IR 05000261/1988025

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Insp Rept 50-261/88-25 on 880829-0902.No Violations Noted. Major Areas Inspected:Fire Protection/Prevention.Weakness Noted:During Exercise,One Individual Did Not Don self-contained Breathing Apparatus in Auxiliary Bldg
ML14191B008
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 09/28/1988
From: Conlon T, Wiseman G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML14191B007 List:
References
50-261-88-25, NUDOCS 8810240396
Download: ML14191B008 (13)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA ST., ATLANTA, GEORGIA 30323 Report No.:

50-261/88-25 Licensee:

Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 Docket No.:

50-261 License No.:

DPR-23 Facility Name:c-H. B. Robinson Inspection Conducted: August 29 -

September 2, 1988 Inspector1/Ci<

7 4 W/22 G. R. Wieman

/Date igned Accompanying Personnel: E. Testa Approved by: cdYf C

T. Conlon, Chief ate igned Plant Systems Section Engineering Branch Division of Reactor Safety SUMMARY Scope:

This routine, unannounced inspection was conducted in the areas of Fire Protection/Preventio Results:

The inspector identified the following strengths in the implementation of the H. B. Robinson fire protection program:

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Staffing for the fire protection group is very goo The group appears knowledgeable of fire protection issues and has adequate manpower to implement the licensee's progra The Fire Protection Shift Technical Aide position is advantageous to provide onshift assistance to plant operations to address fire protection related issue The licensee has effectively implemented a program of controlling transient combustibles within the plant which ensures unsafe fire hazards based on.the very good housekeeping in the plan e810240396 SS.-c1004 PDR ADOCK 05000261 PDC-

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The licensee management appears to be committed to successful implementation of the fire protection progra This is evident based on their 'responsiveness to correct the weaknesses identified in the drill exercise and their approval of plant procedures which effectively implement the fire protection progra The following potential weaknesses were identified during the conduct of an unannounced fire brigade drill exercise:

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During the exercise one individual did not don a Self Contained Breathing Apparatus (SCBA)

in the Auxiliary Building prior to proceeding to the fire scen The remaining areas of the fire protection program reviewed appeared adequat No violations, deviations or new open items were identified in the areas inspecte REPORT DETAILS 1. Persons Contacted Licensee Employees

  • W. Brown, Fire Protection, Unit 2 Operations
  • J. Curley, Director Regulatory Compliance
  • C. Dietz,-Manager, Robinson Nuclear Project Department
  • D. ingram, Administration and Controls
  • R. Morgan, Plant General Manager
  • H. Pollock, Corporate Quality Assurance
  • E. Roper, Fire Protection Specialist, Unit 2 Operations
  • G. Shartzer, Technical Support
  • A. Shephard, Technician, Regulatory Compliance Other licensee employees contacted during this inspection included craftsmen, engineers, operators, mechanics, security force members, technicians, and administrative personne NRC Resident Inspectors
  • R. Latta
  • Attended exit interview Fire Protection/Prevention Program (64704) Fire Prevention/Administrative Control Procedures The inspector reviewed the following Fire Prevention/Administrative Procedures for H. B. Robinson Unit 2:

Procedure N Procedure Title OMM-01, (Rev. 15, 8/30/88)

Conduct of Operations OMM-02, (Rev. 12, 6/17/88)

Fire Protection Manual FP-001, (Rev. 11, 12/16/88)

Fire Emergency FP-002, (Rev. 1, 1/30/85)

Fire Report FP-003, (Rev. 3, 9/24/87)

Control of Transient Combustible FP-004, (Rev. 2, 11/22/86)

Duties of a Fire Watch FP-005, (Rev. 5, 11/22/86)

Hot Work Permit FP-007, (Rev. 3, 5/16/88)

Fire Fighting Equipment FP-009, (Rev. 4, 12/23/86)

Surveillance of Fire Protection Activities FP-010, (Rev. 9, 5/19/88)

Housekeeping Controls FP-011, (Rev. 3, 9/24/87)

