IR 05000275/1982040
| ML20028F238 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/10/1983 |
| From: | Scown K, Zwetzig G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20028F225 | List: |
| References | |
| 50-275-82-40, 50-275-83-40, 50-323-82-18, 50-323-83-18, NUDOCS 8301310292 | |
| Download: ML20028F238 (11) | |
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U. S. NUCLEAR REGULATORY C0tNISSION
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REGION Y Report flo. 82-40. 82-18 Docket flo. 50-275, 50-323 License No. DPR-76, CPPR-69 Safeguards Group Licensee:
Pacific Gas and Electric Company P. O. Box 7442 San Francisco, California 94120 Facility Name:
Diablo Canyon Units 1 and 2 i
Inspection at:
Diablo Canyon Site and Corporate Offices Inspection conducted: December 6-10 (onsite) and December 16 (Corporate offices), 1982 Inspectors:
h/14v, /0,/F3 g ScQn, Ryactf Inspector (/
Da y 51'gned Date Signed
Approvedby:h M/l /O,/7[3
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At A
G.(B. (@etz$,(Chief (/
peSigned Engineering Programs Section Summary:
Inspection on December 6-16, 1982 (Report No. 50-275/82-40 and 50-323/82-18)
Areas Inspected: Routine, unannounced inspection of the licensee's Fire Protection /
Prevention Program and program implementation. The inspection involved 54 inspection hours by one inspector.
Results: As a result of this inspsction two apparent severity level V violations were identified (failure to test Emergency DC Lighting and Communications System as required by procedures, paragraph 2.m; and failure to comply with commitments regarding fire extinguisher servicing, paragraoh 2.j).
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8301310292 830112 f ADOCK 05000275 RV Fonn 219 (2)
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DETAILS
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Persons Contacted Onsite R. C. Thornberry, Plant Manager
- R. Patterson, Plant Superintendent i
- D. Rockwell, Assistant Construction Superintendent
- R. Etzler, Construction Superintendent
- D. Backens, Maintenance Supervisor
- R. Twiddy, Quality Assurance Supervisor
- W. Kaefer, Technical Assistant to Plant Manager-
- R. Kohout, Fire Protection Specialist
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- R. Luckett, Compliance Engineer
- J. Gisclon, Power Plant Engineer
- W. O'Hara, Radiation Protection Engineer
- J. Sexton, Operations Supervisor s
J. M. Raab, Senior Control Operator R. J. Kosmala, I&C Supervisor
R. Tucker, I&C Foreman W. Colton, Maintenance Foreman J. Pequignot, Training Specialist R. Foster, Senior Power Production Engineer Corporate Offices
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- R. L. Ashley, Bechtel
- C. O. Coffer, PG&E Licensing
- M. J. Jacobson, Bechtel Quality Assurance D. B. Hardie, Bechtel Engineering
- D. R. Lampert, PG&E NP0
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- C. Lewis, PG&E Insurance & Claims, Fire Protection
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- W. S. Garrett, PG&E Safety, Health & Claims Fire Protection Engineer
- G. Page, PG&E Engineer, Fire Protection
- Denotes those atterding the site exit meeting on December 10, 1982.
- Denotes those attending the corporate exit meeting on December 16, 1982.
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Fire Protection / Prevention Program and Program Implementati n a.
Procedure Review The inspector reviewed the following licensee procedures on a sampling basis:
i (1) Surveillance Test Procedures STP M-19A, Rev. 1, 3/10/81, "Halon Storage Tank Weight and
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Pressure Verification."
STP M-67, Rev. 8, 9/82, " Weekly Fire. Hose Reel Station Inspection".
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STP M-71, Rev. O, 6/23/78, " Fire Water System Flow Test".
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STP I-1C, Rev. 5, 3/25/82, " Routine Weekly Checks".
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STP P-13A, Rev. 4, 2/17/82, " Fire Pumps Performance Test".
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STP P-13B, Rev. 7, 8/11/80, " Routine Surveillance Test of
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Fire Pumps".
