IR 05000271/1989004

Insp Rept 50-271/89-04 on 890320-23.Violation Noted.Major Areas Inspected:Review Adequacy & Implementation of Fire Protection Program,Including Combustible Matl Control, Housekeeping Conditions,Surveillances & Testing

ML20247K126
Person / Time
Site:	Vermont Yankee
Issue date:	05/17/1989
From:	Anderson C, Krasopoulos A, Mathews R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20247K088	List: IR 05000271/1989004 ML20247K084 ML20247K119
References
50-271-89-04, 50-271-89-4, NUDOCS 8906010222
Download: ML20247K126 (8)

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U.S. NUCLEAR REGULATORY. COMMISSION

REGION I

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Report N /89-04 Docket N License No. DPR-28 Licensee: Vermont Yankee Nuclear Power Corporation RD-5, Box 169 Ferry Road .

Brattleboro, Vermont 05201 )

Facility Name: Vermont Yankee Nuclear Power Corporation Inspection At: Vernon, Vermont Inspection Conducted: March 20-23, 1989 Inspectors: ,

A. Kvaso b

1 s, Reactor Engineer r

date f O' - < S /1b1 R. M8 thews, Reactor Engineer date Approved by:  !. .p 7[tf C. J. / Anderson, Chief, Plant Systems date Section Inspection Summary: Inspection on March 20-23,1989 (Report No. 50-271/89-04)

Areas Inspected: This routine unannounced inspection reviewed the adequacy and implementation of the licensee's Fire Protection Program. The inspection included reviews of the following program aspects: combustible material control, housekeeping conditions, surveillance and testing performed on fire

. suppression and detection equipment, and fire brigade training. Also, a walkdown of fire suppression systems, in particular the carbon dioxide suppression systems in the cable vault and switchgear rooms, was performe Results: The inspector identified a violation regarding operability of the carbon dioxide system in the cable spreading room. Following this inspection, the NRC resident inspector identified a similar violation regarding the operability of the carbon dioxide system in the diesel fire pump day tank roo The operability of these systems was not demonstrated during performance of the initial acceptance tests for these systems. Additional concerns were identified regarding housekeeping conditions, in particular the practice of erecting j combustible structures adjacent to safety related buildings, and the depth of '

engineering involvement in issues affecting the Fire Protection Progra ,%71 PDR ADOCK PDC Q

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DETAILS

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1.0 Persons Contacted Vermont Yankee Nuclear Power Corporation (VY)-

• J. Pelletier, Plant Manager

• R. Pagodin, Technical Services Superintendent

• D. Girroir, Sr. Quality Assurance (QA) Engineer E. Taintor, QA Coordinator / Fire Protection Coordinator

• R. Wanchyk, Operations Superintendent

• R. Moschella, Electrical Engineer P. Johnson, Electrical Engineer

• R. Grippardi, QA Supervisor

• H. Mettell, Engineering Support Supervisor United States Nuclear Regulatory Commission (NRC)

G. Grant, Sr. Resident Inspector

• Denotes those present at the exit meetin .0 Followup of Previous Inspection Findings (Closed) Violation (88-04-01) Lack of Emergency Lights in the Control Room, Torus Catwalk and Fire Area FA-RB-5 The NRC identified the violation of 10 CFR 50 Appendix R, Section III.J in that' emergency lights were not installed in the above area The licensee installed emergency lighting units in the Control Room prior to the NRC team leaving the site. For the Catwalk area the licensee requested an exemption from the requirement because the area contains lighting units powered from the Emergency Diesels. The NRC granted that exemption. Fire Area RB-5,was re-examined by the licensee by turning off all lights in the area to determine the illumination levels provided by the existing emergency lighting. The 1:'umination wa found to be adequate. The above actions satisfy the NRC concerns and this item is close {0 pen) Unresolved Item (88-04-02) Fire Stops in Reactor Building The NRC identified the concern that the fire stops installed to provide fire break zones were inadequately installed. These stops were installed in 5 to 7 foot strips on both sides of each fire break are The correct way of installing the fire stops would be to install the fire retardant thru the entire length of the fire brea The licensee committed to have the fire stops installed at the first opportunity. The licensee stated that they were unable to complete the engineering work associated with the fire stops, therefore, the fire stops will not be installed during this

