IR 05000269/1989004
| ML16127A304 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 02/24/1989 |
| From: | Conlon T, Ward D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16127A303 | List: |
| References | |
| 50-269-89-04, 50-269-89-4, 50-270-89-04, 50-270-89-4, 50-287-89-04, 50-287-89-4, NUDOCS 8903140286 | |
| Download: ML16127A304 (14) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
101 MARIETTA ST., ATLANTA, GEORGIA 30323 Recrt Nos.:
50-269/89-04, 50-270/89-04, and 50-287/89-04 Licensee:
Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nlos.: 50-269, 50-270, License Nos.: DPR-38, DPR-47, and and 50-287 DPR-55 Facility Name:
Oconee 1, 2, and 3 Inspection Conducted:
January 23-27, 1989 Inspector:
My D. Ward Date Signed Approved by:
/
v e/t T. Conlon, Chief Date Signed Plant Systems Section Engineering Branch Division of Reactor Safety SUMMARY Scope This routine, unannounced inspection was conducted in the areas of Fire Protection/Prevention program implementatio Results Within this inspection, several strengths and weaknesses were identified in the implementation of the Fire Protection Program. These strengths and weaknesses are summarized below:
Strengths
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The licensee understands the importance of maintaining the fire protection systems operabl This is apparant based on the licensee's timely resolution of fire protection system impairment Between January and June 1988, over ninety percent (90%)
of the impairments which occurred were resolved and the system returned to service within one da The staffing of the Safety/Fire Protection Department onsite and in the corporate Design Engineering group is adequat The onsite group is staffed with two fire protection specialist who have primary responsibility for the implementation of the Fire Protection Progra However, the entire Safety/Fire Protection staff actively monitors
the implementation of the progra In addition, a Fire Protection Engineer is also assigned to the site from the corporate Design Engineering offic Weaknesses It does not appear that management is actively pursuing the implementation of fire prevention procedures. A single violation for failure to implement the requirements of the Station Directive governing welding and burning operations was identified during this inspectio Violations of the Station Directive by the same work group had been identified numerous times during the previous year by the Safety/Fire Protection Department; however, the work groups management did not pursue the resolution of the violations until the NRC inspector identified this as a concer There is a potential weakness in the area of fire brigade trainin The fire brigade training requirements at Oconee deviate from the NRC guidelines in that Quarterly Training sessions are not required for each fire brigade member and brigade members are not required to participate in two fire drills per yea The licensee's training program was approved by the NRC with the lack of these training requirements. Under the present training guideline, a brigade member may only receive annual training and may never participate in a fire drill in the plant and still remain eligible to serve on the fire brigad This is identified as a potential weakness since the licensee does offer optional quarterly training which the majority of the fire brigade members are presently electing to attend, the licensee presently conducts one drill per quarter for each operating shift which over the year allows the majority of the brigade members to attend at least one drill. The fire brigade performance in the drill witnessed by the inspector was very goo Within the areas inspected, the following violation was identifie Failure to Implement the Requirements of SD 4.2.4; Paragraph 2.a (Not Cited).
REPORT DETAILS Persons Contacted Licensee Employees
- H. Brandes, Design Engineering
- S. Christopher, Design Engineering
- T. King, Safety
- E. Legette, Compliance
- J. McIntosh, Station Services
- D. Powell, CMD-South
- T. Roach, CMD-South
- M. Tuckman, Station Manager Other licensee employees contacted during this inspection included craftsmen, engineers, operators, mechanics, security force members, technicians, and administrative personne NRC Resident Inspectors
- L. Wert
- Skinner
- Attended exit interview 2. Fire Protection/Prevention Program (64704) Fire Prevention/Administrative Control Procedures The inspector reviewed the following Fire Prevention/Administrative Procedures:
Procedure-Date Title SD 4.2.1 - 10/26/87 Control Of Combustible Materials SD 4.2.2 - 9/8/88 Fire Brigade Organization and Training SD 4.2.3 - 11/16/87 Reporting of Fire Protection Impairment SD 4.2.4 - 11/8/88 Welding and Burning Safety Directive SD 4.3.1 -
9/6/88 Housekeeping Based on this review, it is considered that the above procedures satisfy the licensee's commitments made in a January 16, 1978, letter to the NRC and as approved in Section 6.0 of the NRC'S August 1978 Safety Evaluation Report (SER).
