IR 05000261/1987033
| ML14191A880 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 10/29/1987 |
| From: | Conlon T, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14191A879 | List: |
| References | |
| 50-261-87-33, NUDOCS 8711130158 | |
| Download: ML14191A880 (9) | |
Text
,RREG(,
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., ATLANTA, GEORGIA 30323 Report No.: 50-261/87-33 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: October 5-9, 1987 Inspector:,:'
G. R. WiseTian Date Signed Accompanying Personnel D. Ward Approved by:
ne T. E. Conlon,;thief'
Dte Signd Plant Systems Section Division of Reactor Safety SUMMARY Scope:
This routine, unannounced inspection was conducted in the areas of fire prevention/protection and follow-up on previously identified item Results: No violations or deviations were identifie PDR ADOCK 050o0261 GPDR
REPORT DETAILS 1. Licensee Employees Contacted
- J. Benjamin, Technical Support
- W. Brown, Senior Engineer, Fire Protection
- Cabb, Quality Control Supervisor
- W. Gainey, Jr., Operations Support Supervisor
- R. Morgan, Plant General Manager
- E. Roper, Fire Protection Specialist
- D. Sayre, Senior Specialist, Regulatory Compliance
- A. Shepherd, Technician, Regulatory Compliance Other licensee employees contacted included technicians, operators, security force members, and office personne NRC Resident Inspector
- H. E. Krug
- Attended Exit Interview g Exit Interview The inspection scope and findings were summarized on October 9, 1987, with those persons indicated in paragraph 1 above..The inspectors described the areas inspected and discussed in detail the inspection findings. No dissenting comments were received from the license No new items were identified during this inspectio The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio. Licensee Action on Previous Enforcement Matters (Closed)
URI (261/86-16-01) Inadequate One-hour Fire Barrier Wrap Enclosures for CCW Pump Cables due to Unprotected Cable/Conduit Supports:
The licensee provided to the inspectors an evaluation/calculation (File R83-086-CA-818, NELD-R-1772) dated March 2, 198 This Generic Letter GL-86-1 analysis provides justification for the conduit support with no wrap installed on the ceiling or floor supports for CCW pump roo The analysis assumed the ceiling supports to have failed from a fire event and a dead load analysis performed indicated that the associated stresses on the conduit were sufficiently low such that their dead weight can be carried by the conduit itself, therefore, no damage could occur to the protected safe shutdown cablin Based on the inspector's review, this appears acceptable, therefore, this item is close. Unresolved Items Unresolved items were not identified during the inspectio. Fire Protection/Prevention Program (Module 64704)
a. Administrative Procedures The inspectors reviewed the following fire protection administrative procedures for H. B. Robinson Unit 2:
Procedure N Fire Protection Procedure OMM-02 (Rev. 9)
Fire Protection Manual FP-003 (Rev. 2)
Control of Transient Combustibles FP-004 (Rev. 1)
Duties of a Fire Watch FP-005 (Rev. 5)
Hot Work Permit 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 Fire Brigade (1) Organization The plant fire brigade for each shift is comprised of five personnel: a team leader which is a senior reactor operator; one Unit 2 auxiliary operator; one reactor operator; the fire protection technical aide; and an additional operator or a radwaste handle The inspectors reviewed the "On Shift Fire Brigade Duty Roster" for October 8, 1987, and verified that sufficient qualified personnel were on duty to meet the provisions of Technical Specification Section 6. (2) Training The inspectors reviewed the training records for classroom and drill sessions during 1987 for two fire brigade leaders and three fire-brigade members and verified the training was up to date per the requirements of plant Technical Specifications and OMM-002, Rev. 9. In addition, the inspectors verified annual training sessions have been conducted with the off-site fire department, Hartsville Fire Department, for the years 1984, 1985, and 1986. These training sessions included both classroom and drill session (3) Fire Brigade Drill During this inspection, the inspectors witnessed an unannounced fire brigade dril The drill fire scenario was a fire in the Component Cooling Water (CCW)
Pump Room apparently caused by spilled lubricating pump oil ignited by a short circuit in the train B CCW pump moto II
The minimum five fire brigade members responded to the pending fire emergency within approximately three minutes after the fire alarm initiatio The brigade assembled outside the CCW pump room at security door No. 24 in full protective fire fighting turnout clothing and self-contained breathing apparatu An initial size-up of the fire condition was made by the fire brigade leader from his position near the CCW pump room door in the Auxiliary Buildin The initial fire attack utilized a 150 lb. halon extinguisher followed by a 1-1/2 inch hose line and fire fighting foam equipmen Health physics air sample surveys were conducted prior to fire brigade entry into the fire affected are The fire was placed under control in approximately 12 minute In addition, the fire brigade initiated fire victim search and rescue, and smoke contro The fire brigade utilized adequate manual fire fighting methods and reacted to the fire drill scenario in a satisfactory manne 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-608, Revision 5, October 14, 1984 - Unit 1 Fire Water System Flow Path Valves (Monthly).
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Test records between September 23, 1986 and August 25, 198 (2) OST-622, Revision 4, December 23, 1986 - Fire Suppression Water System Motor Driven Fire Pump Test (18 Months).
