IR 05000293/1986038

Insp Rept 50-293/86-38 on 861112-14.Violations Noted: Inadequate Fire Water Sys Drawings & Operating Procedures & Weaknesses in Fire Protection Sys Maint & Fire Brigade Personnel Training

ML20215B861
Person / Time
Site:	Pilgrim
Issue date:	12/03/1986
From:	Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20215B823	List: IR 05000293/1986038 ML20215B820 ML20215B831
References
50-293-86-38, NUDOCS 8612120343
Download: ML20215B861 (8)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket / Report No. 50-293/86-38 Licensee: Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199 Facility: Pilgrim Nuclear Power Station

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Location: Plymouth, Massachusetts Dates: November 12 - 14, 1986 Inspectors: M. McBride, Senior Resident Inspector J. Lyash, Resident Inspector

. Kim, Resident Inspector (R.E. Ginna)

Approved by: _k4 4- /4 86 JJ/Wigginsg [Jh)ef, Reactor Projects Date Section IB Summary: November 12 - 14, 1986 Inspection Report 50-293/86-38 Areas Inspected: Special unannounced inspection of operations and maintenance activities surrounding the isolation of the fire water supply system between November 5 and November 11, 198 Results: One violation involving inadequate fire water system drawings and operating procedures is discussed in section 4. Examples of weakness in prioritizing fire protection system maintenance are identified in sections 4 and A weakness in training fire brigade personnel in use of the onsite fire truck is described in section 5.

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I 8612120343 861209 '

i PDR ADOCK 05000293 G PDR

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TABLE OF CONTENTS Page Introduction aad Inspection Scope ......................... 2 Background and Incident Description ....................... 2 Review of Licensee Response ............................... 3 Fire Water System Walkdown ............................... 3 Backup Fire Water System Evaluation . . . . . . . . . . . . . . . . . . . . . . . 4 Inspection Summary ........................................ 6

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! Exit Interview ............................................ 6 i-

Attachment I - Persons Contacted i

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DETAILS 1.0 Introduction and Inspection Scope During the morning of November 11,198ti, the licensee discovered that the normal fire water supply from the onsite fire water storage tanks had been inadvertently isolated. The licensee promptly notified the NRC via the Emergency Notification System (ENS) telephone and also notified the Pilgrim Senior Resident Inspector. The inspector discussed the incident later that day with the licensee's Chief Operating Engineer and observed operability checks of the electric and diesel fire pump This special inspection further reviewed loss of normal fire water supply. The inspection scope included the following:

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a walkdown of portions of the onsite fire water supply system

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a review of fire system procedures, drawings, and recent pump surveillance test results

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previous fire system maintenance

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interviews with operations, maintenance and fire protection personnel

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a demonstration of the techniques used to activate the backup fire suppression water syste .0 Background and Incident Description The station fire suppression system consists of two, 250,000 gallon fire water storage tanks which supply a common suction header for two main fire water pumps. These two pumps, one motor-driven and one diesel-driven,

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feed the fire suppression system for site process and auxiliary building On November 5,1986, the B fire water storage tank (FWST) was drained to facilitate repair of internal tank heating coils. A maintenance tagging request was implemented to isolate the B FWST from the fire pump suction header. Due to a drawing error (described in section 5 of this report)

the A tank supply valve was isolated instead of the B tank supply valve.

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Because the B FWST had been drained and the A FWST had been inadvertently l isolated, no suction source for the fire water pumps was available. This l condition existed from November 5 until discovery on November 1 Previously, on October 21, 1986, the diesel driven fire water pump was removed from service and isolated. Several outstanding maintenance I requests were worked, including replacement of a diesel engine auxiliary l drive belt and cooling water line. As a result of this ongoing work the l diesel driven pump was physically unavailable until November 10, 1986.

