IR 05000289/1990005

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Insp Repts 50-289/90-05 & 50-320/90-02 on 900122-26.No Violations Noted.Major Areas Inspected:Fire Protection/ Prevention Program Including,Program Administration & Organization & Administrative Control of Combustibles
ML20012B285
Person / Time
Site: Crane  Constellation icon.png
Issue date: 03/01/1990
From: Anderson C, Paolino R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20012B283 List:
References
50-289-90-05, 50-289-90-5, 50-320-90-02, 50-320-90-2, NUDOCS 9003140123
Download: ML20012B285 (9)


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I U. S. NUCLEAR REGULATORY COMMISSION

REGION I

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Report Nos.

50-289/90-05: 50-320/90-02 Docket Nos.

50-289/50-320 g

License Nos. DPR-50/0PR-73 Licensee: GPU Nuclear Corporation P.O. Box 480

Middletown, Pennsylvania 17057

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Facility Name: Three Mile Island Units 1 and 2 Inspection At:. Middletown Pennsylvania

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Inspection Conducted: January 22 o26, 1990 Inspectors:

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R. J. P kdlinb,fSenior actor Engineeer, date

/!fo-Approv'ed by:

~C. J. b ders h, Chief, Plant Systems date

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Section, EB, DRS Inspection Summary.

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Inspection on January 22-26, 1990 (Report Nos. 50-289/90-05 and 50-320/90-02)

Areas Inspected:

Routine unannounced inspection of the Fire

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Protection / Prevention Program including:

program administration and organization; administrative control of combustibles; administrative control of ignition sources; other administrative controls; equipment maintenance, I

inspection and tests; t; a brigade training; periodic inspections and quality I

assura::ce audits; and faciluj tours.

Results: Of the areas inspected, no violations were identified, i

i 9003140123 900303 PDR ADOCK 05000289-Q-PDC E

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h DETAILS 1.0 Persons Contracted 1.1 General Public Utilities Nuclear (GPUN) Corporation J. Colitz, Plant Engineering Director W. County, QA Audit Manager l

D. Covill, QA/NDE/ISI R. Glaviano, Manager Technical Functions - TMI Site C. Hartman, Manager Plant Engineering D. Hassler, Licensing Engineer W. Heysek, Licensing Engineer H. Hukill, Director J. Jandovitz, QA/NDE/ISI M. Knight, Licensing Engineer S. Mervine, Training T. O'Connor, Lead Fire Protection Engineer - TMI - 1&2 E. Schrull, Licensing Engineer - TMI - 2 C. Smythe, Licensing Manager - TMI - 1 1.2 Nuclear Regulatory Commission (NRC)

F. Young, Senior Resident Inspector R. McBrearty, Reactor Engineer - RI Note: above personnel present at the exit interview.

2.0 Fire Protection / Prevention Program (64704)

In response to NRC Generic Letter 86-10 regarding overall improvement of the Technical Specification Program, the licensee's Technical Specifica-tions, Limiting Condition for Operation (LCOs) and surveillance require-ments were removed from the Technical Specifications (IS). All of the former TS, LCOs and surveillance requirements formerly described in TS-3.18 and 4.18 were incorporated into administrative procedure No.

AP-1038 " Fire Protection Program." This procedure (AP-1038) was sent to the NRC and docketed on February 1,1988. The Final Safety Analysis Report (FSAR) Section 9.9 was revised to include the Fire Protection Program on February 5, 1988.

FSAR Amendment 146, Section 2C incorporates the fire protection plan in the FSAR and removes the program from the Technical Specification making it a license requirement.

This became effective on November 30, 1988, at which time the TS, LCOs and surveillance requirements for fire services were removed from the TMI-1 Technical Specifications, t

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The inspector reviewed several documents in the following areas of the

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program to verify that the licensee had developed and implemented adequate procedures consistent with the Fire Hazard Analysis (FHA), 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 (Unit 1)

The inspector reviewed the following licensee documents:

Technical Specification, Section 6, Administrative Controls

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FSAR Section 9.9 " Plant Fire Protection Program"

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Procedure No. AP-1038, Revision 21 " Administrative

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Controls - Fire Protection" Corporate Plan No. 1000-PLN-3680.3

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Fire Hazard Analysis Document No. 990-1745 Revision 11

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AP-1038 exhibit 1 " Fire Protection Organization"

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The scope of review was to ascertain that:

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Personnel were designated to implement the program at the site; and b.

Qualifications were delineated for personnel designated to implement the program, c.

