IR 05000324/1993038
| ML20057B406 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/31/1993 |
| From: | Casto C, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20057B403 | List: |
| References | |
| 50-324-93-38, 50-325-93-38, NUDOCS 9309210304 | |
| Download: ML20057B406 (10) | |
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UNITED STATES p arg%
NUCLEAR REGULATORY COMMISSION
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101 MARIETTA STREET, N W., SUITE 2900
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ATLANTA. GEORGIA 30323 0199
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Report Nos.:
50-325/93-38 and 50-324/93-38 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket Nos.-
50-325 and 50-324 License Nos.:
DPR-71 and DPR-62 facility Name:
Brunswick 1 and 2 Inspection Conducted: August 16 - 20, 1993
[. k. /&dmw TbMM Inspector:
G. R. Wiseman Date Signed
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'N 7/'? / //7 Approved by:
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Castb, Acting Chief
'Date Signed C.
Test Programs Section Engineering Branch Division of Reactor Safety j
l SUMMARY Scope:
This routine, announced inspection was conducted to follow-up on Unit 1 fire I
l protection related restart issues including repairs to the Unit 1 fire barrier
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masonry block wall gaps and penetration seals, the fire barrier reinspection program, periodic tests and e.urveillance of fire protection components, fire protection upgrade project, alternate safe shutdown (ASSD) communications and emergency lighting; and licensee action on previous inspection findings.
Results:
In the areas inspected, violations or deviations were not identified.
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The Operations Fire Protection /Radwaste Unit has procedurally reaffirmed its l
responsibility for maintaining the overall site Fire Protection Program. The current program adequately addressed previous NRC concerns about ownership of fireprotectionatBrunswickNuclearPlant(BNP).g Prioritization and scheduling of outstanding fire barrier masonry block wall gaps and penetration seal repair work was adequate; no concerns were 9309210304 930910 PDR ADOCK 05000324 G
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identified with respect to the fire barrier reinspection program and Unit I restart.
The licensee's actions to correct self-identified (Licensee Event Reports)
problems were good. Appropriate corrective actions were implemented to resolve the enforcement issues of NRC Inspection Reports Nos. 50-325, 324/93-08 and 93-201.
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REPORT DETAILS 1.
Persons Contacted
- G. Barnes, Manager, Unit 1 Operations
- C. Blackmon, Manager, Radwaste/ Fire Protection
- J. Brown, Unit 1 Plant Manager
- J. Dobbs, Special Assistant /Vice-President, Brunswick Nuclear Plant
- L. Gard, Manager, Engineering Projects
- S. Hardy, Fire Protection Engineer, Nuclear Engineering Design (NED)
- K. Harris, Manager, Licensing
- C. Hinnant, Director Site Operations
- B. Hewett, Engineer, Technical Support
- M. Hunter, Technical Support Supervisor
- R. Lamb, Project Engineer, NED
- W. Levis, Acting Manager, Regulatory Affairs
- C. Lewis, Manager, Project Services
- G. Miller, Manager, Technical Support
- T. Mull, Fire Protection Specialist, Operations
- D. Quick, Manager, Nuclear Assessment Division (NAD)
- R. Sims, Senior Engineer, NED
- G. Thearling, Senior Specialist, Regulatory Affairs
- E. Willett, Manager, Project Management Other licensee employees contacted included craftsmen, technicians,
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operators, mechanics, fire watch personnel, security force members, and office personnel.
NRC Resident Inspectors
- R. Prevatte, Senior Resident Inspector
- P. Byron, Resident Inspector Acronyms and Initialisms used throughout this report are listed in the last paragraph.
2.
Review of Licer.see Actions Taken to Strengthen Management Control Over i
the Fire Protection Area (64704), (92700)
During the inspection documented in NRC Inspection Report No. 50-325, 324/93 08, the inspector identified a concern with the on-site fire protection program implementing procedure, in that PLP-01 " Fire
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Protection Program Document" had not been revised to include a description of the current fire protection staffing organizations, their responsibilities or interfaces; fire protection commitments; Appendix R safe shutdown procedures or equipment; and policies 4cr the operability of fire protection features, etc. The licensee respended to the concern
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in a letter dated April 23, 1993, Serial BSEP 93-0060. This response indicated that a Technical Support organization initiative was underway to upgrade the fire protection program. The scope of the upgrade was to: review and revise the Fire Protection Program Document, PLP-01, to ensure the requirements of 10CFR50.48 are met; capture fire protection
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commitments and update the fire protection commitment document, PLP 1.1; and, include the fire protection upgrade as Initiative TY-515 in the
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Brunswick Nuclear Plant (BNP) Three-Year Plan (1993-1995).
