IR 05000289/2005012
| ML060130537 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/13/2006 |
| From: | Rogge J Engineering Region 1 Branch 3 |
| To: | Crane C AmerGen Energy Co |
| References | |
| -RFPFR IR-05-012 | |
| Download: ML060130537 (25) | |
Text
January 13, 2006
SUBJECT:
THREE MILE ISLAND STATION, UNIT 1 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000289/2005012
Dear Mr. Crane:
On December 15, 2005, the NRC completed a triennial fire protection team inspection at your Three Mile Island Station, Unit 1. The enclosed report documents the inspection results which were discussed at an exit meeting on December 15, 2005, with Mr. Rusty West and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, the NRC identified one finding of very low safety significance (Green) that was a violation of NRC requirements. However, because of the very low safety significance and because it is entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with copies to the Regional Administrator Region I, the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001, and the NRC Resident Inspector at the Three Mile Island Station.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the
Mr. Christopher NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/ADAMS.html (the Public Electronic Reading Room).
Sincerely,
/RA/
John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-289 License No. DPR-50 Enclosure: NRC Inspection Report 05000289/2005012 cc w/encl:
Chief Operating Officer, AmerGen Site Vice President - TMI Unit 1, AmerGen Plant Manager - TMI, Unit 1, AmerGen Regulatory Assurance Manager - TMI, Unit 1, AmerGen Senior Vice President - Nuclear Services, AmerGen Vice President - Mid-Atlantic Operations, AmerGen Vice President - Operations Support, AmerGen Vice President - Licensing and Regulatory Affairs, AmerGen Director Licensing - AmerGen Manager Licensing - TMI, AmerGen Vice President - General Counsel and Secretary, AmerGen T. ONeill, Associate General Counsel, Exelon Generation Company J. Fewell, Esq., Assistant General Counsel, Exelon Nuclear Correspondence Control Desk - AmerGen Chairman, Board of County Commissioners of Dauphin County Chairman, Board of Supervisors of Londonderry Township R. Janati, Director, Bureau of Radiation Protection, State of PA J. Johnsrud, National Energy Committee E. Epstein, TMI-Alert (TMIA)
D. Allard, PADER
Mr. Christopher
SUMMARY OF FINDINGS
IR 05000289/2005012 on 11/28/2005 - 12/15/2005, Three Mile Island (TMI) Station, Unit 1;
Triennial Fire Protection Team Inspection, Fire Protection.
This report covered a two-week triennial fire protection team inspection by four Region I specialist inspectors. One Green NCV was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC)0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
NRC-Identified Findings
Cornerstone: Initiating Events
- Green.
The team identified a non-cited violation (NCV) with multi-examples for failure to document fire prevention activities during hot work as required by the administrative control procedures, and for fire watch personnel not being adequately qualified. Specifically: 1) there were numerous cases where hot workers, fire watch personnel, and associated supervisors failed to document, as required, the hot work, fire watching and inspection activities respectively in accordance with OP-MA-201-004, Fire Prevention for Hot Work, and AP-1038, and Administrative Control - Fire Protection Program; and, 2) there were three cases where the fire watchers were not adequately trained as required by the procedures. The licensee generated three condition reports and entered this issue into their corrective action program.
The finding is more than minor because it is associated with the Initiating Events Cornerstone attribute of protection against external factors and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Under Manual Chapter 0609, Significance Determination Process,
Appendix F, Fire Protection, the finding was found to represent a low degradation and as such was of very low safety significance in accordance with the Fire Protection Significance Determination Process. The cause of the finding is related to the cross-cutting element of human performance (attention to detail)because hot work personnel repetitively failed to follow procedural instructions in the documentation of their hot work activities. (Section 1R02)
Licensee-Identified Violations
None
REPORT DETAILS
Background This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (IP) 71111.05T, Fire Protection. The objective of the inspection was to assess whether AmerGen Energy Company, LLC, has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Three Mile Island (TMI) Station, Unit 1.
