IR 05000261/1986016
| ML14175B407 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 07/09/1986 |
| From: | Conlon T, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14175B406 | List: |
| References | |
| 50-261-86-16, NUDOCS 8608110120 | |
| Download: ML14175B407 (10) | |
Text
REG, 1" UNITED STATES o
NUCLEAR REGULATORY COMMISSION
REGION II
0101 MARIETTA STREET, ZATLANTA, GEORGIA 30323 Report No.:
50-261/86-16 Licensee:
Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 Docket No.:
50-261 License No.: DPR-23 Facility Name: H. B. Robinson Inspection Conducted: June 9-13, 1986 Inspector:
gYJ' A.~.1A.~7
@
G. R. Wiseman Date Signed Approved by:
_,_ __________
7/
T. E. Conlon, Section hief
',&a&Signed Engineering Branch Division of Reactor Safety SUMMARY Scope:
This routine, unannounced inspection was conducted in the areas of fire prevention/protection and followup on previously identified item Results:
No violations or deviations were identifie PDR ADOCK 05000261
REPORT DETAILS 1. Persons Contacted Licensee Employees
- P. Beane, Quality Control Supervisor
- J. Benjamin, Operations Support Supervisor
- W. Brown, Senior Specialist, Fire Protection
- J. Curley, Director, Regulatory Compliance
- E. Harris, Director, Onsite Nuclear Safety
- F. Lowery, Manager, Operations
- E. Roper, Specialist, Fire Protection
- D. Sayre, Senior Specialist, Regulatory Compliance Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security force members, and office personne Other Organizations R. Sacramo, Project Manager, Structural, NUS M. Giarratano, Project Manager, NUS NRC Resident Inspector
- R. M. Latta
- Attended exit interview 2. Exit Interview The inspection scope and findings were summarized on June 13, 1986, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings listed below. No dissenting comments were received from the license Unresolved Item (261/86-16-01), Inadequate One-hour Fire Barrier Wrap Enclosures for CCW Pump Cables Due to Unprotected Cable Conduit Supports - paragraph The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio O 3. Licensee Action on Previous Enforcement Matters Unresolved Item (84-51-08), Inadequate Fire Damper Assemblies Installed on Three-Hour Fire Barriers - The licensee has developed for H. B. Robinson Unit 2 a document entitled, Evaluation of Fire Barrier Adequacy, (NUS
Corporation document No. 6611-P-300) which identifies and justifies the adequacy of Fire Area/Fire Zone boundaries based on evaluations of barrier components to accomplish separation of safe shutdown functions where the existing components may deviate from approved configuration This evaluation is justified by the guidance presented in Generic Letter 86-1 Based on this evaluation, the licensee implemented Modification Packages 850 A and B which installed new dampers and/or upgraded fire dampers in Appendix R barriers to conform with Underwriters Laboratory (UL)
Standard 555. Based on the inspector's review of the evaluation and the Modification Packages, this item is close. Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia tion One new unresolved item identified during this inspection is discussed in paragraph. Fire Protection/Prevention Program (Module 64704)
a. Administrative Procedures The inspector reviewed the following fire protection administrative procedures for H. B. Robinson Unit 2:
Procedure N Fire Protection Procedure OMM-002 (Rev. 4)
Fire Protection Manual FPP-001 (Rev. 8)
Fire Emergency FP-003 (Rev. 2)
Control of Transient Combustibles FP-004 (Rev. 1)
Duties of a Fire Watch FP-006 (Rev. 1)
Handling of Flammable Liquids and Gases FPP-010 (Rev. 6)
Housekeeping Controls Based on this review, it appears that the above procedures meet the NRC guidelines of 10 CFR 50, Appendix R, Fire Protection for Nuclear Power Facilities,Section II b. Fire Brigade The plant fire brigade for each shift is comprised of five personnel:
a team leader who is a senior reactor operator, two Unit 2 auxiliary operators, a fire protection technical aide, and a Unit 1 operato The inspector reviewed the 1985 fire brigade drill records to verify that fire drills are being conducted in accordance with the Technical Specifications requirements and the requirements of the licensee's procedure OMM-002, Rev. 4. The following is a summary of the fire brigade activities:
Dates Conducted Drill Exercise Drill Type 1/15/85, 1/29/85, South Carolina Fire Academy Announced 2/19/85, 2/26/85, 3/5/85 3/27/85 Unit 2 Train "B" Diesel Unannounced Generator Room Backshift 5/23/85, 5/31/85, Unit 2 Train "B" CCW Announced 6/6/85, 6/13/85, Pump, CCW Pump Room 6/20/85, 6/27/85 6/26/85 Boron Analyzer Room Unannounced 8/14/85, 8/21/85, Unit 1 Boiler (Fourth Level)
Announced 8/28/85, 9/4/85, 9/11/85, 9/18/85 9/25/85 Unit 2 South Cable Vault Unannounced Backshift 11/6/85, 11/13/85, South Carolina Fire Academy Announced 11/20/85, 11/27/85, 12/4/85, 12/11/85 12/20/85 Unit 2 Train "B" CCW Pump Room Unannounced In reviewing the fire brigade drill records, the inspector confirmed that an adequate number of announced and unannounced fire brigade drills was being conducted for each fire brigade shift per calendar quarter as required by plant Technical Specifications and procedure OMM-00 c. Surveillance of Fire Protection and Safe Shutdown Systems The inspector reviewed the following surveillance inspection and test records for the dates indicated:
(1) OST-611, Revision 3, October 23, 1984 - Unit 2 Fire Detection System; Zones 1 thru 7 (Semi-annual)
-
July 24, 1985, July 26, 1985 and January 24, 1986 (2) OST-616, Revision 3, April 25, 1985 - Unit 2 Fire Detection System Zones 23, 27 and 28 (Semi-annual)
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June 14, 1985 and December 5, 1985 (3) OST-624, Revision 6, April 18, 1986, Fire Dampers Inspection, (Refueling)
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Fire Zone 4, April 25, 1986
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Modification 850-A Dampers, May 14, 1986
(4)
OST-625, Revision 6, February 18, 1986, Fire Doors Inspection (Semi-annual)
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December 23, 1985 (5) OST-910, Revision 6, April 24, 1986, Dedicated Shutdown Diesel Generator (Weekly)
The record data were satisfactor d. Fire Protect Audits The report audit dated December 3, 1985, of a CP&L Corporate QA Department annual inspection conducted on November 18-21, 1985 (Report No. QAA/0020-85-07),
was examine Two fire protection related deficiencies were identified in the report, Nos. QAA-20-38FP and QAA-20-45FP, and corrective action was being taken by the Robinson Fire Protection staf The next three-year independent fire protection audit by a consulting fire protection firm is to be scheduled by 198 e. Plant Tour and Inspection of Fire Protection Equipment A plant tour was made by the inspector. The following fire suppression systems and components were inspected and found to be in service:
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Electrical Motor Driven Fire Pump
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Diesel Engine Driven Fire Pump
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Valve FP-2 (Locked Open) Motor Driven Fire Pump Discharge Valve
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Valve FP-3 (Locked Open) Engine Driven Fire Pump Discharge Valve
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Valve FP-6 (Locked Open) East Yard Fire Main Loop
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Valve FP-7 (Locked Open) South Yard Fire Main Loop
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Valve FP-86 (Locked Open) Outside Isolation Valve for Containment Fire Water Supply
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Valve FP-93 (Locked Open) Main Auxiliary Building Supply from East Loop
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Valve FP-440 (Locked Open) West Yard Fire Main Loop During the plant tour, the inspector visually inspected the fire barrier walls of the Hagan Room (Fire Zone 23), Train "B" Diesel Generator Room (Fire Zone 1), Train "A" Diesel Generator Room (Fire Zone 2),
Safety Injection (SI)
Pump Room (Fire Zone 3),
Component Cooling Water (CCW)
Pump Room (Fire Zone 5),
North Cable Vault (Fire Zone 9),
South Cable Vault (Fire Zone 10),
and the Dedicated Diesel Generator Enclosure. This inspection also included a review of the fire barrier cable wrap enclosures for the CCW Pumps A&C cables (DS503, DS504, 24137, 24138, and pull box APPCC-3) in Fire Zone The above cable wrap fire barrier enclosures appeared continuous from the pump junction boxes to the fire barrier wall except that the cable/conduit supports were not wrapped to the same fire resistance barrier rating as the conduits. Generic Letter 86-10 dated April 24, 1986, Appendix R, Questions and Answers, Sections 3.2.2, 3.3.3 and
3.3.4 address this issue for seismic supports and structured steel where the failure of any structural member due to a fire could result in significant degradation of the fire barrie This condition is identified as Unresolved Item (261/86-16-01), Inadequate One-hour Fire Barrier Wrap Enclosures for CCW Pump Cables Due to Unprotected Cable/Conduit Support The resolution of this item will be based on the adequacy of the licensee's proposed actions in response to the guidance provided in Generic Letter 86-10, with regard to the justifi cation of the conduit fire barrier enclosure support design In addition, surveillance and maintenance procedures for the conduit fire barrier wrap enclosures have not been develope The licensee indicated that the development of a new Operations Surveillance Test (OST) for these Fire Barrier Wrap Enclosures will be tracked by their Facility Automated Commitment Tracking System (FACTS) No. 86R0151, (18 month interval) and that the OST is due for issuance by January 1, 1987. This action will be reviewed during a future NRC inspectio Within the areas examined, no apparent violations or deviations were identifie. Inspector Followup Items (IFI)
a. (Closed)
Inspector Followup Item (261/84-51-01),