During the current inspection, the inspector reviewed PLP-01, " Fire Protection Program Document", Revision 2, dated July 30, 1993, and documents outlining the status of the fire protection upgrade project.
The review indicated that the upgrade project to develop the updated
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revision to PLP-1.1, Fire Protection Program Commitment Document, after receiving strong support at first, was not issued for plant use and was behind schedule (currently in the review cycle). Also, the fire protection program Initiative TY-515 had been deleted from the Brunswick i
Plant Three-Year Plan. A review of PLP-01 revealed, however, that the i
deletion of TY-515 was justified since the remaining TY-515 initiative tasks have now been procedurally assigned to the Operations Fire Protection /Radwaste Unit responsibilities in the Fire Protection Program Document.
Based on this review, the inspector concluded that the current revision of PLP-01 adequately addressed the previous concerns about ownership and management responsibilities for the fire protection program and was acceptable.
3.
Follow-Up (92700), (92701)
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The Licensee Event Reports (LER) and follow-up items listed below were reviewed to determine if the information provided met NRC requirements.
The determination included: adequacy of description, verification of TS compliance and regulatory requirements, corrective action taken, existence of potential generic problems, reporting requirements satisfieo, and relative safety significance of the event, a.
(Closed) LER l-92-12, INADEQUATE FIRE BARRIER WALL GAP MATERIAL
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In April, 1992, the licensee determined that a significant number of concrete expansion anchors, required to provide lateral support to interior walls in the diesel generator building, had been improperly installed during original construction. This resulted
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in a determination that several walls were inoperable, that affected critical safety related equipment, resulting in shutdown of both Units.
As a result of the deficiencies identified with the diesel generator walls, an extensive program was undertaken by the licensee to evaluate and modify, if required, all masonry walls in i
safety-related structures in both Units. During the structural i
repairs to the walls, the licensee discovered that the material sealing the expansion joint at the top of the walls (i.e., between the top of the masonry block and the bottom of the reinforced concrete floor slab) was non-fire-rated. The problem was reported i
verbally to NRC Region II on April 21, 1992, with written follow-i up reports submitted to NRC in letters, dated May 22, 1992, June 26, 1992, (Supplement 1) and August 31, 1992 (Supplement 2).
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The licensee has performed a detailed review and inspection of fire barriers and penetration seals during the current Unit 1
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outage. These licensee inspections were initiated by NED utilizing Design Guide IV.0020. As a result of this effort, approximately 185 Work Requests / Job Orders (WR/J0) have been issued to correct the fire penetration seal and fire barrier masonry wall gap configurations for Unit 1.
The inspector reviewed a computer listing and des:ription of the WR/J0s issued for these fire barriers and concluded that the work had been appropriately prioritized.
Approximately 31 work items have not been completed for Unit 1 areas and are identified against LCO: as:ociated with masonry block wall fire barrier gaps or penetration seal conditions.
These are scheduled for completion trior i.c Unit I restart. The inspector, accompanied by licensee (ngineers, walked down a number of identified masonry block wall fire barrier gaps in the diesel generator and control buildings. The inspector verified that compensatory measures consisting of roving fire watches were in place for those outstanding work items in the diesel generator and control buildings. The inspector concluded that the fire barrier gaps were installed in accordance with the details shown on the construction drawings, and met desig1 requirements. The inspector also reviewed Engineering Evaluation Reports (EER) FP-0006-92081, and SWN-188-003-E & -F, dated August 26, 1992, for analysis and repairs of mortar joint gaps in blocl; fire walls and verified that appropriate equivalent fire tested ri. tings had been considered in the evaluations.
Based on this review, the inspector concluded that the masonry wall fire barrier gaps were inspected by licensee engineers in accordance with their commitments.
Tae results of these inspections were considered in the de::ign evaluations of the walls. The licensee has satisfactorily implemented the corrective actions for LER 1-92-12 and they are a cceptable for restart of Unit 1.
The LER is considered closed.
b.
(Closed) LER l-92-27, TWO FIRE PROTECTION SURVEILLANCE PERFORMANCE TESTS DID NOT MEET TECHNICAL SPECIFICATION REQUIREMENTS The cause of this event was inadequate technical reviews during revisions to the affected periodic tesi procedures, PT 34.4.1.4
" Diesel Generator Building Fire Detection Instrumentation Operability Test" and PT 34.5.1.6 " Sprinkler and Valve Cycle Test".