Although the fire brigade training
..
requirements outlined in Station Directive (SD)
4.2.2 exceed the
training commitments approved by the NRC in the August 1978 SER, these training requirements still deviate significantly from the latest NRC guidanc The differences are discussed in paragraph 2.C.(2) of this repor The inspector reviewed the implementation of SD 4.2.3 and SD 4. Procedure SD 4.2.3 outlines the requirements for controlling the fire protection system impairments for periodic testing, maintenance, and repair to insure the station Fire Protection Technical Specifications are followe The inspector found by reviewing the fire protection impairments which occurred between January and June 1988 that over ninety percent (90%)
of all impairments were returned to service within one da None of the systems required to be operable by Technical Specification were out of service more than seven.day The inspector considered this a strength in the fire protection program and it demonstrates that the licensee clearly understands the importance of maintaining the fire protection systems operabl Procedure SD 4.2.4 outlines the requirements for performing welding and burning at Ocone The procedure outlines a permit system which requires pre-work fire safety inspection signoffs, fire safety precautions and training requirements for personnel involved in this type of wor The inspector reviewed approximately 40 welding and burning permits issued to the Construction Maintenance Department (CMD)
since November 1988 to determine if the requirements of SD 4.2.4 were being implemente The inspector found that on six permits supervisors and/or fire watches were assigned who did not satisfy the training requirements of SD 4. Specifically, Sections 4.2.1 and 5.4.1 requires supervisors and fire watches to attend the required trainin The inspector followed up on this finding by reviewing Safety/Fire Protection Violation Reports issued in 198 These reports are issued to document violations of site fire protection procedure The inspector found that of the twenty five reports reviewed, fifteen were for the same infraction of SD 4.2.4 by CMD as the inspector had identifie This item is identified as Violation 50-269,270, 287/89-04-01, Failure to Implement the Requirements of SD 4.2.4, since Technical Specification 6.4.1 requires the station to be operated and maintained in accordance with approved Fire Protection Program implementation procedure In response to this finding the license initiated the following corrective actions:
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A fire watch training schedule will be developed which will identify whose fire watch qualifications will expire the following mont Completion date February 28, 198 Any violation of SD 4.2.4 will result in a formal counseling notice to the employe All employees whose training has expired will be notified and they will not be allowed to perform the supervisor/fire watch function until they are requalifie Completion date January-30, 198 Once implemented, these actions are considered to be adequate to resolve the inspectors finding and to insure similar violations will not occur. Therefore, this violation meets the criteria specified in Section V of the NRC Enforcement Policy for not issuing a Notice of Violation and is therefore not cite Fire Protection Surveillance Procedures The inspector reviewed the following Fire Protection System Surveillance Procedures:
Procedure (Revision)
Title IP/O/A/250/5B Fire Detection System Inaccessible (Rev. 11, Changes 12, 13, 14)
Detector Functional Test IP/O/A/385/2C Standby Shutdown Facility (SSF)
(Re )
Fire Protection C02 System Level and Pressure Calibration MP/1/A1705/01 Fire Protection Equipment (Rev. 29)
Inspection Monthly MP/1/A/1705/19 Fire Protection -
Fire Rated Doors (Rev. 9)
Bi-monthly Inspection MP//B/1705/22 Fire Protection - Fire Hydrants and (Rev. 4; Changes 5,6)
Post Indicator Valves Semi-Annual Inspection PT/O/A/400/2 SSF C02 Fire Protection System (Rev.7; Changes 8,9)
Performance Test PT/1/A/250/1OC Fire Protection System (Rev. 2)
Valve Dry Test PT/0/A/250/25 Fire Protection Annual Flow Test (Rev. 10; Change 11)
PT/O/B/250/28A Third Floor Auxiliary Building (Rev. 2)
Annual Sprinkler PT/O/B/250/30 Monthly Fire Brigade Equipment (Rev. 7)
Check
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 c. Fire Protection System Surveillance Inspections and Tests The inspector reviewed the following surveillance inspection and test records for the dates indicated:
