IR 05000286/1982009

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IE Insp Rept 50-286/82-09 on 820601-04.Noncompliance Noted: Failure to Install Sprinkler Head Specified Per Natl Fire Protection Assoc Code 15,1977
ML20055B646
Person / Time
Site: Indian Point 
Issue date: 07/01/1982
From: Beckman D, Paolino R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20055B635 List:
References
50-286-82-09, 50-286-82-9, NUDOCS 8207220582
Download: ML20055B646 (8)


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U. S. NUCLEAR REGULATORY COMMISSION Region I Report No. SC-286/82-09 Docket No. 50-286 License No. DPR-64 Priority Category C

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Licensee:

Power Authority of the State of New York 10 Columbus Circle New York, New York 10019 Facility Name:

Indian Point Nuclear Generating Station, Unit 3 Inspection At:

Buchanan, New York Inspection Conducted:

June 1-4, 1982 Inspectors:

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R'.Jgaolino,ReactorEngineeringInspector dafe signed N

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n date signed Approved By:

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D. Y."3e'cKinan, Chief,71 ant Systems Section daile tigned.

DETP Inspection Summary:

Inspection on June 1-4, 1982 (Inspection Report No. 50-286/82-09)

Areas Inspected:

Routine, unannounced inspection by region based inspector (s)

of the fire protection / prevention program including records review and observation of related work activity pertaining to Appendix A of the Branch Technical Position (BTP) 9.5-1; Safety Evaluation Report (SER) commitments and 10 CFR 50, Appendix R.

The inspection involved 32 inspection hours onsite and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> offsite by one region based inspector.

Results: Of the three areas inspected there was one deviation from the SER commitments (failure to install the specified sprinkler head, paragraph 2) and one violation of 10CFR50.48 implementation of Appendix R, except as modified by previously issued NRC Staff SER (brigade members not participating in quarterly drills, paragraph 5).

8207220582 820702 PDR ADOCK 05000286

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DETAILS 1.

Persons Contacted Power Authority of the State of New York L. Anterino, Performance / Reliability Supervisor

  • J. Brons, Resident Manager J. Cirilli, QA Supervisor
  • J. Dube, Safety and Fire Protection Superintendent
  • J.

Foley, Director of Safety and Fire Protection

  • D. Halama, QA Superintendent
  • W. Hamlin, Assistant to Resident Manager
  • W. Josiger, Superintendent of Power T. Klein, Senior Nuclear Operations Maintenance Engineer
  • S. Munoz, Technical Services Superintendent
  • S. Smith, Plant Engineer
  • S. Van Buren, Fire Protection Supervisor U. S. Nuclear Regulatory Commission
  • T. Kenny, Resident Inspector
  • denotes personnel present at exit meeting of June 4,1982.

2.

Facility Tour The inspector toured specific accessible vital and non-vital areas in the Indian Point Unit 3 facility to examine fire detection and alarm systems, automatic and manual fixed suppression systems, interior hose stations, fire barrier penetration seals, and fire doors. The inspector observed general housekeeping conditions and randomly checked tags /date stamps on portable extinguishers and hose stations for evidence of periodic inspections.

No deterioration of equipment was noted.

During this inspection, the inspector noted that the water suppression system in the cable spreading room and the electrical cable tunnel uses closed head, preaction type sprinkler heads (Grinnel type EA-1). The system is a dry pipe design requiring valve actuation to release water to the sprinkler heads. This actuation is provided by a " hot wire" routed through the top row of cable trays. Water is released from the sprinkler head when heat causes the liquid filled glass bulb separator to fracture.

In response to an NRC letter of May 21, 1979 (PASNY Letter IPN-80-78, August 15,1980), the licensee committed to install horizontal side-wall spray nozzles per National Fire Protection Association Code No. 15, 1977, consistent with NRC staff position (2)b of Attachment 2 to the above NRC letter. This information was used as part of the basis for the NRC Safety Evaluation Report issued with Amendment 24 to License DPR-6.