l Isolation tags were not removed from the diesel pump until November 11, l

1986. The electric motor-driven pump was available until the pump suction l source was isolated on November 5, 1986.

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. 3 On November 11, 1986, operations personnel connected a hose to the fire water system .for use in flushing the drained B FWST. When the hose supply was opened, fire water system pressure was relieved and auto start signals for both fire pumps were generated. Both pumps started as designed. No pump suction source existed because of the improper fire water system isolation. The nonlicensed operator at the scene noted the lack of. fire water supply pressure and heard the start of the diesel fire pump in the nearby screenhouse. :nvestigation by the operator identified zero fire pump discharge pressure. The operator removed both pumps from service within one or two minutes and notified the control roo .0 Review of Licensee Response The operations staff took prompt action to restore the correct valve lineup and perform testing required to prove diesel fire pump operabilit Testing of the motor-driven fire pump revealed the failure of pump packing. The packing was repaired the same day. Subsequent testing of the motor-driven pump indicated that the pump could supply only 1700 gpm; not the required 2000 gpm. This pump was declared inoperable but was

! aligned for service to provide additional backup flow. The diesel fire pump was not damaged during the inciden Capability to remove these pumps from service is provided only locally, not in the main control room. The inspectors noted that, had a pump auto start occurred without an operator in the immediate vicinity, the ability to secure the equipment prior to damage would have been reduced. Also, although the general fire procedure, 5.5.1, recommends that an operator monitor pump performance in the screenhouse dering a fire, this is not a l procedural requiremen l The inspectors' review of recent maintenance activities disclosed that about forty hot work permits for performance of activities that could initiate a fire (e.g. welding or grinding) were active on November 1 Four jobs were actually in progress and were halted at the Watch Engineer's direction after he was notified of the fire system proble The inspectors concluded that this level of hot work was consistent with that expected for a plant in a shutdown condition and constituted no unusually high fire ris .0 Fire Water System Walkdown The inspectors reviewed PNPS Procedure 2.2.25, Revision 16, Fire Water System, and Piping & Instrumentation Drawings (P&lD) M218, Rev. E10, Fire Protection System. The inspectors examined accessible portions of the fire water supply system including the fire water storage tanks (FWST),

fire pumps, and associated valves, piping, instrumentation and tags. The inspectors also noted that both the system line-up procedure ano the draw-ing were included in a recent engineering procedure and drawing update progra _ _ _ _ _ _ - - _ _ _

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.. 4 The drawing and procedure indicated that the A tank suction line enters in the diesel fire pump room, and the B tank suction line enters in the electric fire pump room. Review of actual equipment configuration revealed that the B tank suction line enters in the diesel fire pump room and the A tank suction line enters in the electric fire pump room. The isolation valves had local identification tags that were also incorrect, but were consistent with the drawing error. Therefore, the valve line-up performed on November 5, 1986 to isolate the B FWST was conducted in accordance with the drawing and procedure and the root cause of the inadvertent fire water system isolation was the drawing erro The inspector determined that the incorrect drawing is a violation of the Pilgrim Operating Licens Operating License section 3.f, Fire Protec-tion, requires the licensee to implement the administrative controls specified in section 6 of the NRC's Fire Protection Safety Evaluation (SE). Section 6 of the NRC Fire Protection SE states that quality assur-ance provisions will be established in accordance with the licensee's 10 CFR 50 Appendix B operational quality assurance program, and in accordance with NRC Branch Technical Position (BTP) 9.5-1. 10 CFR 50 Appendix B, Criterion V, and B P 9.5-1 Appendix A, Section C.2 require in part that activities be controlled by procedures and drawings. (50-243/86-38-01)

In addition, the licensee initiated an Engineering Service Request 86-531 to review the adequacy of fire protection system drawings. A preliminary walkdown of system piping was conducted to identify any additional problem The licensee stated that these walkdowns and reviews would be extended to include other select systems where similar undetected discrepancies could exis The effectiveness and results of these reviews will be evaluated during a future inspection (86-38-02).

5.0 Backup Fire Water System Evaluation The technical specifications require that the licensee be able to establish a backup fire water suppression system if the normal water supply system is unavailable. Licensee procedure 2.4.54, Loss of All Fire Suppression Pumps, is used to establish the backup supply. The procedure describes three backup methods: 1) direct connection of a Plymouth municipal fire hydrant to the Pilgrim plant firewater system, 2)

connection of the municipal system to the plant system through an onsite, licensee-owned pumping truck, or 3) cross connection of the water systems through a Plymouth municipal fire engine pumping uni Procedure 2.4.54 states that the Plymouth municipal water system can deliver up to 1,000 gpm at 20 psig to the station without additional pumping assistance. The licensee determined that this pressure is not high enough to force water to the upper levels of the plant, therefore, an additional pump must be used to increase the pressure to fight a fire on the upper floor __ ..