Four plant areas that included the following fire zones (FZs) and fire areas (FAs), were selected for detailed review based on risk insights from the TMI Individual Plant Examination (IPE)/Individual Plant Examination of External Events (IPEEE):
C Fire Area CB-FA-2e C Fire Area CB-FA-3b C Fire Area CB-FA-4b C Fire Zone AB-FZ-2a The inspection team evaluated the AmerGen Energys fire protection program (FPP) against applicable requirements which include plant Technical Specifications, Operating License Condition 2.C.4, NRC Safety Evaluations, 10 CFR 50.48 and 10 CFR 50 Appendix R. The team also reviewed related documents that include the Updated Final Safety Analysis Report (UFSAR), Section 9.9, and the Fire Hazards Analysis Report (FHAR).
Specific documents reviewed by the team are listed in the attachment.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems
==1R05 Fire Protection
==
.01 Post-Fire Safe Shutdown From Outside Main Control Room (Alternative Shutdown) and
Normal Shutdown
a. Inspection Scope
Methodology The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentation drawings (P&IDs), electrical drawings, the UFSAR and other supporting documents to verify that hot and cold shutdown could be achieved and maintained from outside the control room for fires that rely on shutdown from outside the control room.
This review included verification that shutdown from outside the control room could be performed both with and without the availability of offsite power. Plant walkdowns were also performed to verify that the plant configuration was consistent with that described in the FHAR. These inspection activities focused on ensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor decay heat removal, process monitoring instrumentation and support systems functions. The team verified that the systems and components credited for use during this shutdown method would remain free from fire damage. The team verified that the transfer of control from the control room to the alternative shutdown location(s) would not be affected by fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for alternative shutdown control circuits).
Similarly, for fire areas that utilize shutdown from the control room, the team also verified that the shutdown methodology properly identified the components and systems necessary to achieve and maintain safe shutdown conditions.
Operational Implementation The team verified that the training program for licensed and non-licensed operators included alternative shutdown capability. The team also verified that personnel required for safe shutdown using the normal or alternative shutdown systems and procedures are trained and available onsite at all times, exclusive of those assigned as fire brigade members.
The team reviewed the adequacy of procedures utilized for post-fire shutdown and performed an independent walk through of procedure steps to ensure the implementation and human factors adequacy of the procedures. The team also verified that the operators could be reasonably expected to perform specific actions within the time required to maintain plant parameters within specified limits. Time critical actions which were verified included restoration of AC electrical power, establishing the remote shutdown panel, and establishing decay heat removal.
Specific procedures reviewed for alternative shutdown, including shutdown from outside the control room included the following:
C OP-TM-EOP-020, Cooldown From Outside of Control Room, Rev. 5 C
OP-TM-AOP-001-C2E, Fire in B Inverter Room, Rev. 0 C
OP-TM-AOP-001-C3B, Fire in 1E 4160V Switchgear Room, Rev. 0 C
1104-45P, Fire Mitigation, Rev. 20 The team reviewed manual actions to ensure that they had been properly reviewed and approved and that the actions could be implemented in accordance with plant procedures in the time necessary to support the safe shutdown method for each fire area. The team also reviewed the periodic testing of the alternative shutdown transfer capability and instrumentation and control functions to ensure the tests are adequate to ensure the functionality of the alternative shutdown capability.
b. Findings
No findings of significance were identified.
.02 Protection of Safe Shutdown Capabilities
a. Inspection Scope
The team reviewed the fire hazards analysis, safe shutdown analyses and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The team ensured that separation requirements of Section III.G of 10 CFR 50, Appendix R were maintained for the credited safe shutdown equipment and their supporting power, control and instrumentation cables. This review included an assessment of the adequacy of the selected systems for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and associated support system functions.
The team reviewed AmerGen Energys procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the Fire Hazard Analysis (FHA). A sample of hot work and transient combustible control permits were also reviewed. The team performed plant walkdowns to verify that protective features were being properly maintained and administrative controls were being implemented.
The team also reviewed AmerGen Energys design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the fire protection program and/or post-fire safe shutdown analysis and procedures.
b. Findings
Introduction.