Administrative and Technical controls, organization and responsibilities, major commitments are listed and references to

other documents which implement the TMI-1 Fire Protection Program l

are provided.

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The inspector reviewed the documents described above and confirmed that the personnel as well as their qualifications were designated to implement the Fire Protection program at TMI-1.

In addition, the inspector confirmed that adequate Administrative and Technical controls exist to implement the program.

2.2 Administrative Control of Combustibles (Unit 1)

The inspector reviewed the following licensee document:

Procedure No.1035, Revision 19 " Control of Transient Combustibles."

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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; b.

Prohibition on the storage of combustible, flammable or explosive hazardous material in safety-related areas;

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The ret.. oval 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;

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All the wood used in safety-related areas to be treated with flame retardant; e.

Periodic inspection for accumulation of combustibles; f.

Transient combustibles to be restricted and controlled in safety-related areas; and g.

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

The NRC inspector reviewed the above procedure and established that it contained adequate measures for controlling combustible materials at TMI-1, No unacceptable conditions were identified, 2.3 Administrative Control of Ignition Sources (Unit 1)

The inspector reviewed the following licensee document:

Procedure No. 1035, revis;on 19 " Control of Transient Combustibles "

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The scope of review was to verify that the licensee had developed administrative controls which included:

a.

Requirements for special authorization (work permit) for activities involving welding, cutting, grinding, open flame or other ignition sources and that they are properly safeguarded in areas containing safety-related equipment and components; and b.

Prohibition on smoking in safety-related areas, except where

" smoking permitted" areas had been specifically designated by plant management.

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Review of Procedure hv. 1035 confirmed that it contained adequate controls for ignition sources and smoking in safety related areas, r

No unacceptable conditions were identified.

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2.4 Other Administrative Controls (Unit 1)

The inspector reviewed the following licensee documents:

Procedure No. AP-1008, revision 17 " Good Housekeeping"

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Procedure No. 1104-45A, revision 7 " Fire Protection System

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Impairment Control."

Procedure No. EP-013 (5000-ADM-7370-01), revision 2-01 " Fire

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Protection Evaluation" AP-1038 exhibit 8 " Fire Watch Log Sheet"

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The scope of review was to verify that the licensee had developed administrative controls which require that:

a.

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

Firo brigade organization and qualifications of brigade members are delineated;

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Fire reporting instruction for general plant personnel are developed; d.

Feriodic-audits are to be conducted on the entire fire protection

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program; and I-e.

Fire protection / prevention program is included in the licensee's QA Program.

The inspector's review of the procedures described above confirmed that the licensee had developed adequate administrative controls to address each 6f the above issues. With the scope of this review, no unacceptable conditions were identified.

2.5 {guipmentMaintenance,InspectionandTests(Unit 1)

The_ inspector reviewed the following randomly selo-ted documents to determine whether_tne licensee had developed adequate procedures which established maintenance, inspection, and testing requirements for the

. plant fire protection equipment.

The inspector also reviewed the test

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results to verify compliance with license commitments.

The procedures reviewed were:-

' Procedure No. 1303-12.8A-I, revision 7 " Fire Protection System

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-Instrument Functional Test" Procedure No. 1303-12.18, revision 9 " Fire System Nozzle Flow Test"-

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Procedure No. 1303-12.9, revision 18 " Fire Barrier Seal Inspection"

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Procedure No. 1301-12.3,- revision 11 " Fire System Hose Station

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Inspection and Functional Test" Procedure No. 3303-M1, revision 18 " Fire System Valve Lineup

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Verification" Procedure No. 3303-R2,- revision 15 " Fire Pump Capacity Test"

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Procedure No. 3303-A2, revision 19 " Fire System Main Header Flush

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and Loop Test."

Procedure No. 3301-W2, revision, " Fire System Diesel 8attery Check"

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Procedure No.1420-FB-1 " Fire Barrier Penetration Fire Seal Repairs"

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-The inspector reviewed the above surveillance procedures and determined that they adequately addressed the maintenance, surveillance and testing of the fire protection equipment.

In addition, a review of the test results confirmed agreement with licensee commitments.

A review of the corrective maintenance list to assess the effects of any l

- Fire Protection System degradations on safety determined that the-required maintenance is properly prioritized and performed. At the time of the inspection, there were approximately 18 requests for maintenance to Fire l

Protection equipment.

None of these maintenance requests appeared to be major and all of the requests were recent.

