IR 05000305/1980024
| ML19351F969 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 12/18/1980 |
| From: | Baker K, Grobe J, Nelson R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML111740395 | List: |
| References | |
| 50-305-80-24, NUDOCS 8102200623 | |
| Download: ML19351F969 (15) | |
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O U.S. NUCLEAR REGULATORY C0?!!!1SSION
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OFFICE OF INSPECTION AND ENFORCEt1ENT
REGION III
Report No. 50-305/80-24 Docket No. 50-305 License No. DPR-43 Licensee: Wisconsin Public Service Corporation Post Office Box 1200 Green Bay, WI $4305
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Facility Name:
Kewaunee Nuclear Power Plant Inspection At:
Kewaunee, WI Inspection Conducted. October 20-23 and November 12-14, 1980 Inspectors:
J. A. Grobe
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elson
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Approved By:
er, Thief
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Nuclear Support Section 2 Inspection Summary Inspection on OctoLer 20-23 and November 11-14, 1980 (Report No. 50-305/80-24)
Areas Inspected: Routine, announced inspection to review the implementation of the licensee's program for fire protection and prevention irr' 2 ding review of administrative procedures to control ignition sources and coiaustible materials, fire brigade and fire team training and drills, fire emergency and fire fighting procedures, manual fire fighting equipment, automatic fire suppression systems, general employee and contractor training, fire inspections, QA audits, and Technical Specification surveillance; and review the implementa-tion of the licensee's program for housekeeping and cleanliness including administrative controls for general housekeeping and procedures for cleanli-
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ness controls during work activities. Tne inspection invo?ved a total of 42 inspector-hours onsite by one region based NRC inspector including zero inspector-hours onsite during off-shifts.
Results: Of the eleven areas inspected, no apparent items of noncompliance were identified in ten areas; one apparent item of noncompliance was identified in one area (failure to iglement ignition source control procedures-Ti.ragraph 2).
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DETAILS 1.
Persons Contacted
- +D. Hintz, Plant Manager
- C. Steinhardt, Operations Superintendan'.
- J. Richmond, Plant Services Superintencant R. Lang, Maintenance Superintendant W. Truttmann, Assistant Operations Superintendant
- +M. Marchi, Technical Supervisor
- F. Stanaszak, Training Supervisor / Fire Marshall J. Tills, Maintenance Supervisor M. Reinhart, Health Physics Supervisor A. Huege, Quality Control Supervisor
- C. Smoker, Associate Engineer C. Long, Radiation Protection Lead Man
+D. Ristau, Nuclear Technical Review Supervisor The inspector also contacted other personnel in the corporate cianagement, operations, maintenance, quality assurance and health physics department.
- Indicates those persons present at the exit interview on October 23, 1980.
+ Indicates those persons present at the exit interview on Ncvember 14, 1980.
2.
Administrative Control of Ignition Sources The inspector reviewed Kewaunee Administrative Cont rol Directive (ACD)
10.6-Revision C, titled Control of Ignition Sources.
This document out-lines acceptable controls for using ignition sciurces except that there is no procedural requirement for the fire watch to remain in the work area after the work is completed to detect any smoldering fires resulting from the work. This is not in accordance with the Kewaunee Nuclear Power Plant Fire Protection Program Analysis, Part 5.5: NFPA Standards Applicable to Kewaunee Plant. This part states that NFPA No. 51B-1977:
Cutting and Welding Processes is applicable to Kewaunee.
NFPA No. 51B-1977, Para-graph 434 reads as follows:
434. A fire watch shall be maintained for at least one half hour after completion of cutting or welding operations to detect and extinguish possible smoldering fires.
The inspector conducted an interview with a maintenance welder. The inter-view revealed a lack of knovledge of Part 5.2.1 and 5.2.2 of ACD 10.6 concerning moving and/or protecting combustible materials below and within a 35 foct radius of the ignition source work area. He indicated that he would protect approximately a 10 foot radius area. The inspector did not have an1 opportunity to observe these practices.
During a plant tour by the inspector, a contractor was observed grinding within twenty feet of the generator hydrogen seal oil unit.