Procedure N Test Dates iP/0/A/0250/05B 10/12/86, 4/5/88, 7/11/88 MP/3/A/1705/01 11/4/87, 12/7/87, 1/7/88, 2/10/88, 3/7/88 MP/1/A/1705/19 11/3/86, 1/2/87, 3/6/87, 4/6/87, 6/16/87, 8/4/87, 10/6/87, 12/18/87, 2/9/88, 4/7/88, 6/10/88, 8/4/88 MP/0/B/1705/22 11/7/85, 4/30/86, 11/3/86, 5/11/87, 11/19/87, 5/5/88 PT/0/A/250/25 4/18/86, 4/13/87, 3/28/88 PT/0/B/250/28A 6/12/87, 6/16/88 PT/0/B/250/30 12/28/87, 1/22/88, 2/17/88, 3/18/88, 4/27/88, 5/25/88, 6/17/88, 7/28/88, 8/25/88, 9/27/88, 10/28,88, 11/18/88, 12/7/88 PT/0/A/400/02 7/7/87, 2/5/88, 6/30/88 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 Procedure IP/0/A/250/05B, Fire Detection System Inaccessible Detector Functional test, provides for fire detector sensitivity adjustments during the functional surveillanc The sensitivity adjustment was
not performed on the Unit 2 detectors during the April 5, 1988, and Uuly 11, 1988., surveillances because the equipment required to perform the adjustment was inoperabl This sensitivity adjustment is not required by the Technical Specifications to maintain the system operable but is required by the NFPA Code 72E, Automatic Fire Detector The inspector discussed with licensee management the need to have this test equipment available for the required surveillanc This will be reviewed during a future inspectio Fire Protection Audit The most recent audit reports of the Oconee Fire Protection Program were reviewed. These audits were:
M & M Protection Consultants Inspection for NML Issuance; October 19-20, 1988 QA Department Audit NP-88-10 (ON); May 9, 1988 The Ml & M Protection Consultants inspection did not identify any significant finding QA Audit NP-88-10 identified a number of unresolved items and recommendations which the licensee has resolved or is in the process of implementing corrective action. This audit identified a single deficiency regarding fire barrier penetration seals which has been resolved by the licensee. Therefore, it appears the licensee is taking appropriate corrective actions on audit finding Fire Brigade (1) Organization The total station fire brigade is composed of approximately 180 personnel from the operations, health physics and maintenance staff. The on duty shift fire brigade leader is normally one of the licensed operator The inspector reviewed the on duty shifts for the following dates and verified that sufficient qualified fire brigade personnel were on duty to meet the provisions of the plant's Technical Specifications:
December 24, 1988 December 25, 1988 December 31, 1988 January 1, 1989 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 Specifications by reviewing operator staff attendance record 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 (2) Training The inspector reviewed the fire brigade training requirements outlined in Procedure SD-4.2.2, and compared it to the NRC guidanc The inspector found that the licensee committed to perform the following training by letter dated January 16, 1978, and in their initial comparison to the requirements of Appendix A to BTP APCSB 9.5-1 dated February 198 Initial Fire Brigade Training for all new members Annual Practice on live fires Bi-annual Requalification This training program was approved by the NRC in an August 1978 SE However, this program deviates significantly from that presently outlined in NRC guidance which recommends *the following training requirements:
Initial Fire Brigade Training Annual Practice on Live Fires Quarterly Training Fire Drills - Two Drills per Year per Brigade Member The licensee's training program outlined in SD-4.2.2 does have training in addition to the committed training above which includes Quarterly Training and Fire Drills; however, this training is not required to maintain a member's qualification In addition a fire brigade member who does not attend Fire Drills is only required to review the drill critiques for the past year. Therefore, it is possible that following the initial fire brigade training, a brigade member may not receive additional training for a full year and may never participate in an in-plant fire dril The inspector emphasized to the licensee the importance of each brigade member receiving periodic training and participating in fire drill The inspector found that the licensee's training program as outlined in SD-4.2.2 meets the licensee's commitment The inspector reviewed the