Inadequate Fire Extinguishing Equipment Selection Guidance Provided for Personnel Handling Flammable Liquids and Gase The licensee has revised paragraphs 5.17 and 5.2.3 of procedure FP-006 and procedure FP-003 to limit the quantity of flammable liquids in safety-related plant areas to one gallon in a safety containe Calculations for fire extinguishers coverage for transient combustibles has been deleted from the procedure These procedures appear to provide adequate limitations and controls for personnel handling flammable materials in the plan b. (Closed)
Inspector Followup Item (261/84-51-02),
Additional Fire Brigade Training Required in Salvage and Water Runoff Control Opera tion The inspector's review of the lesson plans for the third quarter fire brigade training indicated that training in salvage and runoff techniques was completed during the period August 14, 1985 through September 18, 1985, and that actual hands-on exercises were conducted on this training in the fourth quarter 198 c. (Closed) Inspector Followup Item (261/84-51-03), Inadequate Upper Plant Management Review and Approval of Initial Fire Brigade Training Program
- k Lesson Plan Procedure OMM-002 outlines the fire brigade initial training progra The program includes 15 modules of training and is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> in lengt Each module is. reviewed and approved by the Manager of Operations as denoted by the appropriate signature in the issuance proces The inspector verified that all modules had been reviewed and signed by the Manager of Operation d. (Closed) Inspector Followup Item (261/84-51-04),
Fire Brigade/Offsite Fire Department Drill Not Conducted Within the Past 12 Month The inspector reviewed the Fire Drill Reports for the unannounced drills with the Offsite Fire Departments (Hartsville Fire Department)
which indicated that the 1984 and 1985 yearly drills were conducted on December 18, 1984 and October 22, 1985, respectivel e. (Closed) Inspector Followup Item (261/84-51-05), Insufficient Number of Fire Brigade Drills Conducted in Safety-Related Area The inspector reviewed the 1985 Fire Brigade Drill Records as indicated in paragraph 5.b. of this repor These records indicated that fire drills during this period were conducted in the following safety related areas of Robinson Unit 2:
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Unit 2 Train "B" Diesel Generator Room
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Unit 2 Train "B" CCW Pump Room
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Unit 2 South Cable Vault This review confirmed that an adequate number of the fire brigade drills were being conducted in safety-related plant area f. (Closed)
Inspector Followup Item (261/84-51-06),
Inadequate Radiation Control Training Provided to Offsite Fire Department Personne The inspector reviewed the training report for the offsite fire department dated July 18, 198 The report confirmed that the Basic Radiation Control/Protection course was provided to the offsite fire department personnel on July 16, 198 Future radiation training for the offsite department will be conducted by qualified radiological instructors from the plant training staf (Closed)
Inspector Followup Item (261/84-51-07),
Inadequate Fire Door Assembly in M.G. Set Room Fire Barrier Wal The fire door and frame assembly to the M.G. Set Room (Fire Door 6) was repaired per Work Requests No FPR-258,
-264 and-33 The inspector's review of these work requests confirmed that the hinge screws on the door were replaced with the proper type from a listed hinge assembly, the door closure was repaired, and the holes through the door were welded closed. The inspector visually examined the door and verified that all required work had been completed satisfactoril h. (Closed) Inspector Followup Item (261/85-07-01), Issuance, Review, and Approval of Fire Protection Documents in Support of Plant Compliance to Appendix By memorandum dated July 30, 1985, H. P. Hines to M. F. Page, the following documents in support of the H. B. Robinson compliance to Appendix R were issued to the plant:
(1) H. B. Robinson Separations Analysis (Volumes 1-4)
(2) Project drawings as an Appendix to the Separations Analysis (3) H. B. Robinson Fire Hazards Analysis (4) Associated Circuits Analysis (5) Common Power Supply Analysis The inspector confirmed that the above documents were available for use from the plant Quality Assurance Records File No. 12040 (Closed)
Inspector Followup Item (261/85-07-05),
