IR 05000293/1987039

Insp Rept 50-293/87-39 on 870831-0904.No Unacceptable Conditions Noted.Major Areas Inspected:Fire Protection & Prevention Program,Including Maint Work on Sys,Work on Degraded Barriers,Lers & Fire Fighting Capabilities

ML20236C344
Person / Time
Site:	Pilgrim
Issue date:	10/20/1987
From:	Eselgroth P, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236C318	List: IR 05000293/1987039 ML20236C315
References
50-293-87-39, NUDOCS 8710270106
Download: ML20236C344 (8)

Text

_-_- - -_ _ _

'

4 ....

'

i

'

, ,'

!

'

U.S;. NUCLEAR REGULATORY CORiISSION REGION I i

Report'N /87-39'

Docket N '

. 1 LicenseLNo. OPR-35 . Priority -

Category .

Licensee: Boston Edison Company 800 Boyleston Street Boston; Massachusetts 02199 Facility Name: Pilgrim Nuclear Station Inspection At: Plymouth, Massachusetts Inspection Conducted:. August 31 - September 4, 1987

Inspectors- /# o / I A. - Krasopouj4s,- Reactor Engineer, DRS- / da t'e r Approved by: y

, Chi 6f ( Acting),

/d/4/87 P . V. E s 19 date Plant Sys ms Section, DRS Inspection Summary: Inspection on' August 31 - September 4, 1987 (Report N /87-39)

Areas-Inspected: .R'outine unannounced inspection.of ths fire protection /

prevention program including a review of: the licensee's efforts-to complete-the maintenance' work outstanding on fire protection systems; efforts to

. complete work.on degraded barriers; installation, operability and maintenance of fire protection systems; fire protection LERs; fire fighting capabilities; fire protection equipment maintenance, inspection and tests and a facility tou Results: No unacceptable conditions were identifie ,G PDR ADOCK 050 {

L__--____- ..

__. __ _ _ _ . _ _ _ _ . .

..- .

.

I

,,

~ '

.,.

.

.

DETAILS 1.0 Persons Contacted 1.1 Boston Edison Company (BECo)

• K P. Roberts, Nuclear Operating Manager

• R. A. Ledgett, Special. Assistant to'Sr. Vice President, Nuclear

• P. J. Hamilton, Compliance Management, Group Leade *R. E. Grazio, Field Engineering Section Manager

• R. Wozniak, Fire Protection Group Leader

• M. Sullivan, Sr. Fire Protection Engineer

• R. Velez, Project Manager

• R. V. Fairbank, Licensing and Analysis Section Manager 1.2 Nuclear Regulatory Commission (NRC)

J. Lyash, Resident Inspector T. J. Kim, Resident Inspector

• Denotes those present at exit intervie .0 Followup of Previous Inspection Findings

.

_(Closed) Unresolved Item (86-36-01) Unimplemented Maintenance Work on

. Degraded Fire Protection Equipment and Excessive Reliance on Fire Watches ,

l The NRC in a review of the Operability and Maintenance of fire protection (FP) systems determined that the licensee did not diligently perform the maintenance and repair work on fire protection equipment. This assessment was made on the basis of a review of the maintenance request (MR) list which identified about -300 unimplemented maintenance requests on fire protection equipment. Some MRs were outstanding since 1983. The licensee in a management meeting with the NRC acknowledged that a problem with maintenance exists and committed to correct it. During this inspection, the inspector reviewed the maintenance request list and determined that only 37 MRs of relatively minor safety significance on fire protection equipment are still outstandin :

The inspector also randomly examined some of the maintenance work per-formed on varicus fire protection systems and did not identify any unacceptable conditions. Since the backlog of MR's has been significantly

'

reduced and the repair work performed appears to be adequate, this item is resolve ,

With regard to the use of fire watches, the licensee is still relying excessively on fire watches as an interim compensatory measure for de-graded fire barrier _ _ _ _ _ - - _

< _ . _ _

. .

.

.

