IR 05000277/1993009
| ML20044E220 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/12/1993 |
| From: | Blumberg N, Finkel A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20044E215 | List: |
| References | |
| 50-277-93-09, 50-277-93-9, 50-278-93-09, 50-278-93-9, NUDOCS 9305240077 | |
| Download: ML20044E220 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REPORT NOS.
50-277/93-09
50-278/93-09 l
i DOCKET NOS.
50-277; 50-278
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LICENSE NOS.
LICENSEi Philadelphia Electric Company l
Nuclear Group Headquarters Correspondence Control Desk
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P. O. Box 195
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Wayne, Pennsylvania 19087-0195 i
FACILITY NAME:
Peach Bottom Units Nos. 2 and 3
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INSPECTION AT:
Delta, Pennsylvania i
INSPECTION CONDUCTED:
April 26, 28, 30, and May 3,4, and 5,1993
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INSPECTOR:
A. Finkel, Senior Reactor Engineer Dfite /
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Performance Programs Section Operations Branch, DRS
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APPROVED BY:
V Norman J.%lumberg, Chief /
Date Performance Programs Section j
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Operations Branch, DRS Insocction Summary: Insoection on April 26. 27. 28. 30. and May 3. 4. and 5th.1993 l
Gnspection Reoort Nos. 50-277/93-09 and 50-278/93-09)
l Areas Insoccted: Announced safety inspection of the Fire Protection Program and its implementation in the areas of Administrative Controls, Surveillances, Combustible Controls, Testing, Audits, Firewatches and Penetration Inspection Programs.
9305240077 930524 PDR ADOCK 05000277 G
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Results: No safety issues were identified with the fire protection equipment, system, or program. The fire detection instrumentation, control of combustibles, fire brigade training and drills and fire audits are being conducted as described in the site fire protection plan.
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The fire protection system for the site is in an operational mode with firewatch personnel
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assigned to watch the identified nonconforming fire doors and the " Detail 27-type" fire barrier penetration seals. As a result of NRC Information Notice No. 88-56, " Potential Problems with Silicone Foam Fire Barrier Penetration Seals," the licensee inspected their series " Detail 27" silicone foam penetrations. Their penetrations did have voids in the foam; l
and, based on their sampling program requirements, a 100% inspection of the 78 installed
I series " Detail 27" penetrations was required. When the first fire barrier penetration was determined to have voids in the silicone foam, the licensee placed all the series " Detail 27" l
penetrations into their firewatch program. See paragraph 5.0 of the report for information i
on the licensee's identification and repair program.
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The licensee has developed a nondestructive examination (NDE) program on their fire system
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schedule 40 piping. The NDE program on the fire piping system is a self-initiative pmaram the licensee developed based on the information described in NRC Generic Letter i
90-05, " Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1, 2, and 3 Piping." This program is just starting; however, the inspector's review of the program
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description and the first phase piping test results indicates that good engineering went into the
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program plan. See paragraph 10.0 of the report for details of their NDE program.
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DETAIIE 1.0 PERSONS CONTACTED Attachment 1 provides a listing of persons contacted during the inspection.
2.0 FIRE PROTECTION PROGRAM (64704)'
2.1 Introduction An inspection was performed to evaluate the adequacy of the licensee's fire protection program and associated implementing procedures. The inspection included verification of procedure implementation, technical adeqt:acy of procedures and programs, inspection of plant fire facilities, fire brigade training status, firewatch personnel qualifications and program requirements, manpower assignments and review oflicensees audit program.
j Surveillance and routine testing, administrative and other procedures related to the implementation of the fire program were reviewed by the NRC inspector to measure the j
effectiveness of the fire protection program.