training records for 15 brigade members for 198 The records reviewed indicated that each member had attended the required initial, annual and bi-annual trainin The inspector also verified that one drill had been conducted for each of the five operating shifts in 1988 as committed to by the licensee. The fire brigade training records which were reviewed were found satisfactor In addition, the inspector attended a training session for fire brigade leader This session involved the use of a classroom fire simulator which required the leaders to simulat communications, command post activities, and fire fighting activities for postulated fires in various plant area Following each simulation, the leaders performance was critiqued by other fire brigade members and the instructor This training was very effective in enhancing the leaders performanc (3) Fire Brigade Drill During this inspection, the inspector witnessed an unannounced fire brigade dril The drill fire scenario was a fire in the Unit 2 East Penetration Room to West Penetration Room cross over area which involved energized cables and was apparently caused by an electrical faul The fire brigade initially staged at the fire brigade equipment room just outside the Units 1 and 2 Control Room where the fire brigade leader established a command pos The leader then broke the assembled brigade members into two attack teams. and instructed one group to attack the fire from the West Penetration Room and one from the East Penetration Roo The inspector witnessed the action taken by the brigade members in the East Penetration Roo This group assembled outside the East Penetration Room in full protective clothing and self contained breathing apparatus. The leader assigned to this group then instructed the brigade members to advance one 11 inch attack line into the room and apply a fog pattern spray to the burning cable The fire was declared out approximately 30 minutes after the alarm was initiate The fire brigade utilized proper manual fire fighting methods and reacted to the fire drill scenario in an effective and efficient manne The fire brigade leader managed the resources available effectively and implemented effective brigade command. In addition, the communications between the fire scene, fire brigade leader and Control Room were carried out very effectivel Plant Tour and Inspection of Fire Protection Equipment (1)
Inspection of Fire Brigade Manual Fire Fighting Equipment The inspector performed an inspection of the fire brigade equipment, consisting of fire hose, nozzles, tools, and miscellaneous equipment, stored at the following fire brigade equipment response locations:
Name Location Brigade Leaders Cabinet Level 5 #2 Control Room Lobby Equipment Cart Level 5 #2 Control Room Lobby Equipment Storage Room Level 5 #2 Elevator Lobby TB Cabinet Turbine Building Equipment Storage Room Level 5 #3 Elevator Lobby Equipment Cart Level 5 #3 Control Room Lobby Five Equipment Trailer #1 North Side of Radwaste Facility, Foam Trailer #2 North Side of Radwaste Facility The equipment required at each location is described in Procedure PT/O/B/250/30, Monthly Fire Brigade Equipment Chec With a few minor exceptions which were immediately resolved, the equipment was found stored in the proper locatio ':Outside Fire Protection Walkdown The inspector verified that the two High Pressure Service Water Pumps (HPSW) which provide water to the plants fire protection systems were in servic The suction and discharge isolation valves were verified locked in the open positio The following sectional control valves in the HPSW outside fire protection water supply system were inspected and verified to be properly aligned and locked in position:
Valve N Position HPSW-8 Locked Open HPSW-80 Locked Open HPSW-105 Locked Open HPSW-110 Locked Open 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 (3) Permanent Plant Fire Protection Features A plant tour was made by the inspector. During the plant tour, the following safe shutdown related plant areas and their related fire protection features were inspected:
Units 1, 2, and 3 East Penetration Rooms Units 1 and 2 West Penetration Rooms Units 1, 2, and 3 Cable Spreading Rooms Units 1, 2, and 3 Equipment Rooms Units 1, 2, and 3 High Pressure Injection Pump Rooms Units 1, 2, and 3 Battery Rooms Keowee Hydro Station The fire/smoke detection systems, manual fire.fighting equipment (i.e., portable extinguishers, hose stations, etc.)