Training and Drills Documentation

Based on this review it appears the above administrative control procedures meet the intent of NRC guidelines of 10 CFR 50, Appendix R, Fire Protection for Nuclear Power Facilities,Section II b. Fire Protection Organization The inspector examined the activities of certain fire protection organization member This review included interviews with the onshift Fire Protection Shift Technical Aide, review of issued Hot Work Permits, review of certain fire watch training records and observation of hot work operation During this inspection a welding operation was observed in the El/ER Roo An approved "Hot Work Permit" had been issued for the operation and an individual was assigned fire watch dutie Work practices observed met the licensee's fire prevention control procedure Additional inspector discussions were held with the Fire Protection Shift Technical Aide regarding Hot Work Permit issuance and fire watch training. A list of "certified" fire watch personnel is kept by the shift Technical Aide who issues the Hot Work Permit The Technical Aide ensures that listed fire watch personnel assigned fire watch duties are qualified through completion of instruction involving classroom lecture and practical exercis Contractor welding and cutting is supervised by plant fire protection procedures and limited to yard areas and the turbine generato As a result, the inspector determined that fire watch assignment for plant hot work activities and related fire watch training appeared to be in accordance with the fire protection program approved by the NR c. Fire Protection Surveillance Procedures The inspector reviewed the following Fire Protection System Surveillance Procedures:

Procedure N Title OST - 602 Unit 2 Fire Water System Valves (Rev. 16, 3/18/88)

(Monthly)

OST - 606 Unit 2 High Voltage Fire Detection (Rev. 5, 3/30/86)

System (Semi-Annual)

OST -

609 Inspection of Fire Protection (Rev. 13, 1/26/88)

System (Yearly)

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Procedure N Title (cont'd)

OST - 610 Unit 2 Portable Fire Extinguishers, (Rev. 16, 9/22/87)

Fire Hose Stations and Houses (Monthly)

OST -

621 Diesel Generator C02 (Rev. 4, 1/23/87)

System Cylinder Weight Test (Semi-annual)

OST -

626 Actuation and Flow Test for Cable (Rev. 4, 2/18/86)

Vault C02 Suppression System (18 months)

OST -. 632 Unit 2 Fire Suppression Water System (Rev. 5, 6/19/87)

Flow Test (3-Year Interval)

OST - 640 Self Contained DC Emergency Lighting (Rev. 12, 5/25/88)

System (Semi-Annual)

The above surveillance procedures were reviewed to determine if the various test outlines and inspection instructions adequately implement the surveillance requirements of the plant's Fire Protection Technical Specification In addition, these procedures were reviewed to determine if the inspection and test instructions followed general industry fire protection practices, NRC fire protection program guidelines and the

guidelines of the National Fire Protection Association (NFPA)

Fire Code Based on this review, it appears that the above procedures are satisfactor Fire Protection System Surveillance Inspections and Tests The inspector reviewed the following surveillance inspection and test records for the dates indicated:

Procedure N Test Results OST - 602 (Attachment 8.1)

5/18/88, 6/14/88, 7/13/88 Unit 2 Fire Water System Valves (Monthly)

OST - 606 (Attachment 8.1)

3/27/86, 8/4/86, 2/5/87, 8/4/87 Unit 2 High Voltage Fire 8/4/87 Detection System (Semi Annual)

Procedure N Test Results (cont'd)

OST - 630 (Attachments 8.7 &

10/24/86, 2/10/87, 4/10/87, 8.8)

6/25/87 Halon 301 Suppression System Weight Test (Semi-Annual)

OST - 648 (Attachments 8.2 to 8/1/87, 8/7/87 8.3)

CCW Room One-Hour Rated Fire Barrier Wrap Inspection (18 Month)

FP-009 (Attachment 7.2)

Monthly 2/88 to 8/88 Surveillance of Fire Protection Activities FP-010 (Attachment 7.2)

Weekly 5/6/88 to 8/26/86 Housekeeping Controls Weekly Housekeeping Inspection The surveillance test record data and testing frequency associated with the above fire protection system surveillance test/inspections were found to be satisfactory with regard to meeting the requirements of the plant's Fire Protection Technical Specification Fire Protection Audits The most recent reports of the H. B. Robinson Unit 2 Fire Protection Program were reviewed. These audits were:

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Nuclear Mutual Limited Periodic Inspection, October 15, 198 Annual Quality Assurance Audit, QAA/0020-87-07, October 26-30, 198 Nuclear Mutual Limited Inspection, March 24, 198 These audits identified several fire protection program open items and recommended several program improvement The licensee has either implemented the corrective actions associated with the insurance findings or a scheduled date for completion of the corrective actions had been establishe Review of the Corporate Quality Assurance Audit of the Fire Protection Program indicated potential significant findings related to plant modifications not being reviewed for impact on Appendix R compliance.and safe shutdown capability. Discussions between the inspector, the plant Senior Fire Protection Specialist, and Corporate personnel responsible for fire protection indicated that a review of these issues is on-goin Licensee management at the exit interview of September 2, 1988 were reminded of the importance of design configuration control for Appendix R complianc.

Fire Brigade a. Organization The total station fire brigade is composed of 64 personnel from the Operations staf 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 August 2-8, 1988, and verified that sufficient qualified personnel were on duty to meet the provisions of Technical Specification Section 6. In addition, the inspector verified that sufficient personnel were assigned to each shift to meet the minimum operating and fire brigade staff requirements of the Technical Specification Therefore, it appears based on the review of the duty rosters associated with the above dates, that there was sufficient.manpower on -duty to meet both the operational and the fire brigade requirements of the plant's Technical Specification b. Training The inspector reviewed the training records for classroom and drill sessions during 1987 and 1988 for three fire brigade leaders and four fire brigade members and verified that they had performed the necessary number of drills and classroom training as specified in plant Technical Specifications and OMM-00 The inspector also verified that a fire brigade drill had been conducted quarterly for each of the five shifts for 198 In addition, the inspector verified that an 'annual training session and onsite drill had been conducted with the offsite fire department, Hartsville Fire Department on October 20, 198 The fire brigade training records reviewed were found satisfactor Fire Brigade Fire Fighting Strategies The inspector reviewed the following plant fire fighting strategies contained within Operations Management Manual Procedure OMM-003:

Fire Area Title A

Zone 7 Auxiliary Building Hallway near Station and Instrument Air Compressors

Fire Area Title (cont'd),

A Zone 20 Emergency Switchgear Room B

Zone 4 Charging Pump Room C

Zone 5 Component Cooling Pump Room D

Zone 9 North Cable Vault E

Zone 10 South Cable Vault Based on this review, the inspector determined that the above fire fighting strategies adequately addressed the fire hazards in the area, the type of fire extinguishants to be utilized, the direction of attack, systems in the room/area to be managed in order to reduce fire damage, heat sensitive equipment in the room/area, and specific fire brigade duties with regard to smoke control and salvag Fire Reports The inspector reviewed the station fire reports for 1986, 1987 and 1988. These reports are designated in Fire Protection Procedure FP-002, Attachment 7.1. These reports indicated that on Unit 2 there were two incidents of fire in 1986, four fire events in 1987 and no events so far in 198 One of these fires in safety-related areas was significan This involved a lubricating oil fire in the "C" Reactor Coolant Pump (RCP) that occurred on January 17, 198 During this -review, the licensee provided documentation which indicated that the "C" Reactor Coolant Pump Motor was presently experiencing oil leakage while the unit was at powe CP&L memorandums dated July 28, 1988 (RNPD/88-3343)

and August 8, 1988, indicated that a CP&L Task Force developed to evaluate the problem considered the earlier "C" RCP fire history in their recommendation for a program to identify and fix the oil leak at the next upcoming refueling outag In the mean time, the licensee is closely monitoring the leak rate (-/drop/min)

and has taken extraordinary measures by relocating foam extinguishers and portable foam carts t the containment Personnel Hatch to address the increased probability of a fire in the "C" RCP bay and minimize fire brigade response tim In addition the licensee has reviewed their Appendix R long-term compliance to the provision of their NRC approved exemption from RCP oil collection systems in that a maximum quantity of 15 gallons was determined to be the limit on total free oil accumulation in the RCP