(3) OST-625, Revision 7, June 26, 1987 -
Fire Door Inspection (Semi-Annual.)
(4) OST-627, Revision. 5, August 11, 1986 - Actuation and Flow Test for Emergency Diesel Generator CO2 Cardox Suppression System (18 Month Interval).
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Test records between June 20, 1985 and June 13, 198 (5) OST-629, Revision 5, December 23, 1986 - Pre-action Sprinkler System and Dry Standpipe System Functional test (18 Months).
(6) OST-632, Revision 5, June 19, 1987 - Unit 2 Fire Suppression Water System Flow Test (Three year Interval).
(7) OST-638, Revision 3, March 13, 1987 - Electrical Penetration Area Pre-action Sprinkler System (18 Months).
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Test records between October 17, 1984 and April 30, 198 (8) OST-640, Revision 10, August 16, 1987
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Self-Contained DC Emergency Lighting System (Semi-Annual).
(9) OST-646, Revision 4, September 1, 1987 - Fire Suppression Water System Engine Driven Fire Pump Test (18 Months).
(10)
OST-648, Revision 0, September 23, 1986 - CCW Room 1 Hour Rated Fire Barrier Wrap (18 Months).
The procedures and record data were satisfactor d. Fire Protection Audits The Triennial/Biennial Fire Protection Audit of Robinson Nuclear Project (QAA/0020-86-07) conducted October 27-31, 1986, was examine Two fire protection related findings and one concern were noted in the report. The findings and the concern were adequately addressed and closed by the license 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 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-441 (Locked Open) West Yard Supply
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Valve FP-558 (Locked Open)
CCW Pump Room Suppression System Isolation Valve
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Component Cooling Water Pump Room Fixed Suppression System
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North Cable Vault Fixed CO2 Suppression System
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South Cable Vault Fixed CO2 Suppression System
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Elevation 226' Auxiliary Building Hallway Fixed Suppression System
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Hose House and Hydrant Near the Intake Structure
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Hose Stations 31, 78, 82 and 90 During the plant tour, the inspectors visually inspected the fire barrier walls of the Hagan Room (Fire Zone 23),
Component Cooling Water (CCW) Pump Room (Fire Zone 5), North Cable Vault (Fire Zone 9),
and the South Cable Vault (Fire Zone 10).
This inspection also included a review of the fire barrier cable wrap enclosures for the CCW Pumps Train A&C cables (DS503, DS504, 24137, 24138, and pull box APPCC-3)
in Fire Zone The review of the cable wrap enclosures included the verification of the adequacy of the newly issued surveillance procedure OST-648. The procedure appears to be adequate to satisfy Technical Specification requirement The inspectors also verified that emergency lights in the areas of operator actions and along with operator paths required by the Dedicated Shutdown Procedures (DSPs)
were operable and aimed as required by OST-64 Two lights were identified as inoperable with outstanding work request The remaining lights inspected were operable and aimed correctl In addition, the inspectors reviewed the plant areas containing safety-related equipment for housekeeping and transient combustible All plant areas were found clean and free of any significant transient combustible Within the areas examined, no apparent violations or deviations were identifie. Inspector Followup Items (IFIs)
a. (Closed) IFI 261/85-07-11), Technical Specifications not Provided for Alternative/Dedicated System Components:
By letter, dated March 29, 1985, CP&L submitted to NRC/NRR a request for an amendment to add to the Technical Specification Requirements for the dedicated/alternate shutdown system at H. B. Robinson Unit By letter, dated January 20, 1987, the NRC responded that fire protection systems are not part of safety-related systems and do not need to be incorporated in the Technical Specification Therefore, the request for Technical Specifications for dedicated/alternate shutdown system was denie Based on the above action, this item is closed, however, the denial of Technical Specifications for dedicated/alternate shutdown systems is not consistent with those that have been submitted and approved for other sites and the standard Technical Specification b. (Closed) IFI (261/85-07-12),
NRR Response to Licensee's Comments on Alternative Shutdown Capability SER:
Following issuance of NRC/NRR Supplement Safety Evaluation Report (SSER) for Alternate Safe Shutdown Capability, dated August 8, 1984, the licensee made several changes to the alternative shutdown capabilit Also, the licensee addressed the SER open items concerning spurious operation of the high-low pressure interface valve These items were addressed by the licensee to the NRC in letters dated November 30, 1984, and June 18, 198 A SSER was issued on November 21, 1985, addressing these items, therefore, this item is close c. (Closed)
IFI (261/85-07-13),
Review of Training Program for Appendix R Procedures:
Followup inspections in this area were conducted as part of NRC Safety System Functional Inspections (SSFI)
conducted on March 9 April 15, 1987, (NRC Report No. 50-261/87-06) and May 26-29, 198 (NRC Report No. 50-261/87-17).