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The installed closed head, preaction sprinkler head (EA-1) prc eides a 65 degree radial discharge pattern,and is normally mounted in an overhead position. However, for this installation, these sprinkler heads are mounted between the trays, midway across the width of the tray with the radial discharge pattern perpendicular to the tray length. The effective coverage for the radial spray discharge pattern is reduced due to tray spacing (6 inches) which limits the spray discharge pattern above and below the sprinkler head.

The proposed closed head, horizontal side-wall mounted sprinkler head is designed for use in such areas where a structure or other conditions make the standard installation impractical. The horizontal side-wall mounted sprinkler head is designed to provide a shaped spray pattern to cover the obstructed areas.

At the close of this inspection, the licensee was initiating an evaluation of this installation. The installation of radial discharge sprinkler heads constitutes a Deviation from the licensee's commitments to NRC in Letter IPN-80-78 above and may provide insufficient fire _ suppression.

The licensee was unable to technically justify use of these units during the inspection and during subsequent telephone calls with the inspector and NRC:RI management.

(82-09-01)

3.

Status of Previously Identified Open Items (Open) Deviation 81-09-01 pertaining to the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire damper in the ventilation opening connecting the cable tunnel with the transformer yard. This licensee commitment was documented in Section 3.1.2(a) of the Safety Evaluation Report (SER) issued with Amendment 24 to License DPR-64.

Necessary materials are onsite and the required paperwork for the installation has been processed. Completion is scheduled for this outage. This item remains open pending licensee completion and followup verification by the NRC.

(Closed) Unresolved Item 81-09-02 pertaining to the calibration of CO2 storage tank gages for tank level and tank pressure instruments. The inspector verified completion of this task. This item is closed.

(Closed Unresolved Item 81-09-03) pertaining to the revision of Procedure No. SOP-FP-3 regarding protection of control room personnel. The inspector verified revision of the procedure incorporating protective steps to be taken by Control Room personnel.

In addition, Control Room habitability is being addressed in the Control Room Habitability Report of March 23, 1981 per NUREG-0737.

The inspector had no further questions on this item.

This item is closed.

(Open) Deviation 81-09-04 pertaining to failure to complete testing outlined in NFPA-20 for the Centrifugal Fire Pump Installation as required by Section 8.58 of the Fire Protection Program.

This test is scheduled for completion during present outage.

This item remains open pending NRC review of the completed test.

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4.

Fire Protection / Prevention Program The inspector reviewed the following documents to determine whether the licensee has developed adequate procedures consistent with the Fire Hazard Analysis, FSAR, and Technical Specifications (TS) for the Fire Protection / Prevention Quality Assurance. Program:

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QA-P-2.1, Revision 2, Quality Assurance Program.

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Attachment 2.1-4 to QAP-2.1, incorporates fire protection / prevention program into QA program.

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FP-8, Revision 0, Control of Ignition Sources.

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FP-9, Revision 0, Control of Combustibles.

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FP-12, Revision 0, Cutting and Welding.

FP-3, Revision 2, Fire Protection.

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FP-5, Revision 2, Fire Emergency.

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TS 3.14, Fire Protection and Detection Systems Operability.

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TS 3.14-1, Fire Detection Instruments.

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TS 4.12, Fire Protection and Detection System Surveillance Requirements.

The inspector verified that the above procedures for the fire protection /

prevention program and control of combustibles and fire hazards include:

a.

Personnel designated to implement'the fire protection / prevention program at the site.

i b.

Special authorization for use of combustibles, flammable or explosive hazardous materials in safety related areas.

c.

Prohibition on the storage of combustibles, flammable or explosive hazardous material in safety related areas.

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d.

Requirements for the removal of all wastes, debris, rags, oil spills or other combustible materials resulting from a work activity following

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completion of the activity or at the end of each work shift, whichever is sooner.

e.