"C" bay for the period until the upcoming refueling outag Discussions between the inspector and the resident inspector indicated that the RCP oil leakage event has been adequately addressed by licensee management and that the fire protection compensatory measures taken are satisfactor Fire Brigade Drill During the inspection, the inspector witnessed an unannounced backshift fire brigade dril The drill fire scenario developed would involve the fire brigade demonstrating firefighting techniques (including fire hose handling) and which also would demonstrate the adequacy of communication interface between the fire brigade, the Control Room personnel, and Health Physics personnel during a fire emergency condition potentially having radiation hazard involvemen The fire drill postulated a spilled oil fire on and around the "B" Component Cooling Water (CCW) Pump with ignition from a short in "B" CCW pump motor. Electrical arcing would be evident on the pump motor and spilled oil would be draining to a floor drain between "A train" and "B train",pumps. The inspector reviewed the Fire Drill Planning Guide (Serial No. 88-3Q-Z)

and the prefire plan for Fire Area C, Zone 5, Component Cooling Pump Room, which included a walkthrough of the fire are This fire drill was initiated on August 30, 1988, at approximately 0600 hour0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> A regional Emergency Preparedness Inspector was stationed initially in the control room to observe the actions taken by the control room operators upon receipt of the fire alarm (a call was placed to the Unit.2 Control Room by licensee personnel).

This inspector was initially stationed at the fire brigade station at the Turbine Building and followed fire brigade personnel to the security door to the CCW pump room observing their actions until the fire drill was terminate Approximately eight fire brigade members responded to the pending fire emergenc Several fire brigade members including the fire brigade team leader responded to a newly installed Auxiliary Building Fire Brigade Equipment cabinet and donned full turnout appare The remaining fire brigade personnel were observed assembling and donning protective clothing and Self-Contained Breathing Apparatus (SCBA) at the fire brigade station and the CCW room entry point at the Turbine Building Breezewa The inspectors evaluated the fire brigade personnel actions in determining and observing the following:

(1) fire brigade members'

conformance with established plant firefighting procedures; (2) an assessment of the fire brigade leader's direction of the firefighting efforts; (3) actual donning and simulated use of the SCBA; (4) actual donning of protective clothing; (5) simulated use of the 1" fire hose-stations and firefighting equipment; (6) use of portable radiocommunication equipment; (7) brigade timeliness in response and numbers of personnel responding with proper firefighting equipment; and (8) brigade leader interaction with the Health Physics personnel and other support personnel (e.g., security on scene).

An initial size-up of the fire condition was made by the Fire Team Leader who communicated with the control room to de-energize the "B" CCW pum Based on this size-up, the brigade team established a

1 -inch water-foam fire attack hose line and advanced into the plant area experiencing the fire conditio The initial fire attack utilized a Halon portable fire extinguisher with final extinguishment with hose lines and foa The fire foam attack line was placed in service on the fire and the fire was placed under control within approximately ten minute The fire brigade utilized proper manual fire fighting methods and reacted to the fire drill scenario in a satisfactory manne The inspector participated in the post-drill critique where the following observations were discussed:

(1) Positive Observations o

The number of fire brigade members responding exceeded NRC minimum requirement o The fire brigade responded promptly to the fire scen o Personnel from health physics participated in the drill and simulated the taking of radiation survey (2) Areas of Improvement a

Contrary to Procedure FP-011 one fire brigade member responded to a simulated fire without wearing a SCB o Voice communications over the plant PA system at the Turbine Building Breezeway was, difficult to hea Following the drill the licensee prepared Nonconformance Report NCR No. 88/111 addressing the concern with the individual reporting to the fire scene without breathing apparatu This report indicated that the fire brigade member donned full turn-out apparel from a newly installed (August 1988)

auxiliary building fire brigade equipment cabine However, no self contained breathing apparatus was made available to him at this cabine Corrective action was taken immediately by the licensee by placement of two SCBA units at the auxiliary building fire equipment cabinet for fire brigade us Additionally, all fire brigade members will be trained on their responses to fires and the availability of the SCBA The licensee also provided to the inspector a memo (Serial No. RNPD/88-3425, File N, dated August 1, 1988),