PT 34.4.1.4 did not. provide acceptance criteria guidance for thermal fire detectors added to the diesel generator rooms in 1988.
PT 34.5.1.6 did not cycle the service water building sprinkler header isolation valves (1-FP V95 and 2-FP-V263) through at least one complete cycle of full travel.
The inspector verified by reviewing the tevised periodic test procedures, completed testing documentatlon, and area walk-downs,
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that pts 34.4.1.4 and 34.5.1.6 were appropriately revised on November 3, 1992 and December 1, 1992, respectively to ensure the required testing of the detectors and valves would be performed to preclude recurrence of this event. On November 3, 1992, a channel functional test was performed on the detectors and the two valves cycled (using temporary procedure revision 92-298) with no discrepancies noted.
Based on this review, this LER is considered closed.
c.
(Closed) LER l-93-06, INOPERABLE FIRE BARRIER PENETRATION SEALS
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In March, 1992, during the licensee's Fire Barrier Reinspection Program (visual inspections of fire barrier penetration seals)
discrepancies were found for five cable tray penetrations through the ceiling of the battery rooms in the control building and four wall piping seals in the diesel generator building. The cable
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tray seals contained a Delta Maid One Shot seal which was fire tested without a fire hose stream test performed and the diesel generator building pipe seals were of indeterminate qualification.
The problem was documented as Adverse Condition Report (ACR)
numbers B93-088 and B93-087.
The penetrations were located in plant areas in which fire watches had been posted for other fire barrier concerns.
The inspector reviewed the licensee's EER (as allowed by NRC Generic Letters (GL), GL 86-10 and GL 88-12), No. 0FP-0026-92081,
" Evaluation of Unit 1 Battery Rooms lA & IB Delta Maid One-Shot Ceiling Penetration Seals Tested Without Hose Stream Test".
The EER for the nonconforming seals adequately established a basis for evaluation of the existing penetrations seal configurations as an acceptable alternative to totally replacing or repairing the seals in which it was not feasible or practical for reasons that included personnel safety, cable damage, battery equipment operability, maintenance access or similar obstacles.
In addition, the evaluation validated key concepts of the previously NRC reviewed fire hazards analysis and provided an assessment of the impact of effects of the analyzed deviating penetration seals on the plant safe shutdown capability and the plant licensing basis (NRC Approved Appendix A and R Analysis). The inspector previously examined the control building penetration seals during an inspection documented in NRC Inspection Report numbers 50-
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325,324/92-31. During the current inspection, the inspector reviewed the licensee repair activities associated with the nonconforming pipe penetrations in the diesel generator cells. The licensee has completed the engineering inspections of Unit 1 fire barrier penetration seals and the repair of all but approximately 31 work items for Unit 1 areas. These are identified against LCOs associated with both masonry block wall fire barrier gaps and the identified penetration seal conditions. These repairs are scheduled for completion prior to Unit I restart.
Based on the inspectors review of the EER and the licensee's penetration repair schedule the inspector concluded that corrective actions completed l
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to date are adequate for restart of Unit 1. This item is considered closed.
d.
(0 pen) NRC BULLETIN 92-01 and GENERIC LETTER 92-08, THERM 0-LAG 330-1 FIRE BARRIERS NRC issued Bulletin 92-01 on June 24, 1992, and GL 92-08 on December 17, 1992.
This correspondence notified licensees of failures of fire endurance tests associated with Thermo-Lag fire barrier systems and requested licensees to take appropriate corrective actions and compensatory measures. The inspector's review of the licensee responses on this issue (NSL-92-256 and NLS-93-101, respectively, indicated that Carolina Power and Light Company (CP&L) will continue to maintain their identified compensatory measures in accordance with plant procedures and review the guidance and testing being provided through an industry program coordinated by Nuclear Management and Resources Council (NUHARC) to determine the appropriate actions to resolve the issue.
The inspector observed several fire watches provided for inoperable Thermo-Lag fire barriers. The fire watches were attentive of their responsibilities. These compensatory actions were considered acceptable for restart of Unit 1, however, the Thermo-Lag generic industry issues remains open and will be reviewed during future NRC inspections.
Violations or deviations were not identified.
4.
Licensee Action on Previous Inspection Findings (92702)
a.