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. 5 The licensee has a written assistance agreement with the local municipal fire department and estimates (based on past drills) that municipal pumping equipment can be onsite in less than a half hour from initial notification. Such a drill with the local fire department was held on December 27, 198 In addition, on January 9,1986, a municipal fire truck was brought onsite for possible use during a fire in the onsite hydrogen storage facility. Documentation supporting the compatibility of licensee and municipal fire fighting equipment was provided to the inspecto Procedure 2.4.54 also requires that the licensee-owned fire truck be connected between the municipal supply and the station, and be held in standby (i.e., with the municipal supply isolated) if the normal station fire water supply is not availabl By procedure, a municipal truck would only be summoned to the site after a fire broke out. On November 12, 1986, the licensee walked through procedure 2.4.54 with the inspector and demonstrated the operation of the station fire truck with the municipal water supply. The following problems were noted during the demonstratio One of two municipal fire hydrants onsite could not be used as a water source. Maintenance request (MR) 86-33-309 was issued to repair the hydrant on October 1, 1986, about a month and a half earlier. No action had been taken to inspect or repair the hydran The licensee subsequently inspected the hydrant and verified that the hydrant valve was inoperable. At the end of this inspection, the licensee was preparing to excavate the area around the hydrant and repair the valve. The second hydrant was operable during the inspection and could have been used as a backup water supply. The inspector questioned the adequicy of licensee maintenance priorities, since loss of one hydrant eliminated redundancy in the backup fire water supply to the site. Concerns about the timeliness of main-tenance on fire protection equipment were previously discussed in NRC inspections 50-293/86-06 and 86-3 At the exit meeting, the licensee agreed to review priorities for fire protection equipment maintenanc Fire protection maintenance will be reviewed by the NRC during a future inspection (86-38-03).

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The onshift fire brigade leader, a licensed reactor operator, had not operated the station fire truck pumping unit in several years and could not operate it during the demonstration. The or. shift Watch Engineer successfully operated the pumping unit. However, the licensee had no formal, routine training program on the truck. At the exit meeting, the licensee agreed to review the training issu Subsequently, the licensee stated that actions would be taken to assure that at least one individual on each shift could operate the fire truc The inspector will review licensee actions in this regar (86-38-04)

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.. 6 Following the demonstration, the inspector noted that no formal surveil-lance program was in place for.the station fire truck pump unit. While not required by the NRC, the inspector noted that a surveillance program may be beneficial in the future if the truck is not routinely operate In summary, the licensee had a backup water supply system, consisting of the municipal water system and an onsite fire truck pump, available during the time . period that the normal site fire water supply was isolated. Weaknesses were noted in onsite fire truck training and fire protection equipment maintenance schedulin .0 Inspection Summary The normal fire water supply for Pilgrim was inadvertently valved out of service between November 5 and 11, 1986, because station drawing M218, incorrectly reversed the feeds for the supply piping from the two onsite fire water storage tank The supply piping is normally inaccessible and could not be easily verified by previous system walkdowns. Licensee actions were prompt and thorough on November 11, 1986, after the isolation problem was detected. During the time that the normal water supply was not available, a backup water supply could have been established if required to combat a fire. However, weaknesses were identified in por-tions of the backup water supply system, i.e., lack of operational training for the site fire truck and loss of a redundant municipal fire water supply with tended, in the aggregate, to substantially degrade the overall station readiness to respond to a significant fire even .0 Exit Interview At periodic intervals during the course of the inspection period, meetings were held with senior facility management to discuss the inspection scope and preliminary findings. No written material was given to the licensee that was not previously available to the publi . -

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Attachment I to Inspection Report 50-293/86-38 Persons Contacted

• A Pederson, Nuclear Operations Manager

• K. Roberts, Director Outage Management E. Ziemianski, Management Service Section Head S. Hudson, Operations Section Head P. Mastrangelo, Chief Operating Engineer R. Sherry, Chief Maintenance Engineer J. McEachern, Resource Protection and Control Group Leader E. Graham, Compliance and Administrative Group Leader R. Velez, Fire Protection Project Manager W. Sullivan, Fire Protection Engineer B. McCann, Maintenance Engineer

• Senior Licensee representative present at the exit meeting.

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