of the Tech-nical Specifications and performance of the audits in accordance with the revised Technical Specification (Closed) Violation _(50-336/84-15-05) Switchgear Battery Rooms A and B Fire Barrier Walls with Unsealed Penetrations (Unit 2 only)

This item pertains to a violation identified during a previous inspection

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with respect to the unsealed penetrations in the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier walls of the battery rooms and the plastic pipes passing through these pene-trations. The licensee replaced the plastic pipes with steel pipes and sealed the penetrations, as committed in their response letter dated August 30, 1984. The inspector verified the licensee's corrective actions by actual inspection of the battery rooms. This item is close '

(Closed) Deviation (50-336/84-15-06) Fire Protection System Piping Not Installed Per National Fire Protection Association (NFPA) Code (Unit 2 only)

This deviation pertains to the fire protection system piping, near Column Line E15 and Hose Station 235 (Unit I and 2 Turbine Building Corridor, Elevation 14'6"), solidly embedded in a concrete block wall without a sleeve or proper clearance as specified in NFPA 13. The deviation was against the licensee commitment in FSAR Section 9.10.2 1 to design the fire protection systems in accordance with NFPA codes and standards.

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In the licensee's response letter dated August 30, 1984, the licensee j provided detailed justification for not providing the sleeve or clearance around the piping in question as specified by NFPA 13 and also justified '

how the piping system, as presently designed, would meet its intended function. In the same letter, the licensee also discussed the extend of applicability of NFPA codes to Millstone 2. Based on the above, by letter dated September 4, 1985, the NRC withdrew the deviation. However, the NRC '

letter recommended that FSAR Section 9.10.2.1 be updated to include the

specific areas of NFPA the license complies with. By FSAR Change N ,

85-MP2-09 dated June 28, 1985, the licensee had already updated the FSAR

section as recommende This item is therefore close .0 Fire Protection / Prevention Program

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The inspector reviewed several documents in the following areas of the program to verify that the licensee had developed and implemented 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 l

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3.1 Program Administration and Organization The inspector reviewed the following licensee documents:

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* Technical Specifications, Section 6, Administrative Controls
* Procedure NE0 2.14, Nuclear Plant Fire Protection Program, i

Revision 0 i

  • Procedure ACP-QA-2.05, Fire Protection Administration and Program, Revision 1 .
The scope of review was to ascertain that
Personnel were designated for implementing the program at site; and Qualifications were delineated for personnel designated to implement the progra No unacceptable conditions were identifie ,

3.2 Administrative Control of Combustibles The inspector review the following licensee documents:

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Procedure ACP 2.05B; Control of Combustible Materials, Flammable Liquids, Compressed Gases and Ignition Sources; Revision 11

Procedure ACP-QA-2.05, Fire Protection Administration and Program, Revision 18

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Procedure ACP-QA-4.01, Plant Housekeeping, Revision 12

Procedure MAP-5.08, Control of Solvents, Revision 3

, The scope of review was to verify that the licensee had i

developed administrative controls which included: Special authorization for the use of combustible, flammable

or explosive hazardous material in safety-related areas; Prohibition on the storage of combustible, flammable or explosive hazardous material in safety-related areas; The removal of all wastes, debris, rags, oil spills or other combustible materials resulting from the work acti-vity or at the end of each work shift, whichever is sooner;

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6 All wood used in safety-related areas to be treated with flame retardant; Periodic inspection for accumulation of combustibles;

. Transient combustibles to be restricted and controlled in safety-related areas; and

! Housekeeping to be properly maintained in areas containing safety-related equipment and components.

l No unacceptable conditions were identifie I

! 3.3 Administrative Control of Ignition Sources The inspector reviewed the following licensee documents:

  • Procedure ACP-2.05B, Control of Combustible Materials, Flammable Liquids, Compressed Gases and Ignition Sources, Revision 11.
* Fire Watch Certification Form, SF217, Revision 5.

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! The scope of review was to verify that the licensee had devel-oped administrative controls which included:

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' Requirements for special authorization (work permit) for activities involving welding, cutting, grinding, open flame or other ignition sources and that they are properly safe-i guarded in areas containing safety-related equipment cora-ponents; and Prohibition on smoking in safety-related areas, except where " smoking: permitted" areas had been specifically designated by plant managemen No unacceptable conditions were identified.

I 3.4 Other Administrative Controls The inspector reviewed the following licensee documents:

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= Technical Specification, Section 6, Administrative Controls  !

= PMMS Work Order System (Millstone Unit 2)

* Procedure ACP-QA-1-10, Fire Protection Quality Assurance Program, Revision 7

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= Procedure ACP-QA-2.05, Fire Protection Administration and Program, Revision 18

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  • Procedure ACP-8.02, Fire Fighting Training Program, Revision 8 Procedure ACP-QA-2.02C, Work Orders, Revision 7

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  • Procedure ACP-QA.3.10, Preparation, Review and Disposition of Plant Change Requests (PDCBs) (NE0.3.03) Revision 0

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  • New Employee Training - 200, General Safety, Revision 1

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  • Lesson Plan Section 500, Fire Safet The scope of review was to verify that the licensee had developed administrative controls which require that:
Work authorization, construction permit or similar arrangement is provided for review and approval of modification, construc-l tion and maintenance activities which could adversely affect the

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safety of the facility; F

i Fire brigade organization and qualifications of brigade members l

are delineated; Fire reporting instruction for general plant personnel are developed; Periodic audits are to be conducted on the entire protection program; and

Fire protection / prevention progran. is included in the licensee's

QA progra No unacceptable conditions were identifie .