and the fire area boundary walls, floors and ceilings associated for the above plant areas were inspected and verified to be in service or functiona The automatic sprinkler systems required to be operable per Technical Specifications that protect the CT 1 and CT 4 transformers were found operable. The low pressure C02 system which is non-technical specification protecting the safe shutdown facility (SSF) was found operable with the tank full at 300 ps Based on this inspection, it appears that the fire protection features associated with the above plant areas are satisfac torily 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 satisfactory in the areas inspected; however, the inspector did note that in some plant areas trash was not collected, polysheeting was left discarded and fire protection trash can covers had been removed and not replace The licensee's staff took immediate corrective action to eliminate these housekeeping problem (4) Appendix R Fire Protection Features The inspector made a walkdown of the Appendix R related sprinkler protection in the following plant areas:
Units 1, 2, 3 Cable Spreading Room Based on this walkdown, the inspector determined that the sprinkler protection provided for the areas identified above provided sufficient protection with respect to controlling an exposure fir The following eight-hour emergency' lighting units were inspected:
Unit N Location
Aux.,Bldg. 3rd Fl. Col. Line 81/Q
Aux. Bldg. 3rd Fl. Col. Line 82/Q
Aux. Bldg. 3rd Fl. Col. Line 83/Ra
Aux. Bldg. 3rd Fl. Col. Line 85/Ra
Aux. Bldg. 3rd Fl. Col. Line 76/Q These units were in service, lamps properly aligned and appeared to be properly maintaine (5) Reactor Coolant Pump Lube Oil Collection System The inspector conducted a walkdown of the Reactor Coolant Pump (RCP) Lube Oil Collection Systems installed on each of the four Unit 1 RCP The inspector verified that the piping and supports for each system was as shown on the following system design drawings and that each tank had a flame arrestor installed on thecollection tank vent line:
Drawing N Revision O-1RB-NSM 173401
0-RB-NSM173402
O-RB-NSM173403
0-RB-NSM173404
Some areas were inaccessible due to airborne contamination and in these areas the piping, supports, and flame arresters were not inspected. The portions of the systems inspected were found to have piping supports and flame arresters installed as required and it appeared the systems were being properly
.maintaine Action on Previous Inspection Findings (92701)
The following previously identified inspection findings require resolutions by NRR and remain open:
Item-Number Description 50-269,270,287/87-02-01 Violation:
Inadequate Appendix R Circuit Analysis 50260,,270,287/802-02 URI Determine The Status of The SSF Dedicated Submersible Pump as Related to an Appendix R Repai,270,287/87-02-03 URI Adequacy of Actuation Events Evaluation Following Control Room Evacuation 50-269,270,287/87-02-06 URI Inadequate Fire Detection Coverage to Meet Requirements of Appendix R, III (Open) 50-287/87-02-07, Sprinkler Protection Required For Instrument Calibration Room In Area 30 This item was opened to ensure that the sprinkler system protecting the calibration room which is presently only provided above the suspended ceiling is modified to protect hazards below the ceilin Three options for resolving this item are outlined in the inspection report:
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Remove the suspended ceiling over the work area;
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Extend the sprinkler system below the ceiling; or
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Install an.approved "drop-out" type suspended ceilin The inspector found that subsequent to the 87-02 inspection, the licensee decided to modify the Instrument Calibration Roo This modification is being done under Nuclear Service Modification (NSM)
5268 The NSM significantly alters the configuration of the area such that the licensee determined that modifying the sprinkler system prior to the NMS implementation would not be cost effective since the NMS will require additional sprinkler system changes. Therefore, the resolution of this item is dependent upon the completion of NSM 5268 The inspector reviewed the NSM package and found that the licensee proposes to install one sidewall type sprinkler head in the Instrument Calibration Room. When implemented, this will be adequate to resolve the inspection findin.
Exit Interview The inspection scope and results were summarized on January 27, 1989 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, 270, 287/89-04-01 Violation (Not Cited):
Failure to Implement The Requirements of SD-4.2.4, Paragraph 2.a.