Verification of Air Flow for Fire Damper Drop Test within Procedure OST-62 The inspector reviewed OST-624, Revision 2, dated April 18, 1986, which has been revised to include steps 7.1.1.9 and 7.1.1.10 which perform a fire damper drop test with air flow through the fire dampe This testing is considered adequat (Closed) Inspector Followup Item (261/85-07-06), License Review of Pipe Routing and Hanger Support Qualification of Hydrogen Piping to the Volume Control Tan The inspector reviewed the licensee's seismic piping support analysis performed by NUS Corporation and had a telephone conference on June 11, 1986, with representatives of NUS Corporation's structural departmen This review indicated that the 1" hydrogen pipe to the volume control tank is supported by Type A conduit hangers as denoted on drawing 5137-M-250 The analysis verifies that this type of hanger when placed with a maximum spacing of 5 feet will support the piping such that its seismic response remains at or below 33 hertz (hz) and a pipe stress of 4750 ps This is within the rigid piping support range for the Robinson facilit Based on this review, it appears that the existing hydrogen piping located within the safety-relating plant areas has been designed to withstand a seismic event SSE as required by BTP 9.5-k. (Closed) Inspector Followup Item (261/85-07-07), Completion of Modifica tions for Protection of Component Cooling Water Pump Roo By letter, dated October 25, 1984, the NRC granted an exemption from Section III.G.2 of Appendix R to 10 CFR 50 for the component cooling water pump room to the extent that it requires a complete area wide automatic fire suppression syste The exemption was conditioned in that certain modifications were required to be completed to enhance the protection of CCW pumps A and C. The inspector reviewed Modification Package 811 which included these changes. The review indicated that the installation of the modifications were completed on May 20, 1986, and a walkdown inspection QA/QC review was completed on May 27, 198 Operations acceptance testing was completed on May 21, 1986. Based on the inspector's walkthrough of the CCW pump room during this inspec tion, it appears that all identified modifications associated with Modification Package 811 have been complete. (Closed)
Inspector Followup Item (261/85-07-08),
Inadequate Fire Barrier Qualification Testing for Appendix R Fire Barrier Expansion Joint Seals and Blockout Spare Penetration Seal Expansion joints located in Appendix R fire barrier which were previously sealed with non-approved tar-board material have been reworke The tar-board was removed and replaced with approved RTV foam material to provide an approved three-hour rated barrier sea The blockout spare penetration seals in Appendix R fire barrier were reworked to include the placement of a 1" marinite board on the outside of the RTV foam material to conform with the three-hour tested configuration. The inspector reviewed the rework packages and visually inspected the following penetrations to verify their completeness:
Penetration Installation Final QA/QC Number Date Inspection Date CP-5102-FX-AUX2-P28-00 3/21/85 3/22/85 CP-3974-FX-AUX1-Z26-00 3/11/85 3/13/85 CP-4093-FX-AUX1-BB28-00 3/4/85 3/4/85 CP-3975-FX-AUX1-Y24-00 3/13/85 3/21/85 CP-3941-FB-AUX1-Z26-19 6/12/85 6/13/85 Based on the above review and inspections, these penetration seals appear adequate to perform their fire separation functio m. (Closed) Inspector Followup Item (261/85-07-10), Modifications Required on Ladder to Charging Pump Area to Ensure Personnel Safety When Using Ladde The ladder to the charging pump area was modified by Design Change Notice DCN 795 E-5 dated 3/4/85. This change added a guard rail to the existing entry ladder for operator and other personnel safet The inspector visually examined the guard rail arrangement and determined
9 that this will allow personnel to safely use the ladder to enter the charging pump are n. (Closed)
Inspector Followup Item (261/85-07-21),
Exemption Request Approval for Not Providing an Oil Collection System to Meet Appendix An oil collection system has not been provided for the reactor coolant pump The licensee's exemption request from this requirement of 10 CFR 50, Appendix R, Section 111.0., was granted by letter from S. A. Varga, NRC/NRR to E. E. Utley, CP&L, dated March 7, 198 The exemption was conditioned on implementing certain fire protection modifications including additional ceiling mounted detectors within each RCP pump bay, construct 6-inch dikes to retain oil within pump bays No. B&C, and revise operating procedures to allow the use of the containment spray system as a backup fire suppression syste The licensee's Modification Package No. M-866 was reviewed to verify that these modifications had indeed been complete This review indicated that the fire detection system installation and testing for fire zone 25A, 25B and 25C were completed on February 27, 1985. Installation of the dikes for the RCP bays was verified completed on March 9, 198 A walkdown inspection by the licensee to confirm completeness of these modifications was performed on March 19, 198 A final QC review of the modification was completed on May 23, 1986. The inspector reviewed the licensee's pre-fire plan procedure OOM-003, Revision 5 (3/11/86).
Section 5.25.5 of this procedure addresses the allowable use of the containment spray system as a backup to the existing fire suppression syste Based on this review, it appears that all proposed fire protection modifications associated with the exemption request have been completed and tested. In addition, the appropriate revisions to procedures have been implemented to assure that systems are under the plant operational control.