2.6 Fire Brigade Training (Unit-1)

Procedure and Records Review The Inspector reviewed the following licensee procedure:

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Procedure AP-1038 " Fire Protection Program" Section 4.11 " Fire

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Protection Training Program"

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_ Procedure No._6212-PG0-2680, revision 7 "TMI Fire Protection

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Training Program" L

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Fire Brigade Training Records - Procedure No. 6210 - ADM - 2610.02 I

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revision 2-00

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_ Fire Protection Procedure and Fire Fighting Plan No. 11.4.01.041

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revision 3

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Pre-Fire Plans, Detection and Suppression System No. 11.4.01.042

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revision 2

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Fire Fighting Tactics No. 11.4.01.043 revision 1

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Fire Ground Evaluation No. 11.4.01.044 revision 4

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Portable Extinguisher, Fire Streams and Fire Fighting Equipment No.

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11.4.01.040 revision 2

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Fire Brigade Cross-Over Training - TMI to THI-2 No. 11-4-01-066

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revision 0 Fire Chemistry and Behavior No. 11.4.01-039 revision 1

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The scope of review was to verify that the licensee had developed-administrative procedures which included:

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Requirements for announced and unannounced drills;

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Requirements for fire brigade _ training and retraining at prescribed frequencies; c.

Requirements for at least one drill per year to be performed on a-

"back shift" for each brigade; d.

Requiremer.ts for maintenance of training-records, e.

Requirements for each fire brigade member to participate in two-drills per year at Unit I and two drills per year at Unit 2.

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Requirements for annual " hands-on" training,

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Requirements for initial and quarterly training.

The inspector also reviewed the training records of the fire brigade

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members for calendar years.1988 and 1989 to ascertain that they had attended the required quarterly training, participated in the required drills and received the annual hands-on fire extinguishment practice.

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-Review of the above documents determined that they adequately address the

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training requirements described in paragraphs a. through g.

A review of the fire brigade's training records identified no deficiencies.

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m 2.7 Periodic Inspections and Quality Assurance Audits (Unit 1)

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The licensee's Fire Protection Program requires that annual, biennial and triennial audits of-the Fire Protection Program be conducted by the

Quality Assurance Department.

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The inspector reviewed the reports of the following audits:

2.7.1 Annual Audit Fire Protection Audit TMI 1 and 2 No. 0-TMI-89-14 dated

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August 21, 1989 thru September 11, 1989.

The' scope of review was to ascertain that the audits were conducted in accordance with the Technical Specification 6.5.3.2.a and aedit findings were being resolved in a timely and satisfactory manr.er, i

2.7.2 Biennial Audit

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Fire Protection Audit TMI - 1 and 2 No. 0-TMI-88-05 dated

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August 29, 1988 thru October 19, 1988.

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.

2.7.3 Triennial Audit Fire Protection Audit TMI 1 and 2 No. 0-TMI-87-02 dated

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August 24, 1987 thru September 17, 1987 The scope of review was to ascertain that the independent audit was

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conducted in accordance with T.S. 6.5.3.2.b and audit' findings were being resolved in a timely and= satisfactory manner.

Review of the above reports determined that the documented audit findings and. operations were thorough and that they adequately addressed the program requirements. Within the scope of this review, no unacceptable conditions were identified.

2.8' Facility Tour (Unit 1)

~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 fixed suppression systems, interior hose stations, fire barrier penetration seals, and fire doors. 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

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extinguishers indicated that monthly inspections were performed.

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No unacceptable conditions were identified.

2.9 TMI-2 Fire Protection / Prevention Program (64704)

The; inspector reviewed licensee amendment No. 32 and the recovery operations plan change No. 41 (dated May 15,1989) which reclassifies much of the i

TMI-2. fire protection system as not important to safety. The only items remaining in the TMI-2 fire protection program which require regular verification and inspection by the licensee are the fire detectors in the

" Reactor Building Panel 720 and its associated alarm circuits; the fire suppression system in that portion of the water supply system that main-tains an operable flow path from 2 pumps and 2 water sources to the four reactor building hose reel stations, and the yard loop fire hydrant.

.i The inspector verified the licensee's surveillance and test documents for the above equipment and confirmed that they complied with the Technical Specifications requirements.

Due to the high radiation levels existing in the zones of interest, visual

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observation of the equipment was made using video cameras located in the area.

Within the scope of this review, no violations or deviations were identified.

3.0 Exit Interview The inspector met with licensee management representatives (see Section 1.0 for attendees) at the conclusion of the inspection on January 26, 1990. The inspector summarized the scope and findings of the inspection at that time.

The inspector also confirmed with the

, licensee that the report w'il not contain any proprietary information.

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

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