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There was no fire watch in the area. The inspector questioned the contractor concerning this situation and he indicated that he was not required to have a fire watch; his clear face shield permitted him to be his own fire watch. This is not a safety related area but provides an example of the lack of implementation of ACD 10.6 in that this procedure applies to all ignition source work in the plant.
The inspector reviewed three recent work requests involving ignition source vork. One work request (Nc. 15362) involved grinding work in a safety related area (containment). 15e requirement to have a fire watch was not indicated on the Ignition Corsrol Sheet for all three work re-quests. This ommission is not in accordance with ACD 10.6 Part 5.2 which reads, in part, as follows:
5.0 Procedure 5.2 The fire hazards review and completion of the Ignition Control Sheet shall insure the following:
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A fire watch is required whenever hot slag or sparks could be generated by the cutting, grinding, or welding operation.
This represents noncompliance with Technical Specification requirements, Pa t. 6.8.1, for implementing written procedures. Part 6.8.1 reads as follows:
6.8 Procedures 6.8.1 Written procedures and administrative policies shall be established, implemented and maintained that meet the re-quirements and recommendations of Section 5.1 and S.3 of ANSI N18.7-1972.
ANSI N18.7-1972 Section 5.1.6.1 reads, in part, as follows:
... Maintenance that can affect the performance of safety related equipment shall be properly preplanned and performed in accordance with written procedures...
The inspector identified, durink a plant tour, three safety-related areas where smoking had taken place.
Cigarette butts were found in the Cardox
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System Room, the IA Diesel Generator Room and the IB Diesel Generator Room.
l Only two safety-related areas were posted with "No Smoking" signs; the Cable Spreading Room and inside the control panels in the Control Room.
No " Smoking Permitted" arc:e were designated in safety-related areas.
These observations are not in accordance with facility operating license l
No. DPR-43, Amendment 23, Part 3.1.25 of the Fire Protection Safety Evaluation Report (FPSER), concerning administrative controls, which reads, in part, as follows:
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3.1.25 Administrative Control Changes Procedures are being developed or changed to incorporate controls over... ignition sources...
Part 3.1.25 is expanded and clarified by Paragraph 4.0 in Attachment No. 4 to the letter from the licensee dated May 15, 1978 which reads, in part, as folfows:
Smcking should be prohibited in safety-related areas, except where " Smoking Permitted" areas have been specifically designated... These areas should be identi-fied by "No Smoking" signs.
The licensee's response to this position was the following:
These controls have been established of the Kewaunee Plant.
Temporary rule 10 CFR 50.48 promulgated October 29, 1980 suspended com-pliance dates contained in schedules imposed by license conditions relative to fire protection. This temporary rule will be superseded by 10 CFR 50.48 which will become effective February 19, 1981. At that time, if this situation were not corrected, this could become an item of no compliance.
3.
Administrative Control of Combustible Materials The inspectcr reviewed the Wisconsin Public Service Corporation (WPS)
Safety Rules Book Chapters 135 - Flammable Liquids, 242 - Housekeeping,and 507 - Fire Control with respect to combustible materials control. These general guidelines are written for all WPS facilities; 41fice, fossil and nuclear. Kewaunee has no site specific ACD's which apply to housekeeping-or combustible materials control. There is no document 'that designates areas shere combustibles may or may not be stored. Tht Kewaunee Nuclear r ower Plant Fire Portection Program Analysis was prepared by WPS and contains an in-depth analysis of the combustible loadings and suppression capabilities in each plant safety-related area. Transient combustible loadings could invalidate the fire hazards analysis and present a situation where insufficient fire suppression capabilities exist.
Considering the potential at a nuclear power plant for adversely affecting public health and safety, when compared to other facilities, WPS has taken an incongruous attitude toward administrative controls of combustible materials at Kevaunee.
Discussion with the Resident Inspector indicated that in August the Resident Inspector and WPS corporate fire protection specialist identified by plant tour that extensive amounts of combustible materials being stored for excessive periods of time in improper locations. The licensee respond-ed by performing an inspection of the 633 level in the Auxilliary Building.
This effort identified and removed an extensive-list of Class I, II, and III flammable and combustible liquids, flammable gas cylinders and other flammable materials.
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The inspector veri' ed by plant tour that the licensee has not taken s
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corrective.actios ro establish and implement effective controls of combustible matetrals.