The team identified a Green NCV regarding the documentation of hot work activities and the qualification of fire watch personnel under AmerGen Energys fire protection program.
Description.
The team reviewed a sample of completed hot work permits (HWP) and requested additional samples based on the discovery of issues. Of 33 total HWPs reviewed, the hot work activities for six permits were conducted during full power operation while those for the remaining 27 were conducted during the recent refueling outage. Numerous cases of failures to meet the procedural requirements of OP-MA-201-004, Fire Prevention for Hot Work, were identified. The deficiencies identified for the six HWPs conducted during full power were: three cases where the documented fire watch durations did not envelope the total hot work durations, three cases where the hot worker did not document the hot work duration and one case where the supervisor did not sign the HWP within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the hot work activity. The deficiencies identified for the 27 HWPs conducted during the recent plant outage were: 14 cases where the documented fire watch durations did not envelope the total hot work durations, two cases where the hot worker did not document the hot work durations, three cases where the supervisor did not sign the HWP and document the inspection within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the hot work activities, one case where the question in Section 2 of the HWP for possible vertical fire spread should have been answered yes (instead of no) because the hot work involved possible slag falling to the floor below, causing the hot work supervisor to fail to forward the hot work permit to the Fire Marshal for review and approval, and three cases where the fire watch personnel were not qualified (not adequately trained).
Exelon procedure OP-MA-201-004, Fire Prevention for Hot Work, establishes the responsibilities and tasks to be performed by hot workers, their associated supervisors and fire watch personnel. Paragraph 4.6.6 of the procedure requires the hot worker to complete section IV of the HWP, including recording date and time of each activity, upon completion of the hot work. Paragraph 4.6.5 of the procedure requires the hot work supervisors to complete Section III of the HWP (inspect each hot work site initially and every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter to ensure that fire prevention precautions are still established and record the date and time of the activities performed). Paragraph 4.6.7 of the procedure requires the fire watch personnel to: 1) complete section V of the HWP prior to starting the activity, whenever the fire watch is suspended then restarted following breaks, and whenever the fire watch duty is turned over to another individual; and, 2) record the starting and ending date and time of the fire watch. If the question in Section 2 of the hot work permit (for possible vertical fire spread) is answered yes, paragraph 4.6.1.2 of the procedure requires the hot work supervisor to forward the hot work permit to the Fire Marshal for review and approval.Section V of the HWP also requires the fire watchers to be trained to use portable extinguishers. In addition, paragraph 4.15.1 of procedure AP-1038, Administrative Control - Fire Protection Program, requires personnel assigned fire watch duties to complete an annual hot work fire watch training program. Contrary to these requirements, there were numerous cases where hot workers failed to document the hot work duration, supervisors failed to document their hot work area inspections, fire watch personnel failed to properly document the duration of their fire watch activities, and fire watch personnel were not properly trained to perform their duties. These performance deficiencies represent a failure to implement the hot work permit program and its associated hot work record keeping.
Analysis.
Hot work fire watches serve as a fire detection mechanism and an effective means of preventing hot work fires. The early detection and suppression of an incipient fire reduces the maximum heat release rate achieved. NFPA 51B-2003, Fire Prevention During Welding, Cutting and Other Hot Work, Annex B states that hot work performed improperly is a major cause of fire.
The finding described above is more than minor because it is associated with the Initiating Events Cornerstone attribute of protection against external factors and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. This finding was determined to be of very low safety significance (Green, as discussed below) because the likelihood that a fire might occur, or that a fire which does occur and might not be promptly suppressed is remote. In Manual Chapter 0609, the Significance Determination Process (SDP) Phase 1 screening worksheet for Initiating Events Cornerstone refers fire prevention degradation to Appendix F, Fire Protection SDP, which only applies to activities during power operations (involving seven cases of violations associated with hot work record keeping as discussed above). Attachment 2 to Appendix F classifies violations associated with hot work record keeping as low degradation items. According to the guidance provided in the phase1qualitative screening (step 1.3.1) of Appendix F, this finding can be screened to Green.