Requirements that all wood used in safety related areas is-flame retardant treated.

f.

Requirements for periodic inspection for accumulation of combustibles.

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g.

Requirements that housekeeping is properly maintained in areas containing safety related equipment and components.

h.

Requirements that transient combustibles are restricted and controlled in safety related areas.

i.

Work authorization, construction permit or similiar arrangement is provided for review and approval of modification, construction and maintenance activities which could adversely effect the safety of the facility.

J.

Fire fighting strategies for all safety related areas of the plant.

No items of noncompliance were identified.

5.

Fire Brigade Training / Qualification The inspector reviewed the following procedures to determine licensee compliance with 10 CFR 50, Appendix R, Section III.I on Fire Brigade Training and Appendix A of the Branch Technical Position APCSB 9.5-1 by developing adequate procedures for the qualification and training of Fire Brigade members and other plant personnel.

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FP-6, Fire Brigade Training.

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AP-27.3, Revision 2, Fire Protection.

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AP-15, Training Program.

The inspector verified that these procedures provide indoctrination in fire protection and fire reporting instructions for all plant personnel and visitors. The training program includes classroom instruction in fire protection / prevention, practice in fire fighting and fire drills.

10CFR50, Appendix R, Section II.A requires establishment of fire protection policies and procedures required to implement the program.

Section III.I.3 requires that fire brigade drills be performed in the plant to permit team practice in various plant areas; recommends that each brigade member participate in each drill; and, requires that each brigade members participate in at least two drills per year.

10CFR50.48 requires implementation of the requirements of 10CFR50, Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1,1979, except as modified by previously issued NRC staff Safety Evaluation Reports.

Supplemental NRC Staff Evaluation Report of May 2, 1980 states, in part:

" Annually, brigade members will participate in training sessions in actual fire extinguishment. Quarterly, brigade members participate in preplanned fire brigade drills."

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Fire brigade Training Procedures FP-6, AP-27.3 and AP-15, however require member participation in only one drill per year.

The inspector reviewed fire brigade trair.ing records which reflect licensee requirement of one drill per year. The training records indicate that fourteen members out of thirty-eight fire brigade members participated in only one drill and only one member participated in four drills, meeting the quarterly drill requirement.

Failure to establish and implement the SER commitment is a violation of 10CFR50.48 implementation of Appendix R (82-09-02).

Discussions with the licensee and a review of the training program indicates the licensee believes the practice sessions at the Rockland County Training j

Center satisfies the drill requirements of 10CFR50, Appendix R.

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training, which includes entering a smokehouse wearing a self-contained

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breathing apparatus and use of fire fighting equipment i: given to

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approximately 130 site personnel annually. The inspector determined the training meets the requirement in 10 CFR 50, Appendix R, Section III.I.2 for Practice Sessions, but does not satisfy 10 CFR 50, Appendix R, Section III.I.3.b, for Fire Brigade Training which requires that fire drills be performed in the plant so that the fire brigade can practice as a teain in the plant environment and that each fire brigade member participate in 6t (

least 2 drills per year.

Except as noted above, the licensee maintains an aggressive training program which, in some areas, exceeds the regulatory i

requirements.

I 6.

Equipment Maintenance, Inspection and Tests The inspector reviewed the following documents to determine whether the licensee has developed adequate procedures establishing maintenance and testing requirements and inspection frequencies for the plant's fire l

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protection systems / components and fire brigade equipment.

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3PT-W7, Revision 0, Carbon Dioxide System Inspection.

3PT-W8, Revision 0, Surveillance Test CO Emergency Air Pack.

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1 3PT-W6, Revision 0, Hose House Inspection.

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3PT-W3, Revision 4, Plant and Site Emergency Evacuation Fire Alarm.

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3PT-M42, Revision 4, Main Fire Pump Operability Test.

