IR 05000312/1987049

Insp Rept 50-312/87-49 on 871228-30 & 880127-28.No Violations or Deviations Noted.Major Areas Inspected:Fire Protection Program Implementation & Identified Open Items

ML20148F772
Person / Time
Site:	Rancho Seco
Issue date:	03/08/1988
From:	Ramsey C, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20148F761	List: IR 05000312/1987049 ML20148F756
References
50-312-87-49, NUDOCS 8803280281
Download: ML20148F772 (9)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report N /87-49 Docket N License N DPR-54 Licensee: Rancho Seco Nuclear Generating Station Sacramento Municipal Utility District 14440 Twin Cities Road Herald, California 95638-9799 Facility Name: Rancho Seco Unit 1 Inspection at: Herald, California (Rancho Seco Site)

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Inspection Conductedi December 28-30, 1987 and January 27-28, 1988'

Inspector: ... Mu .&  %

C. Ramsey, Regional Inspbetor J///4'

Date Signed Approved by: _ $d SfB[G8 S. Richards, Chief Date Signed Engineering Section Summary:

Inspection During the Period December 28-30, 1987 and January 27-28, 1988

_(Raport No. 50-312/87-49)

Areas Inspected: . Routine, unannounced inspection by a regional based inspector involving followup on previous NRC and licensee identified open items. A limited assessment of specific areas of the fire protection program implementation was made. During this inspection, Inspection Procedures 30703, 62704, and 92701 were used.

., Results: In the areas inspected, no violations or deviations were identifie a0303 PDR ADOCK 05000312 o DCD

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DETAILS Persons Contacted Sacramento Municipal Utility District (SMUD)

J. P. Flynn, Manager, Plant Performance G. Cranston, Manager, Nuclear Engineering S. Crunk, Manager, Nuclear Licensing P. Posakowski, Supervisor, Licensing Technical Services J. Shelter, Director, SRTP J. Kittler, Fire Protection Engineering Reviewer

• Jindai, Fire Protection Group Leader

• 0. Swank, Nuclear Licensing

• K. Zimmermann, Nuclear Operations Fire Protection Coordinator J. Zott, Fire Protection Engineering Coordinator J. Seaphur, Fire Protection Engineering Reviewer Impell J. Robertson, Licensing Engineer Bechtel L. C. Leisburg, Quality Engineer

• Denotes those attending the exit meeting held on January 28, 198 . Licensee Actions on Previous Inspection Findings (Closed) Special Report No. 87-04, "Significant Number of Breached Fire Barriers" This item is closed based on the number of breached fire barriers the licensee has restored to operability status as construction activities have decreased. The number of remaining breached fire barriers is not significant when compared to industry-wide experience. Furthermore, according to the licensee, all breached fire barriers are expected to be operable prior to restar (Closed) Open Item 312/87-15-03, "Organization and Staffing for Fire Protection Program Implementation" The licensee has employed permanent staff to implement the fire protection program requirements. A total of six fire protection personnel have been added to the licensee's staf Three are assigned to the Operations staff and three are assigned to the Engineering staff. All six of the individuals appear to be qualified and capable of carrying out assigned responsibilities for implementing the program. Administrative Procedure Nos. AP-23 and NEAP 4119 have been revised to incorporate the responsibility of these individuals such that the management policy for the program's implementation is clearly delineate According to the licensee,

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this organizational change will be identified to the NRC in the next scheduled FSAR updat This item is considered closed based on the licensee's corrective action C. (Closed) LER No. 87-33, "Hourly Fire Watches Missed During Security Computer Outage" The licensee reported in this LER that a break'own d in the security computer system. caused an unexpected demand on available manpower to perform Technical Specification-required fire watche During the event, eleven fire watch patrol stops in 77 inspection zones were not performed ac required by the Technical Specification The licensee determined that the root cause of these Technical Specification violations was the unavailability of personnel to perform the required fire watch patrol Upon failure of the security computer, the Security Watch Commander was faced with conflicting decision He was required to station personnel in specific plant areas by the Security Plan, and he was required to maintain fire watches pursuant to plant Technical Specifications.and Administrative Procedures. There was insufficient staff on duty to conduct the required manual vital area monitoring and fire watch patrol duties. The Watch Commander's decision to abandon the fire watch patrols and to use available personnel for monitoring vital areas was in accordance with security procedures. This decision resulted in violating Technical Specification requirements for fire watch patrol The licensee's corrective action for this event included the following:

Implementing an organizational change that establishes a fire watch patrol personnel poo Revision of security department procedures to require coordination of manpower availability with the Control Room )

Shift Superviso Revision of Administrative Procedure No. AP-64 to require that the Control Room Shift Supervisor and Security Watch Commander take aporopriate steps to explore every option to ensure the performance of fire watch patrols through the use of qualified operations and maintenance personne Based on the licensee's corrective actions, this itent is considered closed.

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O. (Closed) LER No. 87-35, "Abandonment of Continuous Fire Watch From Fire Alarm Panel" The licensee reported in this LER that during the performance of a post discharge carbon dioxide system test, a continuous fire watch Was abandoned from the associated alarm monitoring panel for approximately three hour ,

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The licensee determined that the cause of the abandonment was uncontrolled discharges of carbon dioxide in the vicinity of the alarm monitoring panel which exposed personnel to the risk of asphyxiation. During the abandonment period, an hourly fire watch patrol was performed by personnel wearing portable breathing-apparatu The continuous fire watch was reinstated after the atmosphere in the area had been determined free of the carbon dioxide effluen Based on the licensee's actions during this event, this item is considered close (Closed) Open Item 312/87-39-01, "Reactor Coolant Pump Lube Oil Collection System Deficiencies

The inspector questioned the adequacy of seismic restraints, flow of lube oil from the tanks to the containment sump, functional surveillance testing of the system, and the quality assurance classification of the Reactor Coolant Pump Lube Oil Collection Syste The licensee responded to the inspector's concerns as follows:

Engineering Calculation No. Z-RB-C0959 was provided for the inspector's review in support of the licensee's position that the lube oil collection tanks are designed and constructed to meet the performance requirements for seismic Category I component Engineering Calculation No. Z-FPP-M2392 was provided for the inspector's review in order to confirm that sufficient capacity exists in the containment sump to hold the entire overflow potential from the lube oil collection syste Maintenance Surveillance Nos. T-213A and T-213B schedules were provided to the inspector to confirm that the lube oil collection system functional surveillances would be performed prior to restar *

Revised quality-related documents were proved for the inspector's review that confirmed the seismic classification attached to the lube oil system collection tank Based on the inspector's review of the licensee's corrective actions for these concerns, this item is considered close F. (Closed) Open Item 312/87-39-03, "Quality Assurance Program Deficiencies" The inspector raised the concern that quality assurance program requirements for fire protection were deficien In response to the inspector's concerns, the licensea provided the following for the inspector's review:

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. 4-Quality Assurance Program (QAP)' Procedure No. 6, which

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l authorizes and guides inspection, planning and testing of fire '

protection feature *

QAP Procedure No. 27, Revision 3, requiring Non-Conforming Activity Reports be issued for non-conforming conditions of required fire protection feature Based on the inspector's review, this item is considered close (0 pen) LER 87-29, "Fire Protection Program Deficiencies With Respect to Technical Specifications and Commitments The licensee reported in this LER that a number of fire protection program features were not in conformance with Technical Specifications or previous commitments made to the NR The inspector's followup on the licensee's corrective action for these

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conditions are as follows:

(1) Fire Alarm System Deficiencies Because of continuing problems associated with de-activated C0 2 systems, the licensee indicated thatl Technical Specification compensatory measures will be implemented for all CO 2 system protected areas for restart and remain in effect until permanent CO 2 and fire alarm system modifications are complet Due to the lack of fire protection control room annunciation, the licensee also implemented Procedure No. H3FPB, requiring an operator to be dispatched to local alarm panels to distinguish the type and exact location of fire alarms that are received in the control room. The licensee indicated that this interim compensatory measure will be in place for restart and remain in effect until final fire alarm system modifications are completed in accordance with the post-restart schedule discussed in the LE (2) Fire Pump ~ nomalies As a result of the inspector's concern over anomalies in fire pump test data, the licensee provided notification to Region V in Special Report No. 88-02 that both the electric and diesel driven fire pumps were declared inoperable due to test results that apparently indicated the pumps may not have met Technical Specification requirement The licensee revised fire pump testing criteria and implemented new test procedures that more appropriately incorporate the governing code requirements. The licensee then retested both pumps in accordance with new test Procedure Nos. SP-705 and SP-70 The inspector's review of the test results indicate that both pump performances were acceptable to the extent that Technical Specification limits were me However, the test results were inconclusive when compared to the' original pump manufacturer's shop test pump performance curve . _ _ - - -

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g By demonstrating that the pumps' performance met the minimum Technical Specification limit, the licensee also demonstrated that either pump.could meet the greatest expected flow rate required for firefightin By o.riginal plant design limitations, neither pump could meet the demand currently stated in the FSAR. However, the licensee's revised calculation of the demand indicate that a significantly less volume of water is required than is stated-in the FSA The licensee indicated that clarification of the FSAR would be made in the next scheduled revisio !

The licensee was in the process of installing a new controller for the electric fire pum According to the licensee, this work would be performed and pre-operational testing completed prior to restar After restart, the licensee indicated that both fire pumps would be re-built and baseline testing will be performed in accordance with manufacturer's specifications and governing code requirements to establish actual pump performance curves and associated operating parameter acceptance criteria for future testing and trending of pump degradation. According to the licensee's January 2,1988, submittal to Region V (No. GCA 87-912), this testing is scheduled to be performed by May 31, i 198 '

This item remains open pending further licensee action and-Region V followu (0 pen) Part 21 Report No. 86-14, "Automatic Sprinkler Corporatio Model 'C' Deluge Valves Failing to Open" In response to this concern, the licensee previously indicated that the subject model "C" type deluge valves would be replaced prior to restar Since that commitment, the licensee has experienced difficulty in acquiring the necessary replacement parts to install the new valve According to the licensee, the results of functional testing of all of the subject valves has resulted in no failures. Based on this, the licensee proposed to delay installation of the new valves to post restart to allow more lead time for parts availabilit This item remains open pending further licensee action and Region V followu . Potentially Non-Conforming Firefighting Hose Stations Inside Containment The licensee's February 1,1978, response to the NRC's position requiring firefighting standpipe hose stations to be provided inside containment did not fully describe the configuration and limitation of the system being relied upon for this purpose. The licensee's response appears to imply that the system's water supply is equivalent to the remainder of the facility's firefighting standpipe hose stations that are designed to governing code NFPA Standard No. 14 and supplied by the station fire

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6 pump Apparently, this was the basis for the NRC's acceptance of the l system as meeting the intent of NRC guidelines contained in Appendix A to .i Branch Technical Position 9.5-1 as stated in the SER associated with i Amendment No. 19 of Facility Operating License No. DPR-54, dated February 28, 197 Although the licensee described the system as being supplied from a 30,000 tank with a pump rated at 300 gpm at 225 feet of head, a clear correlation between_this low capacity system and required water supply for firefighting was not made by the license The additional 1 limitations of -inch diameter piping in the system and the lack of l Technical Specification or other surveillance / maintenance requirements )

were not addressed in the licensee's description of.the syste i

To support the licensee's position aoout the system in its present configuration, the licensee provided Engineering Calculation N Z-FPP-M2370 for the inspector's review. The purpose of the calculation was to determine available fire hose nozzle flow and pressures that can be obtained from the system for firefighting purposes inside containmen The calculation appears to have adequately considered'the essential hydraulic principles for this installation, and accordingly, the calculated results indicate that the system's ability to provide water supply for firefighting purposes is not equivalent to the minimum specified by governing code NFPA 14 which is referenced in the NRC guidelines contained in Appendix A to Branch Technical Position 9.5- The minimum water supply specified for firefighting purposes by the governing code is 100 gpm at 65 psi at the nozzle. The licensee's Calculation No. Z-FPP-M2370 indicates that flows of 40 gpm at 52 psi at elevation 63.0 feet; and 50 gpm at 85 psi at elevation 11.0 feet are available at hose nozzles from the containment standpipe fire suppression system (Miscellaneous Water System).