. _,

j

'

- -

r l

'

,

7 l d, l o l _ A' T ~7 s 3; oM 0

.. p t M

, f , . dL l

, <> s ;)

l' ,f( ,

The barrier issue is still an unresolved concern with thelc{RC and is addressed as such in the write-up of the open unresolved it'eg 86-36-02,

4 'i n in this repor q

$;)>

'(Closed)'Unrosolved Item (86-36-05) Iidf;'ective Corfective Actions to QA Audit find:iah .,

~I i

. F

.The NRC identified. deficiencies jn the licensee's fire protection program

/, ,

which were similar to ones that the licensee's own QA audits had previous-' '

ly identifie The NRC then questioned the effectiveness of the qdrrective and preventive actions taken by the licensee in response to the .QAs.udit findings. TM s area was reviewed during NRC inspect k 87-38 an'd found to i be satisfactory. This item is administratively cbse ,

s

,

y <,

{0 pen) Unresolved item (86-36-02) Licensee Event Reports (LERs) Identify- <

Deficiencies in Fire Barriers '\< J

{ ., t .,

The licensee in various'LERs identified that someI fire ba>riers were

. inoperable. The reasons. for declaring the barriers inoperable were that~ ~ "

either proper surveillance did not take place or that the irytallatior, i records could not be found, or the barriers appeared degraced to some degree, or that the necessary fire test records for penetratha seals could not be found. The licenste established a program to evaluat9<the barriers, and rest' ore the degraded barriers to' operable statu .g 1'

,

,

.

/ No q

. ,

,

'This program and the actions taken by the licgnsee tre as foll63s:

The plant is. divided into eleven (11) fire arias setiscated by ' fire walls and floors. Subsequent to identification of the fife barriers; concern, the licensee performed a survey of all the barrierrp(,approximately 300) to verify the barrier adequac By performing this survey, the licensee also satisfied. the Fire Barrier , y Technical Specification (TS) surveillance requirements. DuringWhis . 1 survey, the licensee made-sketchas of each fire barrief and o.n tne sketcPis -

identified all of the barrier penetrations to facilit4WHfre ?

'

,

surveillance, The survey determined that the barriers havh approxima,te % ,

5200 penetrations' As a result of this survey, the licensee determin&d

.

that about 3,900 of there. penetrations did not meet the acceptance criteri i i

The following table sunmarfiesthestafusofthebd.c)4hlaqthetimeof the inspection: ' ,\ , )( \

/

f i

-

s

{

Ji (

I l

s

.f

l~ /

l .p L__________.__

ra p;q y

.' w ,

9' ._,

g; j is, 4;y 3y E

%

.

'

.

..

4; m .

~

g.; t cr4

,f < >

$y

, _ ,

.

, Yhhh ;p ' DO , , 4l '

l l % &, O*7"x $.o

,

-

,

,

,

ps .,

e Nol...ofbhre' areas' '1 b. s 'No. of barriers . 300 No.Lof' penetrations 5,200-

'No; of degraded. penetrations- .

3,900

No. ofLpenetration seals' that need minor repairs

3,000

'?: No'.7of :pepe#ation seals that need 'to be' replaced . 900;

.i;!

"'

• All; numbers are~ approximat ,

Of the 900_ seals 'needing . replacement, the licensee is proceeding with

.y . replacement of 550 and conducting evaluations of the'need for 350 of the:

G M seal >

h~f

.

(, .With regard' to the'eva> Nations, the inspector stated that because of the _ Lextensive review time' rnuired and because a' large number'of these evalua-fyv tions.were not performed atlthe time of the inspection', the' licensee must s

% f'

~

send these evaluations to'the Region approximately a' month before restart, h

S '.

so that'the" adequacy of tMe evaluations can be verified by an.in-hous ' regional review..'The licensee agreed. Ti.e inspector' also~ noted the L

"

following conditions withi. regard to barrier adequacy that need to be re-

'

. solved with~the'NRC/NRC prior to: restart:

'

!, 0 A)7 The licensee w)s granted aniexemption by NRR~ from the 10 CFR 50 lP- Append k R regbiremen.t.to provide a fixed' suppression system in the control room; The granting of the exemption was partly based on the-

..licensk assertion that the control room:is separated from high risk

~

'j

! ;iyg t , areas by three hour fire rated barriers. . However,.the licensee in M . \"

Ltheirgcurrent' survey of'the fire barriers determined that the floor separating the control room from-the cable' spreading room-is'not a

.three hour-rated fire barrier because'it contains penetrations 1that do' not have a: fire- ratin t The;: licensee performed an evaluation of this condition and concluded that'since a fire in either the control room or the cable spreading q

'

room will require use of the alternate shutdown methods, the floor- I p , need not' t'e fi re ' rated. The inspector informed the licensee that !

k since this barrier formed the basis upon which an exemption request j D' was gra ced, the matter must be resolved with NR ]

$

b'

.. , >>

The NRC in the Branch Teennical Po.ution CMEB 9.5-1 requires that

)

B)

@ " . . . . . . . Openings i.nside conduit larger than four (4) inches in

.

diameter should be sealed at the fire barrier penetration. Openings inside' conduit four (4) in:hes"or lens in diameter should be sealed b on each side of the fire barrier and sealed either at both ends or at the fire barrier with non-combustible material to prevent the passage

_ .

of smoke;and hot gases."