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3PT-M37A, Revision 0, Fire Protection Valve and Hose Station Inspection -

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3PT-M378, Revision 0, Fire Protection Valve and Hose Station Inspection -

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Part B.

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3 PT-M26, Revision 7, Fire Protection Systems.

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3 PT-SA17, Revision 0, Fire Protection Ultra-Violet Flame Detectors.

3PT-SA13, Revision 3, Fire Protection System Smoke Detectors.

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3PT-SA12, Revision 1, Diesel Generator Building Fire Protection System.

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3PT-SA4, Revision 2, Fire Protection System.

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3PT-A15, Revision 1, Hi Pressure Fire Protection System Valve Cycling (on-line).

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3PT-A14, Revision 2, Diesel Generator Sprinkler System.

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3PT-A13, Revision 2, Electrical Tunnel Heat Detector Operability Test.

3PT-R40, Revision 2, Water Deluge System Testing.

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3PT-R48, Revision 2, Hi Pressure Fire Protection System Valve Cycling (off-line).

3PT-R59, Revision 1, Containment Smoke Detector Functional Test.

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3PT-R58, Revision 0, Containment Fire Protection.

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3PT-R47, Revision 1, Fire Hose Station Surveillance.

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3PT-R84, Revision 0, Fire Pump Functional Test.

In addition,- the inspector verified implementation of the following procedures through 1981 and/or the last refueling cycle.

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3PT-SA13, 3PT-R47, 3PT-R59, 3PT-W8, 3PT-M37A, 3PT-W7, 3PT-W6, 3PT-M42, 3PT-M37B, and 3PT-R84.

No violations were identified.

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Audits The inspector reviewed the results of the licensee's annual fire protection audit dated January 4, 1982; the two year audit dated March 26, 1982 and the three year audit dated May 10, 1979. The inspector determined that the audits were conducted in accordance with written procedures and by personnel not having direct responsibilities in the areas audited. The inspector verified that followup action on audit findings NCA-49,'NCA-50, and NCA-83 identified in the March 26, 1980 audit had been completed.

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No violations were identified.

8.

Loss Prevention Report The inspector reviewed the licensee's property loss prevention report prepared by the licensee's insurer, American Nuclear Insurers (ANI), for Property File No. N-31, dated May 12-14, 1981. The report lists rec-ommendations in accordance with ANI property loss standards.

The licensee's response to the Insurer's recommendations is adequate and positive.

None of the items identified were determined to be reportable to the NRC.

9.

Drill Observation The inspector observed a fire drill held on June 3,1982 simulating a fire in the Switchgear Room, elevation 15'0, Control Building at 10:35 a.m.

The inspector observed that fire bridgade members were at the scene of the fire, in full gear and portable fire extinguishers by 10:37 a.m.

The fire brigade leader postulated the fire as being out of control at 10:39 a.m. requesting the control room personnel call for assistance.

Additional brigade members responded by 10:40 a.m. with fire hoses, fans and associated equipment which were put into operation by 10:42 a.m.

The fire was simulated to have spread to the cable trays, overhead, above the electrical switchgear panels.

The brigade members were directed to suppress the fire with water using the fog type nozzle. The simulated fire was considered under control by 10:48 a.m.

In reviewing the effectiveness of the fire drill with the licensee, the inspector made the following observations:

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Inadvisability of using water to suppress a fire in an area with CO 2 suppression and in close proximity to adjacent redundant electrical switchgear panels as simulated during the drill vice use of installed CO suppression.

Brigade leaders failure to call the control room and inform them the

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area was secure.

Control room failure to make the all clear announcement that would

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have permitted personnel that left the fire area to return.

The brigade readiness, speed of response and brigade enthusiasm in

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fighting the fire was impressive.

10.

Exit Interview The inspector met with licensee representatives (denoted in Details, Paragraph 1) at the conclusion of the inspection on June 4, 1982. The inspe tor summarized the scope of the inspection and the findings as discussed herein.

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