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The followir.g significant levels of combustible materials were identified during a p'
mour in these safety related areas:
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Spent Fuel Pool Area Erected untreated wood scaffalding.
Seven containers of flammabe lubricant.
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Control Room Two wooden work benches inside control panel cabinets.
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Cable Spreading Room
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Cardboard box full of flammable packing.
Overfull trash barrel containing combustible materials.
Empty wooden cable spool.
These observations are not in accordance with facility operating license No. DPR-43, Amendment 23, Part 3.1.25 of the Fire Protection Safety Evaluation Report concerning administrative controls which reads, in part, as follows:
3.1.25 Administrative Control Changes Procedures are being developed or changed to tucorporate controls over combustible materials...
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Part 3.1.25 is expanded and clarified in Paragraph A, in Attach-ment No. 3 to the letter from the licensee dated May 15, 1978 which reads, in part, as follows:
... regular plant tours by the Plant Superintendant, Department Heads, Group Supervisors, Shif t Supervisors, Fire Marshall and Operations Staff ensure that com-
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bustibles are stored in the proper'lo(ations...
There are no administrative procedures identifing the proper locations f or-combustible materials. Also there is ru> ausurance of systematic inspection of all areas of the plant for fire hazards.
Temporary rule 10 CFR 50.48 promulgated October 29,_1980 suspended com-
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pliance dates contained in schedules imposed by license conditions relative to fire protection. This temporary rule will be superseded by 10 CFR 50.48 which will become effective February 19, 1981..At that time, if this situation were not corrected, this could become an item of noncompliance.
No items of noncompliance were identified in their area.
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4.
Fire Brigade and Fire Team Training and Drills the inspector reviewed ACD 13.1-Training Records and ACD 13.2 Revision B - Fire Brigade Training. ACD 13.1 adequately defines responsibilities for fire brigade / fire team training and references ACL 13.2 for specific fire trainii3 requirements.
i The inspector reviewed the basi ~ fire fighting training outline used for
initial training and qua 4
!y retraining. The quarterly retraining repeats the entire training curricula over a two year period. This
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training contains the fundamentals of fire fighting and some nuclear plant
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specific tg Jes. The only apparent weakness in the training would be a lack of instr.ction in the area of toxic, corrosive and radioactive by-products of fires in nuclear plants. ACD 13.2 specifies adequate require-ments for quarterly training but does not i'dicate that new fire brigade / fire team members are required to au.end the original in-depth training.
The inspector reviewed the licensees program for fire drills and fire fighting practice sessions. ACD 13.2, Part 5.2 specifies that four drills should be conducted each year with at least one drill per year on the backshifts. There is no specification for yearly practice sessions. The inspector interviewed the Fire Marshall a..d was informed that Kewaunee has four drills per year on the day shift. These drills involve whatever fire fighters are onsite at the time of the drill. Drills are not held for individual fire brigades so they can practice as a team.
The inspector randomly selected ten precent of the fire brigade / fire team members and reviewed their training records. Of those reviewed, all had attended original tranir.g, but one-third had missed one quarterly drill in the previous year and another one-third had missed two quarterly drills in the previous twelve months.
These requirements and observations are not in accordance with facility-operating license No. DPR-43, Amendment 23, Part 3.1.25 of the Fire Protection Safety Evaluation Report conceraing administrative controls which reads, in part, as follows:
3.1.25 Administrative Control Changes Procedures are being developed or changed to incorporate controls over.. fire brigade staffing and training...
Part 3.1.25 is explained and clarified in Pargaraph 3.0(e) of Attachment No. 2 to the letter from the licensee dated May 15, 1978 which reads as follows:
3.0 Drills e.
The drills should be performed at regular intervals but not to exceed 3 months f;r each fire brigade. At least one drill per-6-
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year should be performed on a "back shif t" for each fire brigade. A sufficient number of these drills, not less than one for each fire brigade per year, shall be unannounced, to determine the fire readiness of the plant
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fire brigade leader, brigade, fire protection systems and equipment.
The licensee's response to this position was the following:
r The Kewaunee Nuclear Power Plant training program includes or will be updated to include these items, except that drills for each fire brigade
will be held once every 3 months (125%), to allow flexibility for possible scheduling conflicts.