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outage. The engineering work involves an evaluation of the electrical tray seismic supports to assess the impact of the additional weight from the fire retardant. This modification will be completed by the end of 1989 calendar year. The licensee, meanwhile, has in place, roving fir watche (Closed) Unresolved Item (88-04-03) Circuit Coordination During the circuit coordination review of the Appendix R program, the NRC team observed that coordination curves and analyses for the 120V AC and

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125V DC circuits were not available. The licensee acknowledged the coordi-nation and documentation concerns and committed to finalize the analyse The analyses were completed and the inspector verified the time-current characteristic curves for the 120VAC and 120VDC circuits. The breakers are adequately coordinated except for the breaker of valve V10-17 operato This valve is used for containment isoletion in series with valve V10-1 One of these valves would remain closed because power cables for V10-17 and V10-18 are routed through different fire areas, therefore, a single fire could not disable both valves. The inspector had no further l questions. This item is close (Closed) Unresolved Item (88-04-04) High Impedance Fault The NRC team identified that the analysis of the effect of high impedance faults on all electrical power sources required for safe shutdown was incomplete. The licensee completed this analysis and the inspector reviewed it with regard to fault conditions, assumptions for analysis, breaker set points and safe shutdown operability for 120V AC, 125V DC and 480V AC circuits. The documentation concerning high impedance fault analysis has been completed. Based on this review, the inspector concluded that there is no high impedance fault concern and the safe shutdown load power supplies are adequately protecte (Closed) Unresolved Item (88-04-05) Inadequate Fuse Prctection l

The NRC inspection team conducted a review of the common enclosure ,

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associated circuit concern to determine the adequacy of the electrical '

isolation protectio The team observed that 12 AWG conductors were protected with 35 Amp fuses instead of the required 30 Amp fuses. The inspectors reviewei the licensee analysis of the above concer The 12 AWG l conductors identified are cross-linked polyethylene insulated cables rated at 90 C continuous full load operation. The emergency overload rating for this type of cable is 40 Amp at 130 C up to 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, which is still above the rating of the protective fuse Based on the discussion with

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the licensee's staff and review of the licensee's analysis, the inspector concluded that the 35 Amp fuses are adequate to protect the 12 AWG conductor cables. This item is resolve .0 Controls of Combustibles and Ignition Sources The licensee has in place procedures that control the introduction of combustibles and flammables in safety-related areas. The licensee also has procedures that control the use of ignition sources such as from welding, cutting or grinding operation The plant inspection by the inspector did not identify any unacceptable condition .0 Equipment Maintenance Inspection and Tests The inspector reviewed several surveillance and testing procedures to determine whether the licensee has developed an adequate surveillance and maintenance program that assures the functionality / operability of the fire protection equipmen In addition, the inspector reviewed test records to verify compliance with applicable Technical Specification (TS) requirements. A violation was identified as follows:

The inspector reviewed the carbon dioxide (CO2) systems installed in the cable vault, switchgear and diesel fire pump day tank rooms to verify that each system is capable of performing its . required functio This review involved a system walk-down and a review of the test and surveillance procedures established to assure system operabilit The applicable licensing requirements also were reviewe Licensing Requirements The CO2 systems are required bv License Condition 3.F which states that an automatic CO2 system be provided in the cable spreading room (also referred to as the cable vault), the switchgear room and the diesel fire pump day tank room. The CO2 systems listed above are required to be operable by Technical Specification 3.1 The licensee in a letter to NRC dated January 31, 1977 from J. French to V. Stello committed to abide by the 1977 National Fire Protection Association Standard No. 12 (NFPA 12). This letter specifically states that the CO2 system in use at Vermont Yankee was designed t; meet the requirements of NFPA 12. NFPA 12 is the guide for the design and installation of CO2 systems. Section 1-7.3 of this standard specifies that the completed system shall be tested to determine that the system will function as intende The NRC has adopted the recommendations of NFPA 12. This is stipulated in Appendix A to Branch Technical Position 9.5-1.