STP M-80, Rev. 1, 8/9/82, " Fire Hose Hydrostatic Test".
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STP M-39, Rev. 1, 4/19/79, " Routine Surveillance Test of
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Carbon Dioxide Fire System Operation".
STP M-69, Rev. 3, 10/82, " Monthly C0 Hose Reel, Deluge Valve and Fire Extinguisher Inspection". ' 2
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STP I-34, Rev. 3, 1/15/82, " Fire Detection System Functional
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Test".
STP M-19B, Rev. 1, 3/11/81, "Halon Fire Suppression System
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Functional Test".
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STP M-68, Rev. 3, 8/11/82, " Fire Hose Station Functional
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Test".
STP M-17, Rev.1, 5/31/79, " Functional Test of. Emergency
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DC Lighting System & Comunication System".
STP M-66, Rev. 3, 3/31/82', " Deluge System Nozzle Proof;. Test"..
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STP M-65, Rev. 4, I/6/82, "Delug'e System Functional. Test
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No. M-65".
STP M-64, Rev.1,1/12/80, " Deluge System Functional Test
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(Annual)".
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STP M-638, Rev. 1, 2/25/82, " Containment Fire Water System
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Flush".
STP'M-63A, Rev. 2, 10/1/82, " Fire Wate'r System Flush".
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STP M-72, Rev. O, 8/18/78, " Deluge Valve Tests for Feedwater
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Pump Turbines, Main Turbine Bearings and H Seal Oil System".
(2) Maintenance Procedures
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s MP M-29, Rev. 2, 6/2/78, " Fire Pump Disassembly, Repair:and
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Reassembly".
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MP M-97, Rev. O,'8/25/75, "Mainten'ance and Testing ~of Portable
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Fire Extinguishers".
MP M-18.3, Rev. 3, 6/18/82, " Fire Water Hose Reel; Station.
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Inspection ~and Hose Testing".
(3) Operating Procedures OP K-2A thru K-2A:IV, Rev. 1,'5/12/81, " Fire Water System"
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operating procedures.
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OP K-28 thru K-28:III, Rev. 2, 12/31/81, " Low Pressure'Cardox
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Fire Fighting System".
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OP K-2C thru K-2C:12, Rev. O,1/25/79, " Fire Fighting Tactics".
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OP K-20, Rev. O, 5/14/82, " Fire Protection of Safe Shutdown
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Equipment".
(4) Administrative Procedures AP C-113S1, Rev. 0, 4/19/82, " Project Fire System Impairment".
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AP B-51, Rev. 1, 7/9/82, " Industrial Safety, First Aid and
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Fire Protection Training".
(5) Nuclear Project Administrative Procedures NPAP A-13, Rev. O, 11/12/81, " Plant Organization for Fire
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Loss Prevention".
NPAP B-13, Rev. O, 7/29/81, " Qualification and Training Requirements
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of Personnel Specifically Concerned With Fire Loss Prevention".
NPAP C-10, Rev. 4, 9/1/81, " Housekeeping-General".
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NPAP C-13, Rev. 2, 11/12/81, " Fire Loss Prevention".
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NPAP C-113, Rev. O, 3/11/82, " Fire System Impairment".
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(6) Diablo Canyon Power Plant, " Fire Protection Plan," Rev. 4, November 10, 1982.
(7) Emergency Procedures EP M-6, Rev. 6, 11/9/81, "Non-Radiological Fire".
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EP R-6, Rev. 5, 11/10/81, " Radiological Fire".
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(8) Test Procedures 3.10, App.1, " Portable Fire Pump Operation".
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28.14, Rev.1, 6/4/79, " Battery Powered Emergency Lighting".
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18.9, Rev. 2,1/18/80, "Halon System Functional Test".
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(9) Project Instruction, PI-15, Rev. 0, 9/1/82, " Control of Cutting, Welding and Grinding".
