IR 05000261/1991013
| ML14178A109 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 05/17/1991 |
| From: | Christensen H, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14178A108 | List: |
| References | |
| 50-261-91-13, NUDOCS 9105290282 | |
| Download: ML14178A109 (6) | |
Text
Apgst FEGL,.
UNITED STATES 0 oNUCLEAR REGULATORY COMMISSION A
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 Report No.:
50-261/91-13 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: April 8-11, 1991 Inspector:
,
9,v 7o- >Y--h G. R. Wiseman, Reactor Engineer DAte Signe Approved by: 1". -0
?
H.'T. Christensen, Section Chief te igned Reactor Projects Branch 1 Division of Reactor Projects SoeSUMMARY Scope:
This routine unannounced inspection was conducted in the areas of Inspector Follow-up Items (IFI) related to Fire Barrier Penetrations from NRC inspection report 88-31, onsite follow-up of written reports of non routine events, and review of the licensee's Fire Protection Program (64704).
Results:
In the areas inspected, violations or deviations were not identified. During this inspection, the NRC inspector discussed the plant's status of implementa tion of fire protection requirements provided in Generic Letters 86-10 and 88-12 with the licensee's plant and corporate staff. The licensee's response to these discussions resulted in verbal commitments as documented in paragraph 4 of this repor PDR ADOCK 05000261 G
REPORT DETAILS 1. Persons Contacted Licensee Employees
- R. Barnett, Manager, Outages and Modifications
- B. Biggs, Manager, Nuclear Engineering Department Site Unit
- W. Brown, Senior Fire Protection Specialist, Operations
- R. Chambers, Manager, Operations
- R. Crook, Senior Specialist, Regulatory Compliance
- C. Dietz, Manager, Robinson Nuclear Project
- J. Kloosterman, Manager, Regulatory Compliance
- L. Lynch, Supervisor, Quality Control
- E. Roper, Senior Fire Protection Specialist
- J. Sheppard, General Manager NRC Resident Inspectors
- L. Garner, Senior Resident Inspector
- K. Jury, Resident Inspector Fire Protection/Prevention Program (64704)
a. Plant Tour and Inspection of Fire Protection Equipment (1) Plant Fire Protection Features A plant tour was made by the inspecto During the tour, the following safe shutdown plant areas and their related fire protection and alternative shutdown features for a fire event were inspected:
Fire Area A Fire Zone 1 -
Diesel Generator "B" Room Fire Zone 2 -
Diesel Generator "A" Room Fire Zone 3 - Safety Injection Pumps Room Fire Zone 7 - Auxiliary Building First Level Hallway Fire Zone 15 - Auxiliary Building Second Level Hallway Fire Zone 17 - Heating and Ventilation Equipment Room Fire Zone 19 - Unit 2 Cable Spreading Room Fire Zone 20 - Emergency Switchgear Room Fire Area C Fire Zone 5 - Component Cooling Pumps Room
Fire Area E Fire Zone 10 -
South Cable Vault Fire Area G Fire Zone 25 - Turbine Building The manual fire fighting equipment, automatic fire detection systems, and fire area/fire zone boundary walls, floors, and ceilings associated for the above plant areas were inspected and verified to be inservice or functiona Based on this walkthrough inspection, it appeared that the fire protection features associated with these plant areas were being satisfactorily maintaine The plant tour also verified the licensee's implementation of the fire prevention administrative procedures. The licensee had placed a fire/security door between Fire Area A (Zone 17)
and Fire Area G (Zone 25) out of service (open) due to modifications work being performed in the heating and ventilation roo The area was posted with security personnel and a fire watch in the work are The licensee had posted the associated Hot Work Permit in the work area. The work area had been cleared of all unnecessary combustibles and inspected by the work group supervisor. The fire watch was attentive to the assigned duties and knew the location of the fire extinguishers and communica tions equipment in the area in case of a fire even The inspector also verified the licensee's implementation of housekeeping procedure During the inspector's walkthroughs uncontrolled combustibles associated with piping insulation repairs were noted in several plant area The inspector identified several cardboard boxes containing insulation and a acetylene torch cart with hoses and cylinders stored and partially blocking access to the remote shutdown boards located on the mezzanine level of the turbine building. The inspector expressed concern to the Senior Fire Protec-tion Specialist that storage of these materials in this location may prohibit access to safe shutdown equipment during an emergenc The Fire Protection Specialist immediately contacted the Supervisor for the area, and the materials were removed within approximately ten minutes after discover Other insulation materials were found stored in plastic bags within the Component Cooling Water Pumps Roo The inspector discussed with the licensee's fire protection staff the above items and the desirability of removing combustible materials from controlled areas after shift work is complete Other than noted above, the control of combustibles and flammable materials, liquids and gases, and the general housekeeping were found to be satisfactory in the areas inspecte (2) Outside Fire Protection Walkdown The following sectional control valves in the main fire protection water supply system were inspected and visually verified to be properly aligned, and locked in position:
PIV -
243 PIV -
246 PIV -
447 PIV -
466 Several fire hydrant equipment houses located adjacent to external fire hydrants were inspecte The equipment houses contained the equipment specified by NFPA -
24, Private Fire Service Mains, and/or the FSAR commitment The equipment appeared to be adequately maintaine.