In response to this concern, the licensee took the following actions:

To ensure availability of water supply to the existing containment firefighting standpipe outlets, Engineering Change Notice (ECN) N R2612 was issued to require that valve Nos. DMW-421 and DMW-422 to the system be repositioned from "locked closed" to "locked open." '

The ECN requires that affected drawing No. M593, sheet 2 of 3, be revised to reflect the new system valve positionin '

Containment firefighting pre plans were revised to require that the fire brigade use extra lengths of fire hose as necessary to obtain water supply for fighting fires inside containment from the nearest Auxiliary Building standpipe outlet that is supplied by the station fire pumps in the event that the Miscellaneous Water System supply is inadequate. The licensee installed and designated additional fire hose and hose cabinets for this purpose; and, revised operations and fire brigade annunciator response procedures to include appropriate instructions for this method of fire attac :

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. 7 Prior to restart, the licensee indicated that a decision would be made on the degree of testing of the Miscellaneous Water System t determine its operabilit *

After restart,.the licensee indicated that clarification of the capability of the Miscellaneous Water System would be provided in the next scheduled revision of the FSAR and required modifications to the system, if needed, would be discussed with NR The inspector determined that the actions taken by the licensee prior to restart as interim compensatory measures for this condition provide reasonable assurance fires occurring inside containment can be suppressed by manual firefighting activitie In addition, as stated in the SER associated with Amendment No. 25 to Facility Operating License N OPR-54, dated December 14, 1978, the following features reduce the potential severity of a fire occurrence such that a significant fire is unlikely to occu Oil in the Reactor Coolant Pumps (RCP's) represent a large source of combustibles. However, the RCP. oil collectson system is provided to remove this material from the Reactor Building in the event of fir Electrical cable insulation inside the Reactor Building represent the only other significant combustib'e fire hazard. Early warning ionization fire detectors are provided to detect fire occurrences involving this materia In view of these circumstances, the inspector concluded that resolution to the need for upgrading the capability of the miscellaneous water system for firefighting purposes does not impact the licensee's restart of the facility and NRR's review of this issue is_ require This is considered an open item (312/87-49-01) ar.d is being referred to NRR for resolutio . Additional Licensee Identified Deficiencies Regarding Appendix R to 10 CFR 50 During the inspection, the licensee's staff and the inspector performed a walkdown of areas where the licensee had previously identified deficiencies in emergency lighting provided to support safe shutdown and a deficiency in the fire protection of redundant power cables for control room instrumentation (i.e. , redundant pressurizer level indication). The emergency lighting deficiencies are located in various areas requiring operator actions to achieve safe shutdow The unprotected control room process indication cables are located in the Transformer Alley, south of the Auxiliary Buildin For the emergency lighting deficiencies, the licensee indicated that a compensatory measure for restart will be the use of portable lights and revised procedures. For the unprotected control room process indication redundant cables, the licensee indicated .that compensatory measures for restart will be a continuous fire watch posted in the Transformer Alley are In both cases, the licensee indicated that the compensatory r

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1 measures would remain in place until final hardware modifications are l installe l This is considered an open item (312/87-49-02) pending further licensee action and Region V followu . 'Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC, the licensee, or bot Open_ items disclosed during the inspection are discussed in paragraphs 1.L, 2.M, 2.N, 2.0, 3.A, 3.B, and . Exit Interview The inspector met with the licensee representatives (noted in paragraph 1) at various times during' the inspection and formally on January 28, 1988, to summarize the scope of the findings and inspection activities described in this repor The licensee representatives acknowledged the statements made by the inspecto ,

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