(10) Diablo Canyon Power Plant Fire Protection ' raining Manual, EFA 310, Rev. O, " General Employee Fire Protection".
Except as noted in the following sections, the procedures appeared to be generally acceptable, b.
Administrative The fire protection program is the responsibility of the Plant Manager.
Responsibility for program implementation is delegated to the Technical Assistant to the Plant Manager. Responsibility for the day-to-day coordination of the Fire Protection Plan is further delegated, as a collateral duty, to a Fire Marshal.
The licensee uses a corporate committee to review modifications and system design changes. The connittee relies on the design rngineers to identify fire protection concerns, relating to the modir1 cations
.and system changes, and bring these concerns to the committee for review.
The ~ committee's review is usually performed by examining drawings and documentation at the General Office. No individual at the site, with a fire protection background, is assigned to review design changes and plant modifications for adequate inclusion of fire protection requirements.
The licensee is in the process of evaluating the need to have design changes reviewed at the site for fire protection adequacy. This area will be further examined during a future inspection (82-40-01).
No items of nor.:cmpliance or deviations were identified.
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Fire Brigade The staff for each shift includes a fire brigade consisting of five personnel: one Fire Brigade Leader (senior control operator) and four crew members (three auxiliary operators'and a chemical and radiation protection technician). The fire brigade is supported during normal work hours by two maintenance fire brigades, each consisting of an Assistant Fire Brigade Leader and six crew members. These crews are composed of personnel from various departments to provide a balance of equipment knowledge.
Additional fire fighting assistance is available from the local California Division of Forestry (CDF) fire station (s) in the area. Generally, CDF will respond with a chief. officer and a pumper, if available.
The response time is variable due to the season, traffic, availability of personnel, weather conditions, etc.
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The inspector reviewed non radiological and radiological fire procedures and the fire brigade organization. The procedures appear, satisfactory and the fire brigade appears to meet regulatory requirements.
No items of noncompliance or deviations were identified, d.
Fire Brigade Trainin'g The inspector reviewed the on-site and off-site fire brigade training-programs and records. The on-site training program is partially developed and implemented. The established courses appear to be satisfactory; however, there are some impcrtant training courses that still need to be completed (i.e., Fire Brigade Leader; Tactics and Strategy; Pre-planning; Fire Watch Trainir.g; Cutting, Welding and Grinding Permit System; and Suppression Systems Operation). The licensee is in the
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process of completing and implementing some of these topics.
Fire Brigade training records indicate that the required fire brigade training is being performed.
The inspector examined the off-site training program and records for local fire department members. The off-site training program appears to be adequate for radiation and contamination. Based upon a review of off-site personnel training records, it appears that not all of these personnel have had site familiarization training. The licensee indicated that training of off-site personnel was in process and particular attention would be given to site familiarization.
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The onsite training courses, listed above, and the topic of Site Familiarization training for off-site personnel will be examined during a future inspection (82-40-02 and 82-40-03).
No items of noncompliance or deviations were identified.
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Cutting, Welding and Grig ing Permitj yyn em_
The inspector reviewed applicable procedures used to authorize cutting, welding and grinding by the licensee's Nuclear Plant and General Construction departments. Nuclear Plant Administrative Procedure No. NPAP C-13, Rev. 2, 11/12/81, appears to be in compliance with NFPA 518, " Cutting and Welding Processes".
However, General Construction procedure No.
P I-15 does not appear to require an inspection of the area prior to issuing welding permits, as required by NFPA-518, Article 42. The inspector observed that the General Construction permits appear to be issued for long periods of time (up to 1 year) without being formally reviewed on a routine basis or when conditions change.
The two organizations issuing such permits (General Construction and Nuclear Plant Operations) do not appear to coordinate activities with each other. This lack of coordination could easily result in a fire hazard; e.g., if one department was working with solvents in a given area while the other department was doing cutting or welding in an adjacent area. This was brought to the attention of the licensee and corrective measures were taken by placing fire watches in high fire hazard areas. The licensee has committed to revising the Cutting, Welding and Grinding Permit System for General Construction activities at the plant. This area will be examined during a future inspection (82-40-04).
