IR 05000289/1988023

Insp Rept 50-289/88-23 on 880829-0902.No Violations Noted. Major Areas Inspected:Fire Protection/Prevention Program Including,Program Administration & Organization & Administrative Control of Combustibles & Ignition Sources

ML20204E209
Person / Time
Site:	Three Mile Island
Issue date:	10/12/1988
From:	Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20204E173	List: IR 05000289/1988023 ML20204E169
References
50-289-88-23, NUDOCS 8810210309
Download: ML20204E209 (9)

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U.S. NUCLEAR REGULATORY COMISSION

REGION I

Report No. 50-289/88-23 l l

~ Docket No. 50-289 License No. OPR 50 Priority Category C i

licensee: GPU Nuclear Corporation >

P. O. Box 480 t Middletown. Pennsylvania 17057 ,

Facility Name: Three Mile Island Unit 1  ;

Inspection At: Middletown Pennsylvania [

t Inspection Conducted: August 29 - September 2. 1988  !

t Inspector: . / #[/A /

K.' Krasopon os,' Reactor Engineer I dare  !

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Approved by: b) J C. JY Anderson, Chief Plant Systems

/o/lt/ff ' date

f Section, EB, DRS l l

Inspection Summary: Inspection on August 29 - September 2. 1988 (Report N l 50-289/88-23) -

Areas Inspected: Routine unannounced inspection of the Fire Protection / Pre-i vention Program including: program administration and organization;

! administrative control of combustibles; administrative control of ignition sources; other administrative controls; equipment maintenance, inspection and tests; fire brigade training; periodic inspections and quality assurance audits; and facility tours.

] Results: Of the areas inspected, no violations were identifie <

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OETAILS 1.0 Persons Contracted 1.1 General Public Utilities Nuclear (GPUN) Corporation

• D. Hukill, Director THI-1

• T. A. Broughton, Operations and Maintenance Ofrector, THI-1

• C Hartman, Manager Plant Engineering

"R. Barth, Fire Protection Engineer

• C Incorvati, Audit Manger

• Nelson, Manager Nuclear Safety

• S. Otto, Licensing Engineer

• H. Wilson, THI-2 Plant Material

• S. Hervine, Fire Protection Training Supervisor

• D. Corbett, QA Lead Auditor

• R. Knight TMI-1 Licensing

• D. McGettrick, Tech Functions T. O'Connor, Fire Protection Engineer 1.2 Nuclear Regulatory Commission (NRC)

• R. Conte Sr., Resident Inspection

• A. Bhattacharyya, Resident Inspector

• Denotes those present at the exit intervie .0 Fire Protection / Prevention Program The inspector reviewed several documents in the following areas of the program to verify that the licensee had developed and implemented adequate procedures consistent with the Fire Hazard Analysis (FRA), Final Safety Analysis Report (FSAR), and Technical Specifications (TS). The documents reviewed, the scope of review, and the inspection findings for each area of the program are described in the following sections, 2.1 Program Administration and Organization The inspector reviewed the following licensee documents:

-- Technical Specifications, Section 6, Administrative Controls

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Fire Protection Program Plan

-- Admin. Procedure 1038 Rev. 15 Fire Protection Program

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The scope of review was to ascertain that: Personnel were designated for implement the program at site; and Qualifications were delineated for personnel designated to implement the progra ,

. No unacceptable conditions were identifie , ,

2.2 Administrative Control of Combustibles The inspector reviewed the following licensee document:

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Admin. Procedure 1035 Rev. 14 Control of Transient Combustible

Materials i

! The scope of review was to verify that the licensee had developed

! administrative controls which included:

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Special authorization for the use of combustible, flammable or explosive hazardous material in safety-related areas;

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, Prohibition on the storage of combustible, flammable or explosive hazardous material in safety-related areas; I The removal of all wastes, debris, rags, oil spills or other

! combustible materials resulting from the work activity or at the end of each work shift, whichever is sooner; i

' All the wood used in safety-related areas to be treated with flame j retardant; Periodic inspection for accumulation of combustibles; Transient combustibles to be restricted and controlled in safety-related areas; and

l Housekeeping to be properly maintained in areas containing safety-related equipment and components.

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No unacceptable conditions were identified.