Temporary rule 10 CFR 50.48 promulgated October 29, 1980 suspended com-pliance dates contained in schedules imposed by license conditions relative to fire protection. This temporary rule will be superseded by 10 CFR 50.48 which will become effective February 19, 1981. At that time, if this situation were not corrected, this could become an item of noncompliance.
No items of noncompliance were identified in this area.
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5.
Fire Emergency and Fire Fighting Procedures The inspector reviewed ACD 12.1 Revision E - Plant Emergency Organization, t.CD 12.2 Revision D - Fire Emergency and the Kewaunee Emergency plan. The emergency response procedures are acceptable in all respects except two:
(1) There is confusion in the documents between the shift " fire brigade" and the plant " fire team".
These documents should be made clear and consistant with respect to thes.e groups of fire fighters.
(2) There is a contradiction betweea ACD 12.2, Part 5.3.4 and the.
Kewaunee Emergency Plan, Paragraph D.2.
The ACD indicates that the fire brigade should report to the Welding Shop for equipment while the Emergency Plan indicates that the Health Physics Office is the
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proper assembly area for the brigade. This point should be clarified and procedures updated.
The inspector interviewed The Fire Marshall concerning fire fighting procedures or strategies..The Fire Marshall stated that they presently had no procedures, but there were provisions in the calendar year'1981 budget to contract out this work. Fire fighting strategies for variobs areas are a topic of discussion during the quarterly training sessions, but written strategies are not available onsite.
This situation is not in accordance wita the facility operating license No. DPR-43, Amendment 23, Part 3.1.25 or the Fire Protection Safety-Evaluation Report which reads, in part, as follows:
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3.1.25 Administrative Control Changes Procedures are being developed or changed to incorporate controls over... fire fighting procedures...
Part 3.1.25 is expanded and clarified in Paragaph PA7 of the letter from the licensee dated August 4,1978 which reads, in part, as follows:
General [ fire fighting] strategies will be written for safety-related areas where significant con-centrations of cables and liquids combustibles exist.
Temporary rule 10 CFR 50.48 promulgated October 29, 1980 suspended compliance dates contained in schedules imposed by license conditions relative to fire protection. This temporary rule will be superseded by 10 CFR 50.48 which will become effective February 19, 1981. At that time, if this situation were not corrected, this could become item of noncompliance.
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No items of noncompliance were identified in this area.
6.
Manual Fire Fighting Equipment The inspector reviewed the manual fire fighting equipment available for use by the fire brigade / fire team. The equipment includes turnout coats, boots, sealed-beam hand-held lights, self-contained breathing apparatus, portable smoke exhausters, fire extinguishers and hose and standpipe stations.
All of the manual fire fighting equipment is operable and available for use except the fire extinguishers and self-contained breath-ing apparatus.
Kewaunee submits to the commitments of National Fire Protection Association (NFPA) Standard No. 10-1975 - Portable Fire Extinguishers in the Kewaunee Nuclear Power Plant Fire Protection Program Analysis Part 5.5 and the FPSER Part 4.3.3.
The licensee has provided portable fire extinguishers throughout the plant and performs yearly preventative maintenance procedures for the fire ex-tinguishers but does not do monthly inspections as required in the NFPA standard.
This practice is not in accordance with NFPA No. 10-1975 Part 4-3.1 which reads:
4-3 Inspection 4-3.1 Frequency. Extinguishers shall be inspected monthly, or at more frequent intervals when circumstances require.
Also Appendix B of NFPA No. 10-1975 recommends markings to indicate extinguisher spicability. Kewaunee does not use these markings for fire fighting suitability on their extinguishers or at the extinguisher
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locations. Some extinguishers have small markings on their label plates.
In most areas of the plant, two different types of extinguishers are provided at each location.
It could be confusing to a fire fighter in an emergency situation when trying to decide which extinguisher to use.
Kewaunee is presently using two types of self-contained breathing apparatus (SCBA):
(1) A full-face, pressure-demand, open-circuit device using compressed air cylinders (MSA Air Pack) and (2) A full-face, closed-circuit, rebreather, device using chemical cartridges (CHEM 0X).