No items of noncompliance or deviations were identified.
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Firewatch Program The inspector examined the Firewatch Program ' implemented at the site.
The firewatches are required to neet standards as defined in NPAP C-13,
" Fire Loss Prevention". However, procedure NPAP B-13, " Qualification and Training Requirements of Personnel Specifically Concerned With Fire Loss Prevention," does not appear to be consistent with the requirements of NPAP C-13.
The inspector brought this to the attention of the licensee. The licensee has since developed a firewatch training program on video tape and is using it to train firewatches.' This area will be examined during a future inspection (82-40-05).
No items of noncompliance or deviations were identified.
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Fire Barrier Penetrations and Fire Doors The inspector examined fire door installation relative to the licensee commitments contained in the staff's Safety Evaluation Report (SER)
and the licensee's " Fire Protection Review" document. The fire doors
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appear to have been installed in accordance with the commitments of Supplement No. 8 to the SER and the Fire Protection Review, Section 6.0, with one exception: The door to the SSPS room is required to be an "A" rated fire door; however the currently installed door is equivalent to a "B" rating. This was brought to the licensee's attention by the inspector and a change order (change 23, drawing no. 59634, G.C.) was issued to upgrade the door. The licensee stated that the new door installation would be completed prior to fuel load. This will be verified during a future inspection (82-40-06).
Fire Barrier penetrations were not examined during this inspection but will be examined during a future inspection (82-40-07).
No items of noncompliance or deviations were identified, h.
Emergency Lighting The inspector examined the installed emergency lighting system for compliance with requirements contained in Supplement No. 13 to the SER. The system appeared to have been properly installed and functionally tested.
No items of noncompliance or deviations were identified.
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Fire Protection Systems The inspector reviewed the installation of the following systems:
automatic sprinkler (wet, deluge, pre-action), halon, cardox, smoke and heat detection, water supply, and alarm annunciation. Selected systems were surveyed to verify the following:
proper installation of identification tags, valves sealed or locked in the proper positon, gauge operability, required system pressures, and fire pump tests were adequately performed.
Except as noted below, all fire protection systems examined appeared to be installed and operating in accordance with requirements and procedures.
The exception relates to the halon system initiator, for which the licensee could not produce any certification documentation. The licensee is in the process of replacing the initiator with one that is certified and stated that this will be completed prior'to fuel load. This item will be examined during a future inspection (82-40-08).
No items of noncompliance or deviations were identified.
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Fire Extinguisher Program The inspector reviewed the fire extinguisher program for compliance with NFPA Part 10, " Portable Fire Extinguisher," as committed to in Amendment 51 (Fire Protection Review). Two areas of concern were identifie r
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(1) The licensee did not appear to.have a system to evaluate fire extinguisher distribution in areas where building modifications have occurred (e.g.,'after fire walls were installed in the 4.16'
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KV switchgear area). Although no specific deficiencies were identified,:
the inspector considers a re-evaluation' of fire extinguisher distribution
should be performed periodically in view of the building modifications l
which have occurred in safety related areas and the significant
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(2) The inspector observed licensee personnel removing extinguishers l
for servicing from an auxiliary building stairwell and-the lower
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level of containment. Replacement extinguishers of equivalent
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capacity were not being provided.
Instead, a tag was being placed t
on the hanger indicating that the extinguisher was out for service.
t NFPA Part 10, Chapter 4-4.1.2 states, " Extinguishers out'of service for maintenance or recharge shall be replaced by spare extinguishers
having the same classification and at least equal rating." -This
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i No other items of noncompliance or deviations were identified,
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Fire Fighting Equipment
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The inspector examined fire fighting equipment and determined that
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an adequate supply of protective gear.was provided..The l_icensee has
added several items of fire fighting material and equipment,-such as i
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Aqueous Film Forming Foam (AFFF) and smoke ejectors. The licensee-has a total of 600 feet of 2h inch hose onsite and. spare nozzles,-fittings
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and couplings were-observed by the inspector.