! 2.3 Administrative Control of Ignition Sources

, The inspector reviewed the following licensee document:

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l Maintenance Procedure MP 1410-Y-26, Control of Hot Wor ,

The scope of review was to verify that the licensee had developed i administrative controls which included: , Requirements for special authorization (work permit) for activities involving walding, cutting, grinding, open flame or other ignition sources and that they they are properly safeguarded in areas containing safety-related equipment and components; and (

, Prohibition on smoking in safety-related areas, except where

"smoking permitted" areas had been specifically designated by plant '

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managemen No unacceptable conditions were identifie !

2.4 Other Administrative Controls l The inspector reviewed the following licensee documents: f

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Technical Specifications Section 6, Administrative Controls I

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Administrative Procedure 1038, Revision 15, Fire Protection Program The scope of review was to verify that the licensee had developed -

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administrative controls which require that: t Work authorization, construction permit or similar arrangement is ,

provided for review and approval of modification, construction and I maintenance activities which could adversely affect the safety of the facility; Fire brigade organization and qualifications of brigade members are delineated;  !

i Fire reporting instr iction for general plant personnel are developed;

" Periodic audits are to be conducted on the entire fire protection program; and Fire protection / prevention program is included in the licensee's QA l Progra ;

j No unacceptable conditions were identified, '

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4 2.5 Equipment Maintenance, Inspection and Tests The inspector reviewed the following randomly 5 elected documents to determine whether the licensee had developed adequate procedures which

. established maintenance, inspection, and testing requirements for the

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plant fire protection equipment. The inspector also reviewed the test results to verify compliance with the Technical Specifications. The procedures reviewed were:

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i Procedure 3303-Al Fire System Valve Cycling

. Procedure 3303-R2 Fire Pump Capacity Test i

Procedure 3303-A2 Fire System Main Header Flush and Loop Test Procedure 3303-01 Fire Pump Diesel Fuel Procedure 3301-R1 Fire Service Diesel Engine Inspection

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Procedure 3301-Q2 Specific Gravity Check, Diesel Fire Pumps i fcocedure 1303-1 CO2 Fire Protection System Test Fire Damper Functional Test

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Procedure 1303-12.23 Procedure 1303-12.24 TSI Fire Barrier Inspection l The inspector in reviewing the st.rveillance procedures did not identify any unacceptable conditions, however, the inspector observed that the I

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visual surveillance of fifty one fire dampers was accomplished by one person in one eight hour shift. A similar surveillance performed in the l previous cycle was performed in 20 man hour !

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The inspector also observed the capacity test of the diesel driven fire j pump, located in the circulating water pump house. The test was performed i !n accordance with the established procedures. The licensee after the i completion of the test declared the fire pump inoperable since the pump

could not attain its design capacit The licensee stated that the pump l will either be repaired or replaced in the very near future, f

l The inspector also reviewed the corrective maintenance list to assess the

> effect of any Fire Protection System degradations on safety. This review i determined that required maintenance is properly prioritizea and performed.

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At the time of the inspection there were approximately 70 requests for

maintenance to Fire Protection equipment. None of these maintenance f requests appear to be major and all of the requests are recen Another observation by the inspector concerned the surveillance procedure titled "Fire Damper Functional Test." This is a mistitle since it is a

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visual inspection not a functional tes The licensee agreed to change the procedure title.

l 2.6 Fire Brigade Training i

j Procedure and Records Review The inspector reviewed the following licensee procedure:

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TMI Fire Protection Training Program No. 7812-PGD-2680 Revision 6 The scope of review was to verify that the licensee had developed

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administrative procedures which included: Requirements for announced and unannounced drills; Requirements for fire brigade training and retraining at prescribed J frequencies; Requirements for at lrast one drill per year to be performed on e a "back shift" for each brigade; Requirements for maintenance nf training record Requirements for each fire brilade member to participate in two i drills per year at Unit 1 and two drills per year at Unit , Requirements for annual "hands-on" training, Requirements for initial and quarterly training.

! The inspector also reviewed the traini'ig records of the fire brigade

, members for calendar years 1987 and 1988 to ascertain that they had attended the required quarterly training, participated in the required drills and received the annual hands-on fire extinguishment practic ,

One deficiency was identified as follows:

, The licensee in the definition section of the above referenced procedure i

defines that annual training can be given anytime within a 15 month perio I Similarly, quarterly training can be given anytine within 112 days. The licensee stated that this definition was derived for the Technical Specifi-cations that allow the surveillance intervals to be exceeded by 25%.