which discussed deficiencies and proposed corrective actions for the plant PA system noted in past emergency drills. The licensee is tracking these corrective actions under RAIL 88R0079. These items will be reviewed during future NRC inspection. Plant Tour and Inspection of Fire Protection Equipment a. Outside Fire Protection Walkdown The plant has two Underwriters Laboratory (UL)

listed vertical turbine fire pumps rated at a capacity of 2500 gpm @125 psi Both pumps and controller are located on the open deck of the intake pump structur The two fire pumps were inspected and found to be in servic The following control valves in the outside fire protection water supply system were inspected and verified to be properly aligned in position:

Valve N Position Function FP-1 Open Fire Water Booster Pump Discharge Valve FP-2 Locked Open Motor Driven Fire Pump Discharge Valve.

FP-3 Locked Open Diesel Engine Driven Fire Pump Discharge Valve FP-4 Locked Open Fire Main Isolation Valve FP-7 Locked Open Fire Main Loop South Isolation Valve FP-85 Locked Open Isolation Valve From Fire Main to Hydrant No. 6 Fire Hydrant No. 6 and its associated equipment house was inspecte The equipment house contained the minimum equipment requirements of that specified by NFPA-24, Private Fire Service Mains and Their Appurtenances, and/or the FSAR commitments.,

The equipment appeared to be adequately maintained and the hydrant operable which met the requirements of the Technical Specification Section 3.1 A tour of the exterior of the plant indicated that sufficient clearance was provided between permanent safety-related buildings and structures and temporary buildings, trailers, and other transient combustible material The general housekeeping of the areas adjacent to the permanent plant structures was satisfactor b. Permanent Plant Fire Protection Features A plant tour was made by inspecto During the plant tour, the following safe shutdown related plant areas and their related fire protection features were inspected:

Fire Zone Description

Train "B" Diesel Generator Room

Train "A" Diesel Generator Room

Safety Injection Pump Room

Charging Pump Room

Component Cooling Pump Room

North Cable Vault Room

South Cable Vault Room

Unit 2 Cable Spreading Room

Emergency Switchgear Room and Electrical Equipment Area

Control Room

Hagan Room 4160-V Switchgear Room The fire/smoke detection systems, manual fire fighting equipment (i.e., portable extinguishers, hose stations, etc.) and the fire area boundray walls, floors and ceiling associated for the above plant areas were inspected and verified to be in service or functiona Based on this inspection, it appears that the fire protection features associated with the above plant areas are satisfactorily maintaine The plant tour also verified the licensee's implementation of the fire prevention administrative procedure The control of combustibles and flammable materials, liquids and gases, and the general housekeeping were found to be very good in the areas inspecte c. Appendix R Fire Protection Features This inspection also included a review of the fire barrier cable wrap enclosures required for compliance with Appendix R,Section III. for the CCW Pumps (Train A and C cables DS503, DS504, 24137, 24138 and pull box APPCC-3)

in Fire Zone 5, component Cooling Water Pump Roo Based on the inspector observations of the above cable fire barrier enclosures, it appears that the fire barrier integrity associated with the above fire barrier assemblies was being properly maintained in a satisfactory conditio The following eight-hour emergency lighting units were inspected:

Unit N Location ELS-13 Hagan Room ELS-14 Control Room ELS-54 Turbine Building Auxiliary ELS-91 Feedwater Valve Room ELS-37 4160 V. Switchgear Room ELS-55 ELS-103 ELS-5 Auxiliary Building CVCS CLS-83 Charging Pump Room Access These units were in service, lamps properly aligned and appeared to be maintaine Within the areas examined, no violations or deviations were identifie.

Exit Interview The inspection scope and results were summarized on September 2, 1988, with those persons indicated in paragraph The inspector described the areas inspected and discussed in detail the inspection result Proprietary information is not contained in this repor Dissenting comments were not received from the licensee.