For the cases of violations associated with hot work record keeping that occurred during the plant outage, the finding did not meet the prerequisites for the use of Manual Chapter 0609 Appendix F and therefore falls under regional branch chief review in accordance with Manual Chapter 0612, 05.04.C. Since these cases are similar to those that occurred during power operations, these cases are treated as additional examples to the finding described above. The team also determined that the cause of this finding is related to the personnel aspect of human performance (attention to detail) cross-cutting area because hot work personnel repetitively failed to follow procedural instructions in the documentation of their hot work activities.
Enforcement.
License condition 2.C(4) requires that AmerGen implement and maintain in effect all provisions of the Fire Protection Program as described in the Updated Final Safety Analysis Report (UFSAR). Section 9.9.2 of the UFSAR identifies Administrative Procedure AP-1038 as the procedure establishing TMI Unit 1 Fire Protection Program functions. Procedure AP-1038 section 5.19.1 directs fire watch personnel to provide fire protection in support of work involving open flames, welding and grinding in accordance with procedure OP-MA-201-004. Procedure OP-MA-201-004 paragraphs 4.6.5 through 4.6.7 requires the hot workers, hot work supervisors, and fire watch personnel to document the dates and time of the hot work activities on the HWPs.
Section V of the HWP also requires the fire watch personnel to be trained to use portable extinguishers. In addition, paragraph 4.15.1 of administrative procedure AP-1038 requires personnel assigned fire watch duties to complete an annual hot work fire watch training program. Contrary to these requirements, there were numerous cases where hot workers failed to document the hot work duration, supervisors failed to document their hot work area inspections, fire watch personnel failed to properly document the duration of their fire watch activities, and fire watch personnel were not properly trained to perform their duties. The licensee issued condition reports ARs 399726, 428991 and 429891 and entered these deficiencies into their corrective action program. This violation is being treated as a Non-Cited Violation (NCV), consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000289/2005012-01) Failure to Implement Hot Work Procedural Requirements.
.03 Passive Fire Protection
a. Inspection Scope
The team walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries (including walls, fire doors and fire dampers) to ensure they were appropriate for the fire hazards in the area.
The team reviewed installation/repair and qualification records for a sample of penetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design.
b. Findings
No findings of significance were identified.
.04 Active Fire Protection
a. Inspection Scope
The team reviewed the design, maintenance, testing and operation of the fire detection and suppression systems in the selected plant fire areas. This included verification that the manual and automatic detection and suppression systems were installed, tested and maintained in accordance with the National Fire Protection Association (NFPA) code of record, or as NRC approved deviations, and that they would control and/or extinguish fires associated with the hazards in the selected areas. A review of the design capability of suppression agent delivery systems was verified to meet the code requirements for the fire hazards involved. The team also performed a walkdown of accessible portions of the detection and suppressions systems in the selected areas as well as a walkdown of major system support equipment in other areas (e.g., fire protection pumps, Carbon Dioxide (CO2) storage tanks and supply system) and assess the material condition of the systems and components.
The team reviewed electric and diesel fire pump flow and pressure tests to ensure that the pumps were meeting their design requirements. The team also reviewed the fire main loop flow tests to ensure that the flow distribution circuits were able to meet the design requirements.
The team also assessed the fire brigade capabilities by reviewing training and qualification records, and drill critique records. The team also reviewed pre-fire plans and smoke removal plans for the selected fire areas to determine if appropriate information was provided to fire brigade members and plant operators to identify safe shutdown equipment and instrumentation, and to facilitate suppression of a fire that could impact post-fire safe shutdown. In addition, the team inspected the fire brigades protective ensembles, self-contained breathing apparatus (SCBA), and various fire brigade equipment (including smoke removal equipment) to determine operational readiness for fire fighting.
b. Findings
No findings of significance were identified. An observation for the review of fire pump tests was discussed in Section 4OA2.01.
.05 Protection From Damage From Fire Suppression Activities
a. Inspection Scope
The team performed document reviews and plant walkdowns to verify that redundant trains of systems required for hot shutdown are not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team verified that:
C A fire in one of the selected fire areas would not directly, through production of smoke, heat or hot gases, cause activation of suppression systems that could potentially damage all redundant trains.