Both devices are NIOSH (National Institute of Occupational Safety and Health)
approved. The open circuit device is positive pressure, but the chemical cartridge rebreather does not satisfy positive pressure requirements. The following table shows the number of SCBA units available onsite, i
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Service Life No. Masks Service Life of No. Cartridges / Bottles Available Onsite Available Cartridge / Bottle Available Onsite Per Mask Type Onsite (Minuter:)
(flours)
Open-Circuit Positive Pressure
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1.3 (MSA Air Pack)
Closed-Circuit Rebreather
45 250
(CIIEM0X)
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l The Kewaunee Nuclear Power Plant Fire Portection Program Analysis l
Parts 6.3 and 6.4 submits that the SCBA equipment available onsite I
complies with the requirements of the Standard Review Plan 9.5.1.
Standard Review Plan 9.5.1, Appendix A, Part D.4(h) reads, in part, as follows:
(h) Self-contained breathing apparatus, using full-face positive pressure masks, approved by NIOSH should be provided... Service or operating life should be a minimum of one half hour... At least two extra air bottles should be located onsite for each self-contained breathing unit.
In addition, an onsite six hout supply of reserve air should be proviaed [for each mask].
This position is clarified in the letter from the licensee dated May 26, 1978; Enclosure 2 Paragraph P5 where the licensee responds as follows:
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A minimum of ten emergency air masks are available for _the fi e brigade. A1 hour air supply is available at each mask and an additional six hour supply is available onsite for each mat k.
The CHEM 0X closed-circuit devices do not satisfy these requirements be-cause they do not operate with positive pressure. The MSA Air Pack open-circuit devices do not satisfy these requirements because of insufficient reserve air supply available onsite.
Kewaunee recently purchased twelve Biomarine Biopack-60 positive pressure rebreather units.
If the licensee provides sufficient reserve air supply and performs fit tests for these devices on the plant fire fighters, these will satisfy the requirements of SRP 9.5.1.
Until that time, the licensee
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is not in accordance with their commitments.
No items of noncompliance were identified in this area.
7.
Automatic Fire Suppression Systems The inspector examizad the automatic suppression and detection systems, fire barriers and cable penetration seals for operability. The automatic fire suppression and detection systems appeared to be operational. The detection systems have been modified to.be electrical-ly supervised, but the prints for the. system have yet to be updated. The
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indication panels were operational. The fire suppression. system valves
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l located in the Screen House /Firepump area and Cardox room that are critical to operation of the fire suppression systems in safety-related
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areas were checked for proper line up.
Two valves were identified that were critical to fire water supply for safety-related areas that were not supervised with wire seals. These were the firepump 1A and IB
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discharge valves numbers FP-2A and FP-2B.
This observation is not in accordance with facility operating license No. DPR-43, Amendment 23, Part 3.1.21 of the Fire Protection Safety Evaluation Report which reads-as follows:
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3.1.21 Valve Supervision All valves in the fire water system that protect safety-related areas will be provided with tamper indicating seals (4.3.1.3).
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Temporary rule 10 CFR 30.48 pr - ';ated October 29, 1980 suspended i
compliance dates contained in.cnedules imposed by license conditions
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relative to fire protection. This temporary rule will be superseded by 10 CFR 50.48 which will become effective February 19, 1981. At that time, if this situation were not corrected, this could become an item of noncompliance.
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During a plant tour the inspector examined many of the cable penetration
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fire barriers and they were found to be in good condition excep' in A penetration fire barrier in the turbine driven auxtiliary one area.
feedwater pump area was found to have cracked and peeling fire retardant coating. The maintenance supervisor was inter'iewed concerning main-
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tenance involving cable penetration seals. He indicated that he was the
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responsible individual to determine when a penettition seal required i
maintence work and that he would examine this barrier. He also indicated that when maintenance or modification work involved removing a penetration barrier and the work would not be completed in one shilt, the maintenance
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men are instructed to replace the fire resistant Cera-wool in the penetra-tion and continue work on the following day. This would not constitute an intact fire barrier and if a fire watch was not instituted, this would be a violation of Technical Specification 3.15.f which reads as follow:
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Fenetration rire Barriers
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j A;1 penetration fire barriers protecting safety-related areas shall *ue intact at all times, or a fire watch on at least one
side of the affected penetration will be established withing i
one hour.
This practice was not observed by the inspector.