2.2 Plant Tour The inspector toured accessible vital and nonvital areas of the site and visually inspected the
fire protection water systems, fire pumps, fire water piping and distribution systems, post-indicator valves, yard hydrants, contents of fire protection equipment storage cabinets and the
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condition of the fire brigade equipment. The tour also included the inspection of the various types of fire detectors, alarm panels, positions of automatic and manual fixed suppression
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instruments, interior plant fire hose stations, fire barrier penetrations, fire doors and discussions with firewatch personnel encountered during tour. The inspector noted that the fire protection equipment was in an operational status and where there was a system or fire barrier penetration identified with a deficiency tag, a firewatch was established. Fire equipment tank gauges indicated correct levels as described in their procedures and battery powered lights tested during the tour were in working order. During the plant tour the inspector noted that some fire doors, that did not affect the safe operation of the site, did not close or latch automatically. These fire doors have been identified as nonconforming items by the licensee and are scheduled to be replaced or repaired. However, until the deficient fire doors are corrected, they are part of the firewatch program and are listed on the daily rounds chart to be inspected on an hourly inspection cycle.
'The parenthetical notation following the paragraph title denotes the NRC inspection procedure that was used by the inspector in conducting this inspectio !
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3.0 DOCUMENTS AND PROGRAMS REVIEWED The fire protection program documents and programs listed in Attachment 2 of this repon were used by the inspector in performing his inspection of the fire program at this site. The licensee's fire program policies, documents, and self-initiative program (discussed in paragraph 10) reviewed by the inspector appeared to be technically sound and properly implemented. No violations were identified.
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4.0 FIRE DETECTION INSTRUMENTATION SYSTEM The fire detection instrumentation for this site consists of either smoke or heat detectors.
The plant locations and types of detector are listed in Technical Specification Table 3.14.C.I.
Using this Table, an inspection of the fire detectors in the Diesel Rooms, 4KV Emergency Auxiliary Switchgear and Battery Room and High Pressure Cooling Injection Area was performed by the inspector to verify: (1) that the installed equipment defined in site fire system drawings complied with the latest amendment of the Technical Specification; and (2)
that the fire detectors complied with the surveillance procedure test requirements of ST-1-037-249-2 and ST-I-037-223-2. The inspector verified that the specified detector types listed in TS Table 3.14.C.1 were installed in the listed location and that they were tested semiannually as required by TS. The inspector also verified that detector test panels and fire detectors were operational by reviewing the latest system test data and inspecting the present mode positions of the equipment.
5.0 FIRE BARRIER PENETRATION SEALS An inspection of the licensee's fire barrier penetration seal installation and surveillance program was performed by the inspector. The inspector established that the requirements of Technical Specification Section 4.14.D, " Visual Inspection," of the fire barrier penetration seals were performed by the licensee. While the licensee was performing a modification, during 1992, on fire barrier penetration No. TBC 150-302-4017, a " Detail 27" type penetration (2'6"x 3'4"x9"), a 4" x 4" x 9" deep void was found within the silicone foam barrier seal. The seal was installed per " Detail 27," which is a fire barrier penetra: ion design that consists of 9" of silicone foam with a 1" thick ceramic fiber damming board on each side of the penetration. The nonconforming penetration was documented in NCR PB-92-00919, on December 1,1992. An Engineering repon No. A0043061, that analyzed the penetration seals indicated that the " Detail 27-type" fire barrier penetration design could have the same type of problems described in NRC Information Notice 88-56, " Potential Problems l
With Silicone foam Fire Barrier Penetration Seals." Based on Engineering direction in l
report No. A0043061, an inspection program of the " Detail 27-type" penetration seals was l
staned. The preliminary inspection results indicated that their " Detail 27-type" penetrations did have voids in the silicone foam. Based on the inspection sampling program established in repon No. A0043061, the penetrations were declared inoperable and put under the firewatch program. There are 78 total " Detail 27-type" penetrations for both Units 2 and 3 that will be inspected and repaired as required. The boroscope inspection technique
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developed by the licensee to evaluate voids in the penetration seals was completed and
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April 1993. The licensee's safety analysis for " Detail 27-type" penetrations indicates that i
plant safety and safe shutdown capability were not adversely affected, based on the following
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conclusions:
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Both sides of the void were covered with a 1" thick ceramic fiber "S" board, l
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which prevents the passage of fire and hot gases through the seal; j
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There were no combustibles passing through the silicone seal voids with the 1"
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ceramic "S" boards in place that could propagate fire;
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Early warning detectors and automatic fire suppression systems are installed in
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fire areas reducing the fire severity; and, j
i The " Detail 27-type" fire barrier penetrations are included in the site hourly firewatch
!j program; and, based on the reasons described above, there are no safety concerns with these
fire barrier penetrations at this time. The licensee's fire barrier penetration seal repair j
l program, which is described in NCR 92-00919 and report no. A0043061, appears to be an j
adequate approach for identifying and correcting nonconforming penetrations.