C A fire in one of the selected fire areas (or the inadvertent actuation or rupture of a fire suppression system) would not directly cause damage to all redundant trains (e.g., sprinkler caused flooding of other than the locally affected train).
C Adequate drainage is provided in areas protected by water suppression systems.
b. Findings
No findings of significance were identified.
.06 Alternative Shutdown Capability
a. Inspection Scope
Alternative shutdown capability for the areas selected for inspection utilizes shutdown from outside the control room and is discussed in Section 1R05.01 of this report.
.07 Circuit Analyses
a. Inspection Scope
The team verified that the licensee performed a post-fire safe shutdown analysis for the selected fire areas and that the analysis appropriately identified the structures, systems and components important to achieving and maintaining post-fire safe shutdown.
Additionally, the team verified that AmerGen Energys analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot shorts, shorts to ground or other failures were identified, evaluated and dispositioned to ensure spurious actuations would not prevent safe shutdown.
The teams review considered fire and cable attributes, potential undesirable consequences and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, spurious actuations, actuations resulting in flow diversion or loss of coolant events.
The team also reviewed wiring diagrams and routing lists for a sample of components required for post-fire safe shutdown to verify that cables were routed as described in the cable routing matrices.
Cable failure modes were reviewed for the following components:
C MU-P-1B, Make-up Pump B C
MU-P-1C, Make-up Pump C C
MU-V-14A, Make-up Valve C
MU-V-16A, Make-up Valve C
LI-777, Pressurizer Level Instrument C
PI-949, Pressurizer Pressure Instrument C
LI-776A, OTSG Level Instrument The team reviewed circuit breaker coordination studies to ensure equipment needed to conduct post-fire safe shutdown activities would not be impacted due to a lack of coordination. The team confirmed that coordination studies had addressed multiple faults due to fire. Additionally, the team reviewed a sample of circuit breaker maintenance and records to verify that circuit breakers for components required for post-fire safe shutdown were properly maintained in accordance with procedural requirements.
b. Findings
No findings of significance were identified.
.08 Communications
a. Inspection Scope
The team reviewed safe shutdown procedures, the post-fire safe shutdown analysis and associated documents to verify an adequate method of communications would be available to plant operators following a fire. During this review, the team considered the effects of ambient noise levels, clarity of reception, reliability and coverage patterns.
The team also inspected the designated emergency storage lockers to verify the availability of portable radios for the fire brigade. The team also verified that communications equipment such as repeaters, transmitters, etc. would not be affected by a fire.
b. Findings
No findings of significance were identified.
.09 Emergency Lighting
a. Inspection Scope
The team observed the placement and coverage area of eight-hour emergency lights, and in specified locations permanent essential lighting, throughout the selected fire areas to evaluate their adequacy for illuminating access and egress pathways and any equipment requiring local operation and/or instrumentation monitoring for post-fire safe shutdown. The team also verified that the battery power supplies were rated for at least an 8-hour capacity. Preventive maintenance procedures and various documents, including the vendor manuals and completed surveillance tests were reviewed to ensure adequate surveillance testing and periodic battery replacements were in place to ensure reliable operation of the eight-hour emergency lights and that the emergency lighting units were being maintained consistent with the manufacturers recommendations and accepted industry practices.
b. Findings
No findings of significance were identified.
.10 Cold Shutdown Repairs
a. Inspection Scope
The team verified that AmerGen Energy had dedicated repair procedures, equipment, and materials to accomplish repairs of components required for cold shutdown, which might be damaged by the fire to ensure cold shutdown could be achieved within the time frames specified in their design and licensing bases. The team verified that the repair equipment, components, tools and materials (e.g., precut cables with prepared attachment lugs) were available and accessible onsite.
b. Findings
No findings of significance were identified.