, The inspector noted tiiat this 254 grace period was not bounded and allcwed personnel to exceed the nominal time interval numerous time Furthermore, the inspector noted that the licensee is not making use of

! the grace period conservatively since the inspector determined that about 50% of the fire figM?rs had not received the two drills per year either at Unit 1 or Unit I In addition, the inspector questioned the propriety l of using the T.S. c1 ,ition. The inspector, however, committed to

resolve the issue b, jetting an interpretation from NRR on the appli-t cability of the T.S. cetinitions for the training interval. This item is

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unresolved (88-23-01).

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2.7 Periodic Inspections and Quality Assurance Audits 2. Annual Audit The inspector reviewed the following annual audit:

Audit 0-TMI-86-09, Fire Protection THI-1 and THI- The scope of review was to ascertain that the audits were conducted in accordance with the Technical Specification 6.5.3.2.a and audit findings were being resolved in a timely and satisfactory manne No unacceptable conditions were identifie . Biennial Audit The inspector reviewed the following biennial audit:

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GPUN - Audit Report S-THI-83-03 The scope of review was to ascertain that the audit was conducted in accordance with T.S. 6.5.3.1.g. and audit findings were being resolved in a timely and satisfactory manner.

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No unacceptable conditions were identifie . Triennial Audit

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The inspector reviewed the following triennial audit:

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GPUN QA Audit Report 0-TMI-87-02 Tr?ennial Fire Protection THI-1 and TMI- The scope of review was to ascertain that the audit was conducted in accordance with T.S. 6.5.3.2.b and audit findings were being l resolved in a timely and satisfactory manne l t No unacceptable conditions were identifie .8 Facility Tour The inspector examined fire protection water systeas, 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 fixed suppression systems, interior hose stations, fire barrier penetration seals, and fire door The inspector observed general plant housekeeping conditions and randomly checked tags

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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 l 2  :

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i No unacceptable conditions were identified except as follow i The inspector in checking the contents of the Hose Houses in the yard i

' observed that the hoses in hose houses on the TMI-1 side are tested annually while the hoses located in hose houses at the Unit 2 side are

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tested every three years. The National Fire Protection Association (NFPA) :

quidance specifies that hoses stored in outside hose houses are tested I annually. The licensee agreed to review the Unit 2 procedure and test all i

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hoses located in outside hose houses annually. The inspector also observed that on the Turbine building ground floor licensee personnel had storad a one 55 gallon drum of alcohol and one 55 gallon drum of a flammable solvent. l

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The latter was taped out and had a funnel for pouring. The inspector ;

observed that although there were no safe shutdown equipment in the area i this practice of storing and pouring flammables is dangerous and could i

present a fire hazard. The licensee agreed and removed the drum !

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2.9 10 CFR 50 Appendix R Concerns

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i The inspector reviewed the licensee's actions relative to the issues i identified to NRC by letter dated May 21, 1988. In this letter the

! license informed the NRC that intermediate cooling valves IC-V-3 and

1C-V-4 could close spuriously as a result of fire in several plant area The effect of this inadvertent closure would be loss of thermal barrier

! cooling of the Reactor Coolant Pu'rp (RCP) seal The primary method of

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providing seal cooling would also be lost as a result of the same fire.

j Neither of these valvas could be manually reopened on time, that is prior to seal failure and the RCP's also could not have been tripped on time.

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) 1.o55 of the thermal barrier cooling will result in a rupture of the primary coolant boundary and this is a violation of 10 CFR 50 Appendix R requirements which stipulate that shutdown shall be accomplished without rupture of the primary coolant boundary. However given the fact that this violation was identified by the licensee and was promptly corrected the NRC will not issue a notice of violatio .0 Unresolved Items Unresolved items are matters about which more information is required to ascertain whether they are acceptable items, violations or deviation One unresolved item disclose during the inspection is discussed in Section 2.6,

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5.0 Exit Interview The inspector met with licensee management representatives (see Section 1.0 for attendees) at the conclusion of the inspection on September 2, 1988, The inspector summarized the scope and findings of the inspection at that tim The inspector also confirmed with the licensee that the report will not contain any proprietary informatio At no time during this inspection was written material provided to the licensee by the inspector, I

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