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NRC Information Notice No. 88-04, " Inadequate Qualification and Documentation of Fire
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Barrier Penetration Seals." The supporting qualification reports for the site fire barrier i
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penetration seals are stored in the licensee's documentation files.
6.0 CONTROL OF COMBUSTIBLES I
i The program for the control of combustibles is described in licensee's procedure A-12.2,
" Control of Combustibles " January 23,1991. During the site tour, the inspector verified l
that flammable and combustible liquids and materials were stored in approved storage cabinets and in assigned site areas. The inspector also verified that flammable gases such as hydrogen, acetylene and oxygen containers were stored, marked, and controlled as described
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in paragraph 7.6, " Flammable Gas Control" of procedure A-12.2. Inspection of various trash containers, located throughout the site, indicated that they were being emptied on a shift bases as required by paragraph 5.0, " Responsibility and Authority," of procedure A-12.2 Transient combustible materials in the plant were stored and approved as required by paragraph 4.7, " Transient Combustible Materials," of procedure A-12.2. The inspector determined that the control of combustibles for the site was being performed in accordance j
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with the requirements described in procedure A-12.2 and that no safety concerns were
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identified in this area.
7.0 FIRE BR.IGADE TRAINING AND DRILIS Fire Department training procedures and attendance records for brigade members were i
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l reviewed by the inspector. The records were complete and maintained in an up-to-date
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status. The inspector verified that the fire brigade members listed on the May 4th,1993,
" Fire Brigade Qualification Status Listing," have completed their required fire training i
courses including their hands-on training program at the fire school. Discussions with fire brigade members during the site inspection indicated that the fire brigade members are
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cognizant of their responsibilities and that the training they are provided is beneficial in
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maintaining their awareness of current developments in fire protection and fire fighting l
techniques. There are 59 qualified members and 38 qualified leaders listed on the Fire j
Brigade Qualification Status Listing. This is an adequate number of qualified fire brigade i
i personnel to support the licensee's six shift operation.
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8.0 AUDITS OF FIRE PROGRAM
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The inspector reviewed the annual and triennial audit reports performed on the fire protection
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program plan, fire documentation and the operation of the fire protection system equipment were adequate. The yearly audit (No A0680030) conducted from January 27,1993, through
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February 24,1993, did not have any significant safety findings. The audit scope reviewed l
the elements of: (1) Administration and Organization, (2) Testing of the Fire Protection
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System and Equipment, (3) Maintenance of Fire Protection Equipment, (4) Fire Brigade, and (5) Corrective Action. The Triennial Audit (No. A0167292 - November 39 through December 18,1992) scope reviewed the elements of: (1) Administrative Controls, (2) Fire i
Detection and Suppression Systems, (3) Manual Suppression Equipment, (4) Emergency
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Lighting, (5) Fire Brigade, (6) Surveillance and Routine Testing, (7) Alternative or i
Dedicated Shutdown Capabilities, (8) Corrective Actions, and (9) Conformance to INPO Good Practices. Three corrective action requests (CARS) were identified during this audit; l
however, they had no safety significance associated with the fire protection system. The inspector verified that the three CAR's have been closed by the assigned organizations and
that the licensee's actions were performed in a timely manner.
9.0 FIRE EQUIPMENT TESTING
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The mspector reviewed the test results of the Diesel Driven Fire Pump Operability Test (ST-
0-37D-370-2) that is performed once/31 days, and the Diesel Driven Fire Pump Flow Rate Test (ST-F-37D-340-2) that is performed once/18 months. The monthly test results from i
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January 1993 through April 1993 (ST-0-37D-370-2) indicated that the equipment met the test i
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procedure acceptance requirements. The results of the 18 month tests (ST-F-37D-340-2) also l
indicate that the " Flow Rates" of the Diesel Fire Pump and fire systems have not degraded.