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No items of noncompliance or deviations" were identified..
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Pre-Fire Plans
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The inspector reviewed the pre-fire palns,.provided in the Operating l
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Procedure series K-2C through K-2C:12. Procedure K-2C (Fire Fighting i
Tactics) is general information' and references other: fire fighting i
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Procedures K-2C:1 through 12. are documents containing information
needed for fighting fires in specific areas. These' twelve procedures (pre-fire plans) are provided for some vital and high hazard areas l
but do not cover all vital areas.
Such pre-planning enables the licensee
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fire in a specific area.
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(82-40-10).
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No items of noncompliance or deviations were identified.
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Maintenance, Test and Inspection Records'
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The inspector examined maintenance, test, and inspection records required by technical specifications and licensee procedures.
Except for the following, the records appear to be complete and current.
The inspector found that the licensee has not been testing the Emergency DC Lighting System every six months, as required by Surveillance Test Procedure M-17. The latest test records appear'to be those of Test Procedure No. 28.14, Addendum 1, Rev. 1, " Battery Powered Emergency
Lighting" and are dated 6/18/79. This failure to test this system in accordance with a required plant procedure is an item of apparent noncompliance (82-40-11).
Since there is no fuel in the reactor vessel and there has been no previous reactor operations a Severity Level V has been assigned to this apparent violation.
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Housekeeping The inspector reviewed housekeeping procedures and the cleanliness conditions in Unit 1.
Housekeeping appeared to be satist.~ tory.
No items of noncompliance or deviations were identified.
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Procedures The inspector examined licensee procedures related to the Fire Protection Program.
In general, the procedures appear to be satisfactory. However, the following need minor corrections or revision:
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NPAP A-13, states "During off-shift periods an assistant Fire Brigade is available if needed."
No information is included as to brigade location or the' notifications
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OP K-28:1, " Low Pressure Cardox System - Make Available for Service"-
This procedure does not appear to address compensatory measures to ba taken when the system tank is empty.
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NPAP B-13, Qualification and Training;Regtiirements of Personnel Specifically Concerned with Fire Loss Prevention".
This procedure needs to be revised to be consistent with NPAP C-13 and should include operation of fire protection systems, i.e., initiation of automatic sprinklers, deluge, and pre-action systems.
The licensee has committed to making appropriate procedure changes.
This area will be examined during a future inspection (82-40-13).
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Audits The inspector reviewed audits performed by the licensee's Quality Assurance personnel and Nuclear Mutual Limited (NML) Insurance personnel. The licensee's audits appear to be in accordance with requirements.
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NML audits appear to be on a regular basis 'and in accordance with a'
defined program acceptable to NML.
No items of noncompliance or deviations were identified.
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Independent Inspection The inspector examined the Unit 1 Residual. Heat Removal (RHR) Heat Exchanger 1-2 room and determined that it has a large (36" x 42") ventilation duct with no fire _ barrier. The Fire Protection Review, after-discussing the rooms where the RHR pumps and heat exchangers are located, states that, "It is bounded on all sides by ventilation barriers."
It was not clear whether a fire damper is required in',this duct. The licensee is currently conducting an evaluation of the need for a damper in that duct. The licensee agreed to evaluate and identify any necessary corrective action by February 8, 1983.
This item will be examined further during a future inspection (82-40-15).
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Exit Meetings The inspector met with the licensee representatives (denoted in paragraph 1)
onsite on December 10, 1982 and at the corporate offices on December 16,
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1982. The scope of the inspection and the findings, as detailed in this report, were discussed. The licensee's management committed to make ~ improvements in the Fire Protection Program as described in paragraphs 2.b, e, f, g, i, 1, o and q.
A representative of the licensee's management was contacted by telephone on December 20, 1982 and informed of the apparent violations detailed in paragraphs 2.j and 2.m.