.11 Compensatory Measures
a. Inspection Scope
The team verified that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g., detection and suppression systems and equipment, passive fire barriers, pumps, valves or electrical devices providing safe shutdown functions or capabilities). The team also verified that the short term compensatory measures compensated for the degraded function or feature until appropriate corrective action could be taken and that AmerGen Energy was effective in returning the equipment to service in a reasonable period of time.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems
.01 Corrective Actions for Fire Protection Deficiencies
a. Inspection Scope
The team verified that the licensee was identifying fire protection and post-fire safe shutdown issues at an appropriate threshold and entering them into the corrective action program. The team also reviewed a sample of selected issues to verify that the licensee had taken or planned appropriate corrective actions.
The team reviewed condition report AR 00175664 dated September 14, 2003, which documented an issue that the fire system capability test on September 13, 2003, for the fire pumps failed to meet the acceptance criteria prescribed in Procedure 3303-A2, Fire System Main Header Flush and Loop Test. Specifically, the measured flow was 1800 gpm which is less than the required flow (the acceptance criteria) of 2575 gpm.
AmerGen completed an operability evaluation (OPE-03-025) and determined that the degraded condition would not affect the post-fire safe shutdown function of the fire system, because a significant portion of the prescribed 2575 gpm was for a fire in the cooling towers, which was not required for safe shutdown. AmerGen completed another test on September 2, 2004. Again the measured flow (2200 gpm) was less than the required flow. This deficient condition (inadequate flow) was covered by the original operability evaluation. AmerGen completed a third test on October 13, 2005, under an interim procedure change to include a device for more accurate flow measurement, and obtained a flow of 3420 gpm at 96 psig. This flow exceeded the acceptance criteria of 2575 gpm but fell short of the required 100 psig pressure. The licensee was able to provide a basis that 96 psig at the measuring point would not affect the fire systems post-fire safe shutdown capability.
b. Findings
No findings of significance were identified.
While the failure to meet the acceptance criteria for the fire systems tests during the past three years did not affect the systems post-fire safe shutdown function, the system was in non-compliance with the UFSAR. The UFSAR states that the fire suppression water system piping is sized and arranged to transport 2575 gpm to the most remote deluge system plus 1000 gpm to hoses with a minimum residual pressure of 100 psi at the most remote deluge system. Historically, the successful performance of the fire systems test bounds both the post-fire safe shutdown requirements and those for general property protection. AmerGen generated condition report AR 433847433847to resolve this non-compliance issue.
4OA4 Cross-Cutting Aspects of Findings
Section 1R05 described a finding of numerous cases where hot workers failed to document the hot work duration, supervisors failed to document their hot work area inspections, fire watch personnel failed to properly document the duration of their fire watch activities, and fire watch personnel were not properly trained to perform their duties. The cause of this finding was related to the personnel aspect of human performance (attention to detail) cross-cutting area because hot work personnel repetitively failed to follow procedural instructions in the documentation of their hot work activities.
4OA6 Meetings, Including Exit
Exit Meeting Summary
The team presented their preliminary inspection results to Mr. Rusty West, Site Vice President, and other members of the site staff at an exit meeting on December 15, 2005. No proprietary information was included in this inspection report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
AmerGen Energy Personnel
- J. Banett, Maintenance
- D. Barry, Systems Engineer
- G. Chick, Plant Manager
- E. Eilola, Director, Engineering
D Hull, I&C Engineer
- W. McSorley, Operator
- R. Myers, Fire Marshall
- D. Palaferro, System Manager
- C. Pragman, Corporate Fire Protection Program Manager
- S. Queen, Senior Manager, Plant Engineering
- L. Rajkowski, Fire Protection Program Engineering
- W. Reiley, Reactor Operator
- R. Sieglitz, System Engineer
- C. Shorts, Electrical Power & Instrumentation
L Terrazas, Fire Protection Engineer
- R. West, Site Vice President
- T. Wickel, Senior Manager, Design Engineering
PA Department of Environment Protection
- M. Murphy, Engineer
NRC
- J. Rogge, Chief, Engineering Branch 3, Division of Reactor Safety
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
NONE Open and
Closed
- 05000289/2005012-01 NCV Failure to Implement Hot Work Procedural Requirements (Section 1R05.02)
Closed
None
Discussed
None