Wlp, y

( i R

,

f i

,

udMM M - -. .

_ - . (

o -

,

t .  ; /, -

,

t

.j

/

.

' -

x ..g .

.s

,,p

,

e

- yf

, i i

}. '

f

'l,.

',

5 , i N 4 '

k 4 't J i

I '

, c ]

>

The licensee in Nuclear Engineering Dep'artment Work' Instruction (-

(NEDWI) 352 autlines the position that for conduits extending three 1 (3) feet frodthe fire. barrier a sm:. a and hot- gas seal need not be <'

inst $ ed.'" \U{

,

! '

"

. The inspedtgr informed the . licensee. that .;f che this, position is not . :f in a~greement with the BTP or the guidance' contained in Generic

,

'

Letter 86-16 .the issue must be resolved yith WWR prior to restar ,Oj q

3.0 Background and Scope of Inspection ' '

)

"

The NRC in variotis recent inspections identified deficiencies in the f licensee's fire ,prdtection program which the licensee committed to address and correct prior to restart. The specific deficiencies were in the areas-of the fire brigade training, the maintenance of fire barriers, and the maintenance gf, fire protection equipment and fire protection staffing.

'j The purpose.of this inspection was to evaluate the licensee's. corrective actions in'these areas *and inspect other portions of the fire protection program to vdrify that the licensee is maintaining this progryn,in accor- 4 dance with the app Ucable licensing commitments and regulatory require-ment The docUme6ts reviewed, the scope of. review and the inspectiorf ,

'

findirgs for each area of.~the programs reviewed are described in the l following rection I/

'

3.1 Review of Maintenance to F Pe Protection Equipment and Fire

' Barrier Reports #

• ,/ */.

)

The inspector reviewed the Maintenance Request List as described in Section 2'c f this report and observed the condition of fire protection

equipment where repairs were 5ade to've,rify when possible the quality ofsthe work. Similarly, the inspedtor reviewed repairs made to the fD;e barriers. No unacceptable b mditions were identified although two issues requiring resolution with NRR-whe identified as described in Section 2.0 of the repor y j

, .

3.2 Review of Fire Fighting Capabilities ,

l

) ,

The psoector reviewed the training given to the fire fighters, ,

i conouce,e'd interviews with fire fighters and the fire fighters' l

'/ h.ctructo,r, inspected fire fighting gear, % viewed individual fire

, 4f'ghWr $ raining files, miscellaneous lesg plans and drills to , /

'

,3 ,

'

waluate the licensee's onsite capabilit3 tt fight fire , h, j

'

,#

/ ,

l Jhe scope of, the review was to: <

/

s verify that all personnel designated to take part in fire '

(emergenciesaretrainedintheseactionsandintheoverall -

'

{,}ir,ergencyplan; , ( ,

I

,

r, j

+

>  ; i

, s 1

,  ;. !

,

I I I d

(

( /' ,t 4

\l <

fB 9;yg c,n , ,g'

% N l ,

'

[,

{ "

-

b., : verify that the licensee has establishe'd 'a training. program ithat: ensures the capability-to fight potential. fires; l # . verify.that the ~ licensee's training program-consists of initial

.

classroom instruction.followed byl periodic classroom

,

-

a instructions, fire fighting practices and fire drills;.

f fd; . verify that the licensee had developed ~ fire fighting' strategies for. fires in all" safety related' areas 'and in areas in which a f . fire could present a. hazard to~ safety related equipment; and, ti

[ ' v'erify that the.' fire fighters -can fight plant' fires with the l' -equipment availabl No. unacceptable conditions were identifie 'I The' licensee, in' explaining the fire fighter training p'rogram, stated

'that a' state certified instructor has been recently hired to be on site to. conduct the. brigade training. Prior to joining the BECO L ~ organization,;the individual was an instructor at the Massachusetts Fire Academy and a. lieutenant.in the local fire department. This addition enhances the plant fire protection progra , 1The training records review identified that the licensee has about

.