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The CO2 system design was reviewed by the NRC and was discussed in 1 an NRC Safety Evaluation (SE), supporting License Amendment 43,-

dated January 13, 1978. The SE states that the design of the

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L C02 system is acceptable because it can provide 50% concentration-in the cable vault and maintain this concentration for ten minute The CO2 concentration and duration of concentration mentioned above are required for the effective extinguishment of deep soated fires that could occur if a fire started in areas such as the cable vault housing electrical equipmen .

Procedure and Records Review The inspector. reviewed the procedures which ensure that if a fire occurs in the areas protected by CO2 the proper alarms would activate, the ventilation dampers would close and the system would discharge. The licensee also has procedures verifying that the design quantity of CO2 is available at all time The review of these procedures did not identify any unacceptable condition The inspector reviewed the CO2 system acceptance test records to verify that the system can deliver the 50% of CO2 concentration for 10 minutes. The licensee presented to the inspector the test results of the full discharge test conducted in the switchgear room. The licensee could not locate the records for tests for the other areas. However, they committed to search for the test records for these areas. The inspector indicated to the licensee that if these tests were not performed, the system operability must be verified by a tes Regarding the switchgear room test, the licensee indicated that this test identified a condition where the concentration was not maintained at 50% for the entire 10 minutes in some locations of the switchgear room (high in the ceiling). On the advise of their vendor they made system modifications to improve the mixing of the C02 so that this problem could be eliminate The modifications included an adjustment to the discharge valve timing to slow CO2 injectio They also made provisions for the ventilation dampers to stay open for five minutes to address room over pressurization concerns and improve mixing of the CO2 in the roo The NRC on April 21, 1989 informed the licensee via telephone that since the CO2 test records for the cable vault and the diesel fire pump day tank rooms had not been found and s'nce inadequate evidence exists to verify that the system would function as intended, the system must be assumed inoperable and the compensatory measures specified in the Technical Specifications be placed in effect. As a result of that call the licensee committed to declare the system a a --.----,----------------------s- - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

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, inoperable and establish fire watches in accordance with the Technical Specifications. Since compensatory measures for an inoper--

able 002 system were not in effect when this deficiency was identified by the NRC, this was a violation of the Technical Specifications (Violation 89-04-01).

5.0 Quality Assurance (QA) Audit Review The inspector reviewed the QA audits of the Fire Protection Program. The audits were found to be thorough. Audit finding were adequately resolve No unacceptable conditions were identifie .0 Fire Protection Engineering and Modifications The inspector observed activities that affect the Fire Protection and noted the following: The fire annunciator panel f s located in the Security Room (SAS)

within the control room. The security monitoring panel that was recently installed was placed right up to the Fire Panel muking panel surveillance and testing difficul . The licensee did not complete the work of the fire stops mentioned in Section 2 of this repor The need for these fire stops was identified in February 1988, The licensee must now erect scaffolds and do the modification work in the Reactor Building when the plant is at powe . The NRC, during the Appendix R inspection, could not verify the adequacy of the communication system because using walkie-talkie radios in some plant areas could adversely effect the plant. Wal kie-tal kies would bc used for communications' to shutdown the plant from outside the Control Room if a fire forced Control Room evacuation. The licensee committed to determine plant conditions for which use of the communi-cation system is acceptabl The licensee reviewed the communications system and determined that the system would not perform adequately 'iti certain areas. The licensee corrected the problem by installing an antenna to enhance the radio signal. The corrective actions are adequate.