Follow-up (92701, 92702)
(Closed) LER 90 - 10, Inoperable Fire Barrier Penetration Sea This item was identified as part of the corrective actions in LER 90-03, and the licensee's fire barrier inspection progra The inspector verified via review of work request WR/JO 90 -
AHUK1, completed on June 26, 1990, that the condition identified inLER 90 -
10 had been repaired as stated in the LER. This LER is considered close (Closed) IFI 88-31-01, Review of Engineering Evaluations for Fire Barrier NRC Inspection Report 90-15 documented the status of the licensee's 1990 Fire Barrier Penetration Inspection program to provide inspection of all fire-barrier penetrations to insure the seal was operable per the required Technical Specification Surveillance OST-62 This licensee inspection identified additional fire barrier components which were not installed in conformance with the requirements of fire rated barrier The licensee has inspected and analyzed the barriers for all safety related shutdown interior fire zones within the plant and has generated a number of Engineer Evaluations (EEs)
(as allowed by Generic Letters GL 86-10 and GL 88-12)
to address the adequacy of fire barrier penetrations for each zone which are not three hour rated seal In addition fire doors and fire dampers which do not conform to the respective NFPA requirements are listed, and deviations generically addressed in engineering evaluation EE 90-10 Nonconforming blockouts are listed, and deviations are addressed generically in EE 90-07 In addition to the above generic EEs, the inspector reviewed in detail the following Engineering Evaluations:
EE N Associated Fire Zone 90-107-Fire Zone 1 90-110 Fire Zone 6 90-106 Fire Zone 2 90-119 Fire Zone 15 90-124 Fire Zone 20 90-109 Fire Zone 5 90-126 Fire Zone 22 Each of the evaluations for nonconforming seals, established a basis for evaluation of the existing penetration seal configuration as an acceptable alternative to totally replacing or repairing a seal in which it was not feasible or practicable for reasons that included personnel safety, equipment operability, maintenance or operations access or similar obstacle In addition all engineering evaluations provided a Fire Protection Evaluation for each seal which reiterated or validated key concepts of previously approved fire hazards analysis or other engineering evaluations and an assessment of the impact of effects of analyzed deviating penetration seals on the plant safe shutdown capability and the plant licensing basis (NRC Approved Appendix R exemptions).
The inspector selected several licensee analyzed fire barrier penetration seals for visual inspection:
Identified Seal Deviation Number Location Fire Zone N Access interference EP-44945 Emergency (Fire Zone 20)
for repair Switchgear Room Improper Foam EP-2525 CCW Pump Room (Fire Zone 19)
cell cure and and Unit 2 congestion Cable Spreading Room No Fire Damper AP-2104 Diesel Generator (Fire Zone 2)
installed in opening
"A" Room Inadequate Seal CP-4754 Emergency (Fire Zone 20)
depth Switchgear Room Unrated fire doors CP-4560 Auxiliary (Fire Zone 15)
(FD-46 and FD-47 Building Second Level Hallway
The EE's reviewed clearing stated and analyzed the technical basis for accepting the penetration seals in an "as-is" condition and/or also provided descriptions of modifications completed to upgraded or repair certain seals to on acceptable justified (although not fully tested)
configuration. In all cases the evaluations stated justifications for not fully repairing or replacing those seals which are not installed in conformance with three-hour rated fire seal The inspector visually verified that these existing fire barrier penetration seal configurations were as described in the evaluation Based on the inspector's review of the minutes of the Plant Nuclear Safety Committee meeting of February 22, 1991 (N ) the licensee has of March 7, 1991, completed repair of all Appendix R interior wall penetration Penetrations in exterior walls had not been complete A schedule for completion of those forty-one remaining penetrations has been provide The licensee's goal was to have these completed by August 1, 199 Based on the inspectors review of EE's and the licensee's penetra tion repair schedule this item is considered close. Exit Interview The inspection scope and results were summarized on April 11, 1991, with those persons indicated in paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results listed belo Proprietary information is not contained in this repor Dissenting comments were not received from the license The following items were reviewed and closed:
oLER 90-10 olFI 88-31-01 The inspector expressed to the licensee at the exit interview the observation that H. B. Robinson has yet to prepare and submit a license amendment request, after incorporating the NRC approved Fire Protection Program in the Final Safety Analysis Report, to fully implement the guidance of Generic Letter 86-10 to provide a licensing basis for the Engineering Evaluations for Fire Barrier Penetration Seal Discussions with licensee regulatory compliance personnel indicated that the corporate licensing organization had not scheduled such a license amendment request for implementation of Fire Protection requirements at Robinso The inspector requested that further information be provided to the NRC on this observatio Subsequent to the inspection, the licensee made certain verbal commitments to the NRC in a telephone conference on April 19, 199 These commitments specifically relate to the licensee to prepare and submit to the NRC, prior to the end of February 1992, a license amendment request to fully implement Generic Letter 86-10, thus instituting the standard license condition for the Robinson Fire Protection Program which includes the Engineer Evaluations described in paragraph 3 of this report.