3.5 Equipment Maintenance, Inspection and Tests The inspector reviewed the following randomly selected documents to determine whether the licensee had developed adequate procedures which established maintenance, inspection, and testing requirements for the plant fire protection equipment:

** Procedure SP 680, Fire Hose Pressure Test, Revision 3 i

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    • Procedure SP 680B, Electric Fire Pump Monthly Run, Revision 7 i.

i ** Procedure SP 680I, Fire Protection System Station Deluge Valve Functional Test, Revision 5

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Penetration Inspection, Revision 1 ,

' ** Procedure SP 680 R, Fire Damper Inspections, Revision 2 i

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! ** Procedure SP 680 T, Diesel Fire Pump Monthly Run, Revision 2  :

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Procedure SP 680 V, Control Room Flemmable Liquid / l j Materials Inspection, Revision 0  ;

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    • Procedure SP 2618 A, Monthly Fire Protection System

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Fire Pump Auto Start Test, Revision 3 i l v i 4 ** Procedure SP 2618 C, Fire Protection System Smoke  !

] Detector Test, Revision 5 l i ** Procedure SP 2618 F, Fire Pump Performance Test, Revision 4 In addition to reviewing the above documents, the inspector reviewed the l maintenance / inspection / test records of the items identified by an asterisk l

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(*) to verify compliance with Technical Specifications and established t procedure ;

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J No unacceptable conditions were identifie f

3.6 Fire Brigade Training  !

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{ The inspector reviewed the following licensee procedures:  ;

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Procedure ACP-8.02, Fire Fighting Training, Revision 8 .

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Station Form SF-842, Departmental Programs Description, e l

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Station Form SF-843, Training Records Attendance,  !

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Station Form SF-860, Fire Brigade Drill Announced /Unan-  !

nounced, Revision 2  ;

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Quarterly Brigade Training Lesson Plan l

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  • Fire Brigade Leader Exam  !

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oped administrative procedures with included:

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i l Requirements for announced and unannounced drills;

i Requirements for fire brigade training and retraining at l prescribed frequencies; i Requirements for at least one drill per year to be per-formed on a "back shift" for each brigade;

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9 , , Requirements for local fire department coordination and training; and Requirements for maintenance of training record No unacceptable conditions were identifie . Records Review The inspector reviewed training records of fire brigade members for calendar years 1985 and 1986 to ascertain that they had successfully completed the required quarterly training / meeting, semiannual drill, and yearly hand-on fire extinguishment practic No unacceptable conditions were identifie Quarterly Meeting, Training and Drill Sessions (Unit 2 only)

The inspector noted that, out of a total of 61 fire brigada

memoers, 11 during third quarter of 1985 and 14'during i fourth quarter of 1985 missed the quarterly meeting, train-

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ing, and drill sessions. The licensee explained that this

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was because the members were offsite on operato* licensee training or Shift Technical Advisor (STA) training. Most of these people were on a reserved status on the fire brigade roste The minimum 5 member fire brigade per shift were always available as required by the Technical Specifications. The licensee by internal memorandum dated January 10, 1986, took appropriate corrective actions i.e.,

by arranginc make up training, (having the members read and i sign the lesson plans for the missed sessions). Further-more, most of these members have already completed the 1986 i first quarter training sessions and remaining members are

,being scheduled for the training during the 1986 first quarter. With the enhanced computer tracking system now in place, the licensee expects to streamline the fire brigade training activitie Based on the above corrective ac-

_ tions, the inspector finds this' acceptabl I 3.7 Periodic Inspections and Quality Assurance Audits *

l 3. Annual Audit i

! The inspector reviewed the reports of the following annual audits:

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  • Audit No. A20406, Performed on November 14 -

December 7, 1983 ,

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  • Audit No. A60428, Performed on November 7, 1984 -

, December 20, 1984

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The scope of review was to ascertain that the audits were conducted in accordance with Technical Specification 6.5.4.7.e and audit find-ings were being resolved in a timely and satisfactory manner.

i No unacceptable conditions were identified.

i 3. Biennial Audit The inspector reviewed the reports of the following biennial audits:

  • Audit No. A20402, performed on November 15-19, 1982
  • Audit No. A60409, performed on November 14-20, 1983 The scope of review was to ascertain that the audit was con-ducted in accordance with TS 6.5.4.7.d and audit findings were being resolved in a timely and satisfactory manne No unacceptable conditions were identified.

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3. Triennial Audit The licensee's present Technical Specifications do not require Triennial Audits. However, by letter dated January 30, 1986, the licensee made a commitment to revise the present Technical Specifications to include the requirement for triennial audits and to perform first such audit in November 1986 (see Section 2.0 of this report, the discussion on Unresolved Items 50-245/85-15-03 and 50-336/85-15-04, for details).

3.8 Facility Tour l The inspector examined fire protection water systems, including fire pumps, fire water piping and distribution systems, post indicato t valves, hydrants and contents of hose house The inspector toured

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accessible vital and nonvital plant areas and examined fire detection and alarm systems, automatic 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 performed.

i No unacceptable conditions were identified.

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4.0 Unresolved Items Unresolved items are matters about which more information is required to ascertain whether they are acceptable items, violations or deviation .0 Exit Interview The inspector met with licensee management representatives (see Section 1.0 for attendees) at the conclusion of the inspection on February 28, 1986. The inspector summarized the scope and findings of the inspection at that tim The inspector and the licensee discussed the contents of this inspection report to ascertain that it did not contain any proprietary informatio The licensee agreed that the inspection report may be placed in the Public Document Room without prior licensee review for proprietary information (10 CFR 2.790).

At no time during this inspection was written material provided to the licensee by the team.

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