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The above items are examples where the engineering group did not perform l

a thorough job in the Fire Protection Are .0 Fire Brigade Training 7.1 Procedure Review The inspector reviewed the fire Brigade Training program to verify that this program includes: Requirements for announced and unannounced drills; I

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l 7 Requirement for fire brigade training and retraining.at prescribed frequencies; Requirements for at least one drill per year to be performed on a "back shift" for each brigade; Requirements for maintenance of training record No unacceptable conditions were identifie .2 Records Review The inspector reviewed training records of fire brigade members for calendar years 1988 and 1939 to ascertain that they had attended the-required quarterly training and participated in a quarterly drill, and received the annual hands-on fire extinguishment practic The inspector noted that all fire fighte s have received the required trainin However, the inspector observed that the licensee's procedures allow prospective fire brigade members to be on the fire brigade without the initial hands-on fire fighting practice. The concern is that personnel without firefighting experience can be a member of the brigade. The licensee explained that the initial " live" fire fighting training usually takes place during the warm weather .nonth The-inspector verified that the licensee makes every effort to quickly qualify new fire fighter This effort even includes sending some.of them to fire Academies as far away as Texas, but the procedures still allow membership in fire brigade without that training. At the time of the inspection, every member of the brigade had this trainin The licensee was told of the concern and they committed to review i This in an unresolved item. (89-04-02). The inspector also noted that the licensee's record-keeping in this area can be. improved. .The licensee's staff had a problem locating'the required records but ultimately the records were foun .0 Facility Tour The inspector examined fire protection water systems, including fire pumps, fire water piping and distribution systems, post indicator valves, hydrants and contents of hose houses. The inspector toured accessible vital and nonvital plant areas and examined fire detection and alarm systems, automatic and manual fised suppression systems, interior hose stations, fire barrier penetration seals, and fire doors. The inspector observed general plant housekeeping conditions and randomly checked tags of portable extinguishers for evidence of periodic inspections. No deterioration of equipment was noted. The inspection tags attached to extinguishers indicated that monthly inspections were performe _ _ _ - _ _ _ _ _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ - - _ _ -

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No unacceptable conditions were identified. However, the inspector  !

observed the following conaitions requiring resolution by the licensee:

Housekeeping / Hazard Control The inspector observed that the licensee installed large wooden

. structures outside but next to the Reactor Building. These structures although temporary have been there for more than a year. A fire in these structures could affect the plant. The structures have no smoking signs but the inspector observed cigarette butts on the

. floo The inspector also observed the licensee's practice of storing combustible trash next to the training building. The inspectors observed a large pile of wooden pallets and other combustible trash stored near the building. The inspector expressed the concern that a cigarette from passers-by could ignite these combustible Within the Control Room, the inspectors observed that spare breathing air bottles were stored on the floor. The inspector noted that these bottles represent a missile Sazard to people and equipmen Penetration Review The inspector while in the cable vault inspecting the integrity of the fire seals noted that in the Northwest corner of the room, a sound -of air leakage could be hear This sound was later determined to be air leaking from the Reactor Building to the Control Structure via an apparently degraded penetration seal. That determination was made by the licensee. A work request to repair the seal was issued while the inspectors were still on sit .0 Unresolved Items Unresolved items are matters for which more information is required in order to ascertain whether they are acceptable, violations, or deviation An unresolved item is discussed in Section .0 Exit Interview  ;

The inspector met with licensee management representatives (see Section 1.0 for attendees) at the conclusion of the inspection on March 23, 1989. The inspector summarized the scope and findings of the inspection at that time. The inspector also confirmed with the licensee that the report will not contain any proprietary informatio The licensee agreed that the inspection report may be placed in the Public 1 Document Room without prior licensee review for proprietary informatio (10 CFR 2.790).

At no time during this inspection, was written material provided to the licensee by the inspector.

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