Also during a plant tour, the inspector examined many fire doors thoughout the plant. One fire door, Door No. 45, between'the two battery rooms was found to be open due to a broken latch and not electrically supervised.
This is not in accordance with the NRC position contained in Standard Review Plan 9.5.1, Appendix A, Part.D.I.(j) which' reads as follows:
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General Guidelines for Plant Protection 1.
Building Design (j)... separate fire areas should have minimum fire rating
of three hours... Door openings should be' protected with equivalent rated doors, franes-and hardware... should be closed and locked or alarmed with alarm and annunciation in the ccatrol room...
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The licensee indicated that they would fix the latch and supervise this door.
No items on noncompliance were identified in this area.
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8.
General Employee and Contractor Training The inspector reviewed the plants program for general employee fire training. All plant personnei receive annual hands on fire fighting training using portable fire extinguishers and burn pans as specified in the Kewaunee Emergency Plan, Part V.f.. - Emergency Preparedness: Fire Training. This training also includes a discussion of emergency response procedures. The inspector reviewed the training records for these training sessions and verified that they are held annually.
General emple,ees have monthly safety meetings which occasionally contain information pertinent to fire protection. General employee training in fire protection administra-tive controls is basically obtained through on the job experience. There is no formal training in administrative controls.
Contractor training is contained in video tapes that are reviewed before access is permitted to the plant. These tapes contain information about emergency response. No training is given in fire protection administrative controls.
This is not in accordance with facility operating license No. DPR-43, Amendment 23, Part 6.0 of the Fire Protection Safety Evaluation Report that reads, in part, as follows:
6.0 Administrative Controls
... The program and its implementing procedures as provided by letter 1/om the licensee dated May 15, 1978...
Paragraph 1.0d.(5) in Attachment No. I to the letter from the licensee dated May 15, 1978 reads, in part, as follows:
... program for indoctrination of all plant contractor personnel in appropriate administrative procedures which implement the fire
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l protection program... done by video tapes provided by the Training Group.
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l Temporary rule 10 CFR 50.48 promulgated October 29, 1980 suspended
ccmpliance dates contained in schedules imposed by license conditions
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relative to fire protection. This temporary rule will be superseded by 10 CFR 50.48 which will become effective February 19, 1981. At that time, if this situation were not corrected, this could become an-item of noncompliance.
j No items of noncompliance were identified in this area.
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9.
Fire Inspections The inspector reviewed the most recent report from the fire insurance inspector dated March 31, 1980. One item was identified by the insurance iespector that has yet to be resolved. This item was a concern pertaining to the four inch hose connection on the outside hose hydrants.
Improper use ci chis connection by improperly trained or inexperienced offsite brigades when filling their tanks could degrade the interior fire suppression system water supply.
No items of noncompliance were identified in this area.
10.
Quality Assurance Audits t
The inspector reviewed QA Audit Number 80-19.
This audit was performed to satisfy the requirements J Technical Specification 6.5.3.8.f for bi-annual audits of the fire protection program and implementing procedures.
This QA audit reviewed equipment and technical specification requirements and made a recommendation that a checklist for fire fighting equipment inventory should be developed. This is still an open i;em. The audit did not address the completeness or effective implementation of adminis-trative controls when compared to licensee commitments.
No items of noncompliance were identified in this area.
11.
Technical Specification Surveillance l
The inspector reviewed Surveillance Procedures SP-08-184, 185, 186, 187, I
and 188 for the last two years. All surveillance required by Technical
Specifications had been performed within the applicable time period.
No items of noncompliance were identified in this area.
12.
Housekeeping Tue inspector reviewed GMP-116: Cleaning of NSSS Pipes and Components.
This general maintenance procedure provides guidance for cleanliness of NSSS components and pipes after maintenance has been performed.
GMP-116 is referenced in applicable procedures and on work requests that involve
breaching the NSSS barrier.
Kewaunee does not have any. work area cleanliness requirements when work is being performed on safety.related equipment except for the general guidlines contained in the WPS Safety Rules Book Part 142-Housekeeping which is not nuclear _ plant spreific.
During a plant tour, the inspector found the plant to be in a clean condition.
t No items of noncompliance were identified in this area.
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13.
Exit Interview The inspector met. with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on October 23 and November 14, 1980.
The inspector presented the scope and summarized the findings of the inspection.
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