80 fire fighters wh,o have completed all required training and they are eligible'to be members of the fire brigad i 3.3 Fire Protection program Staffing The licensee's current fire protection engineering activities are p'

'

numerous resulting from F.P. system upgrade modifications, mainte-nance and repair activities and efforts to achieve full compliance-with the. regulatory requirements, namely 10 CFR 50, Appendix Because of the magnitude of the F.P. work, the inspector reviewed the site engineering and corporate staffing levels that support this <

effort.

a '

M -

The licensee makes extensive use of outside consultants in the area to supplement and assist their own engineering staff. The

'

corporate Appendix R effort utilizes eighteen (18) "outside con-lsultants", engineers and technician ', '

The fire protection activities at the site are carried out by the

'

W site fire protection group consisting of six persons, engineers and i

j

,._ aj technicians.- Four of these positions are currently occuppied by

%1 . qualified contract (temporary) personnel, but the licensee stated ,

33 d

'

that these positions are authorized to be permanent and the hiring process for these positions has begu I O

l'% -

o- I

-_ = _ _ _ _ _ .

- . _ - _ _ _ _ _ _ _-_-__

, .

.. ..

. .

'

, .

!/ 4 ,

.' 7 1 ,

+ ,

~

The' inspector did:not identify any unacceptable conditions with the

staffing levels ~or personnel qualification .- 3. 4 Review'of. Equipment Maintenance Inspection and Tests

'

The. inspector reviewed the following documents.to. determine whether

!,

the licenseelis implementing the maintenance inspection and< testing-requirements of the plant fire _ protection equipment:

Procedure

"

8.B;19A, Fire' protection equipment. inspection

'" A.6A, ~ Fire extinguisher quick check monthly inspection 8.B.20A Monthly. fire protection checklist

.

,

"

8.B' 1C, Fire pump shutoff' valve position inspection

.

checklist'

Procedure .8.B.1A,. Weekly fire pump. test checklist

'"-

. ..

8.B.3,1A, Interior fire hose stations and cabinets monthly

.

inspection checklist

' Procedure

"

8.B.21A,' Emergency lighting unit tes .

>

18.B.4E, Smoke and heat detector supervised circuit l checklist Procedure 8.B.22Ac Halon system visual inspection eThe above documents were reviewed to verify compliance with the and'other established procedure 'i

No unacceptable conditions were identified, q

3.5 Facility To'ur The inspector toured the plant and reviewed miscellaneous fire i

~

j suppression and fire detection systems. This included fire pumps, .]

fire water piping and distribution systems, post indicator valves, j

. hydrants and the c:ontents of hose houses. The inspector also toured 4 accessible vital and non-vital plant areas and examined fire detec- )

' tion and alarm systems, automatic'and manual fixed suppression

- systems, interior hose stations, fire barrier penetration seals, and ] i fire doors. The inspector observed general plant housekeeping condition and randomly checked tags or portable extinguishers-for evidence of periodic inspections. No deterioration of equipment was noted. The inspection tags attached to extinguishers indicated that monthly inspections were performed. The tour included a walkdown of the Halon Test procedure in the Cable Spreading Room to assess pro-cedure feasibility and accuracy. The plant tour identified one minor deficienc The inspector observed that the spanner wrench of hose station TB-28-06 was missing. This is believed to be an isolated incident with no safety significanc No other unacceptable conditions were identifie _ _ - _ _ _ - _ _ _ _ _ _ _ _

__ _ _ _ _ _ _ _ _ _ _ - _ -

. .- .

.

j l 1 l

l i

4,0 Unresolved Items l '

Unresolved items are matters about which more information is required to I ascertain whether they are acceptable items, violations or deviation One unresolved item updated during this inspection is discussed in Section .0 Exit Interview The inspector met with licensee representatives (see Section 1.0 for attendees) at the conclusion of the inspection on September 3, 1987. The inspector summarized the scope and findings of the inspection at that  ;

time. The inspector also confirmed with the licensee that the report '

will not contain any proprietary information. The licensee agreed that the inspection report may be placed in the Public Document Room without prior licensee review for proprietary information (10 CFR 2.790).

At no time during this inspection was written material provided to the licensee by the inspecto l I

)

l

!

I

.

__.:___-_. _-