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10.0 FIRE PROTECTION NON DESTRUCTIVE EXAMINATION (NDE)
PROGRAM The Peach Bottom Fire Protection NDE program, which is a licensee self-iriitiative program, was developed to determine the structural integrity of the fire protection piping. In
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establishing this program, the licensee is using the evaluation criteria described in NRC
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Code Class 1,2, and 3 Piping." The licensee has identified 28 piping locations where they have taken piping wall readings using Ultrasonic NDE techniques. The NDE readings are maintained by the fire protection engineering organization. The 28 piping locations will be tested every year using the NDE program developed to obtain the base line data. The objective of this program is to be able to determine the corrosion mechanism and the rate of piping wall thinning. The program has identified six locations where the wall thickness was less than the calculated minimum; however, none of the readings caused the fire protection piping to be inoperable. NDE testing on these six locations will be performed to determine the piping corrosion mte. In addition to the six minimum wall locations, seven locations were identified to be within 0.020 inches of minimum wall thickness and were listed as
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" marginally acceptable." These seven locations have been evaluated to ensure that the predicted wall thickness, after one year of operation, will be above the minimum wall thickness. The inspectors review of the phase one NDE piping data indicates that, even i
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though some readings are below the engineering established value, the readings are within the safety calculations for schedule 40 pipe. Based on the data results of the licensee's NDE program, the inspector determined that this system presents no safety concern at this time.
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11.0 EXIT MEETING Licensee management was informed of the scope and purpose of the inspection at an entrance meeting conducted on April 26,1993.
The findings of the inspection were discussed periodically with licensee representatives during the course of the inspection. An exit was conducted on May 5,1993, at which time the findings of the inspection were presented.
Attachments:
1. Persons Contacted i
2. Documentation Reviewed l
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l A*ITACHMENT 1 Persons Contacted l
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Philadelphia Electric Company
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- H. Abendroth, Atlantic Electric Site Representative
- D. Alexander, Nuclear Quality Assurance
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- T. Furlong, Industrial Risk Management i
- R. Knieriem, Delmarva Site Representative l
- D. Myers, Site Support Services
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- P. Ott, Site Representative
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- R. Smith, Regulatory
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United States Nuclear Regulatory Commissign l
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- F. Bonnett, Resident Inspector
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- Denotes those present at the Exit Meeting on May 5th,1993.
The inspector also held discussions with managers, supervisors and other licensee employees j
during the course of the inspection, including operations technical and administrative i
personnel.
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ATI'ACHMENT 2 l
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Fire Protection Documentation Reviewed l
Technical Specification Section 3.14, Fire Protection PBAPS Fire Protection Plan l
Audit Reports
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PBAPS Annual Fire Protection Report No. A0005497 l
Triennial Fire Protection Audit Report No. A0167292
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Fire Protection Procedures and Drawines
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l ST-F-37D-340-2, " Diesel Driven Fire Pump Flow Rate Test"
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ST-O-37D-370-2, " Diesel Driven Fire Pump Operability Test" i
ST-I-037-223-2, "4KV Emergency Auxiliary Switchgear and Battery Room Smoke Detectors
Functional Test"
ST-1-037-249-2, "HPCI Room Heat Detectors Functional Test"
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ST-F-037-311-2/3, " Detailed Visual Inspection of Penetration Seals and Difficult To View Fire Barriers" f
A-12.2, " Control of Combustibles"
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Engineering Work Request No. A0043%1
Non-Conforming Report (NCR) No.92-00919
Fire Brigade Qualification Status List, May 4,1993 PBAPS Fire Protection NDE Program Report, March 26,1993 Fire Barrier Penetration Drawing No. 6280-M-3010-0 (Detail 8, 27 and FB-5)
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Attachment 2
NRC Information Notices IN No. 88-04, " Inadequate Qualification and Documentation of Fire Barrier Penetration Seals" IN No. 88-56, " Potential Problems with Silicone Foam Fire Barrier Penetration Seals" P
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