As a result of this inspection, several training discrepancies were identified in part as Violation Item (87-06-01) and Inspector Followup Item (IFI) (87-17-02). Based upon the results of these followup inspections, the review of the licensee's training program has been completed, therefore, this item is close d. (Closed) IFI (261/85-07-14), Review of Staffing for Implementation of Appendix R Procedures:
This item was identified during the 1985 Appendix R inspection during review of the "draft" dedicated safe shutdown procedure During this inspection, Dedicated Shutdown Procedure DSP-002 was reviewe This procedure requires concurrent actions by three operators including a turbine building operator, an electrical operator, and an auxiliary building operator. Based on this review, the minimum staff level appears to be adequate to implement the Dedicated Shutdown Procedures to achieve hot shutdown, and is consistent with that approved in the Safety Evaluation Report dated August 8, 1984, therefore, this item is close e. (Closed)
IFI (261/85-07-15),
Equipment Running Without Loss of Offsite Power During Appendix R Fire Event:
During this inspection the inspectors reviewed Dedicated Shutdown Procedure DSP-002, Hot Shutdown using the Dedicated/Alternate Shutdown System, Revision 1, dated June 7, 198 This procedure through implementation of Steps 2.3.5 and 2.3.9.1 de-energizes onsite and offsite AC power sources and powers the Dedicated Shutdown (DS)
bus from either the onsite DS diesel generator or offsite power if available. These breaker trip actions assure that power sources to plant equipment not required to accomplish dedicated hot shutdown are deenergized in a safe condition. Based on this review, this item is considered close (Closed)
IFI (261/85-07-16),
Spurious Operation of Normal Diesels During Appendix R Fire Event:
During this inspection, Dedicated Shutdown Procedure DSP-002 was reviewed. This procedure requires the tripping (open) of breakers 52/17B and 52/27B which de-energizes the power circuits for the normal plant emergency diesel generator In addition, the procedure directs that the fuel oil supply racks be tripped out which precludes any diesel start. These actions assure that spurious operations of the diesel cannot occur, therefore, this item is close (Closed) IFI (261/85-07-17),
Review of Actions to Prevent Spurious Movement of Valves Procedurally Aligned for Hot Shutdown:
Dedicated Shutdown Procedure DSP-002 was reviewed by the inspector The procedure requires that control and power be removed from selected valves by tripping of the associated breakers to assure proper alignment of valves and that these valves not spuriously move from the required condition due to a fire even Based on this review, these actions appear adequate, therefore, this item is close h. (Closed) IFI (261/85-07-18),
Review of Boration to Allow Cooldown in Appendix R Fire Event:
This item was identified from the review of procedures during the 1985 Appendix R inspectio At that time, no analytical determination of shutdown margin prior to proceeding from hot to cold shutdown was accomplished in the procedure The DS procedures require the reactor coolant system to be borated from the RWST (1950 ppm)
by making up reactor system inventory with the charging pump(s).
The licensee provided an analysis (File 13510 E, RNPD/85-1735, dated July 8, 1985) which indicates that by utilizing the RWST, there is more than 1% AK/K shutdown margin under the hot shutdown conditio During the followup SSFI inspection on May 26-29, 1987, it was noted, however, that specific acceptance criteria for shutdown parameters, and charts and tables for operator shutdown calculations were not yet incorporated into the DS procedure These items were identified as part of IFI (216/87-17-02). Based on the review of the licensee's analysis and the licensee's commitments from the followup inspection May 1987, there is adequate information available to close this original ite i. (Closed)
IFI *(261/85-07-19),
Review of All Completed Appendix R Operational Procedures:
At the time of the Appendix R inspection conducted February 4-8, 1985, the Dedicated Shutdown Procedures (DSP) that had been developed were in draft for Also, several procedures'were not developed at that time. As part of a NRC team Safety System Functional Inspection (SSFI)
conducted on March 9 - April 15, 1987, the DSPs were reviewed for adequacy to achieve the required hot standby condition Also, the operating and post-fire procedures necessary to achieve the cold shutdown conditions were reviewed. As a result of this inspection, significant deficiencies were noted which are identified as Violation (50-261/87-06-01).
Based on the follow-up review of these procedures, the original item is considered close j. (Closed)
IFI (261/85-07-20),
Exemption Approval for Emergency Lighting Requirements of Appendix R:
By letter, dated June 29, 1984, and supplemented January 16, 1985, Carolina Power and Light Company submitted a request for exemptions
from the technical requirement from Appendix R III.J. for emergency lighting various plant areas for hot shutdown and also for the containment and RHR pump pit areas for cold shutdown operation By letter dated July 30, 1987, the NRC/NRR granted the exemptions requests, therefore, this item is close (Open)
IFI (261/85-07-22),
Discrepancies from 1978 Fire Protection SER Requirements:
By letter, dated June 11, 1985, (Mr. A. B. Cutter to Mr. S. A. Varga, Serial No. NLS-85-135)
CP&L requested a supplement to their SER to provide clarification and changes to the Fire Protection Safety Evaluation Report (SER),
which was originally issued in Support of Amendment 31 to the Robinson Operating License. This information was initially reported to the NRC/NRR in a letter dated October 15, 1984, (Serial No. NLS-84-441). At the time of this inspection, no response from NRC had been received by the licensee. Pending review by NRC of these items and issuance of a supplement SER, this item remains open.