(Closed) Violation 325, 324/93-08-01, INAPPROPRIATE POST MAINTENANCE TEST REQUIREMENTS FOR FIRE PROTECTION SYSTEMS The violation contained two examples of the specification of inappropriate post maintenance hydrostatic pressure test criteria for fire protection piping replaced under Work Request / Job Orders (WR/J0s). The licensee responded to the violation on April 23, 1993, BSEP-93-0060. The corrective actions are discussed below:
The incorrect specification of hydrostatic pressure test
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requirements for fire protection systems was partially attributed to procedure inadequacies. Specifically, procedures WP-123 or HMM-003 contained no references to the National Fire Protection Association (NFPA) criteria for testing of fire protection systems.
Procedure, PLP-24, " Work Management Process", was revised, in Revision 4, issued August 2, 1993, to supersede both MMM-003 and WP-123 to provide a unified process for identification of a fire protection material problem or plant deficiency and have-it evaluated by plant management.
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Revision 1 of procedure PLP-20, " Post Maintenance Testing Program", Attachment 3, was issued on August 2, 1993 to address the post maintenance testing guidelines of fire protection equipment and systems. The inspector reviewed Revision 1 of procedure PLP-20 and verified that the deficiencies identified in violation item 325,324/93-08-01 had been corrected.
In addition, the inspector reviewed OSPP-HYDRO 500, Revision 1, dated April 8, 1993, and verified that the procedure was revised to specify the hydrostatic pressure test requirements for fire protection piping and system components and to involve the fire protection system engineer during the performance of testing activity.
The inspector verified that both fire protection systems with inadequate hydrostatic tests were re-tested under WR/J0s 93-AHLN1 and 92-BGNTI to the correct acceptance criteria.
Based on review of the completed corrective actions, this violation is closed.
b.
(Closed) Violation 325, 324/93-201-01, INADEQUATE TEST PROGRAM FOR THE ALTERNATE SAFE SHUTDOWN (ASSD) SOUND POWERED COMMUNICATIONS SYSTEM The inspector reviewed and verified completion of the corrective actions listed in the licensee's response letter dated July 23, 1993, BSEP-93-0201. The licensee had replaced the existing ASSD headsets with improved quality headphones.
Revised Periodic Test PT 48.4, Revision 7, was issued on July 22, 1993, to test the ASSD sound powered phone circuits with a fully loaded (11 headsets)
configuration and at an increased (monthly v quarterly) frequency.
Functional tests had been performed under the revised procedure to demonstrate operability of the sound powered communications system.
On August 19, 1993, the inspector observed an operations crew perform a exercise for remote shutdown from outside the control room utilizing the Alternate Safe Shutdown Procedure 0-ASSD-02,
Revision 12.
During this drill, the operators indicated that the sound powered phone system station-to-station reception was clear and audible. The inspector did express concern to the licensee that the " Appendix R" emergency lighting units installed in the Unit I reactor building in support of ASSD were misaligned (due to being bumped during outage activities) and did not provide full illumination to the remote shutdown equipment.
In response to the concern, the licensee has established on the restart schedule (WR/JO 93LA5003) the performance of the emergency lighting periodic test (0PT-34.13.3.0) for Unit I during the week of
September 18-24, 1993, to ensure emergency lighting alignment.
In addition, the licensee is evaluating (Facts No. 93B9095) the i
functional reliability of the ongoing station radio repeater system upgrade for possible utilization as a backup ASSD
communication system. Overall, the drill successfully demonstrated the operators' ability and capability to shutdown the plant from outside the control room in accordance with the ASSD-j
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procedure.
Based on the successful drill performance during this inspe-tion, this item is considered closed.
5.
Exit Interview The inspection scope and results were summarized on August 20, 1993,
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with those persons indicated in paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection results listed below.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
a.
(Closed) LER 1-92-12, INADEQUATE FIRE BARRIER WALL GAP MATERIAL
- Paragraph 3.a.
b.
(Closed) LER 1-92-27, TWO FIRE PROTECTION SURVEILLANCE PERFORMANCE TESTS DID NOT MEET TECHNICAL SPECIFICATION REQUIREMENTS -
Paragraph 3.b.
c.
(Closed) LER 1-93-06, INOPERABLE FIRE BARRIER PENETRATION SEALS -
Paragraph 3.c.
d.
(0 pen) NRC BULLETIN 92-01 and GENERIC LETTER 92-08, THERM 0-LAG 330-1 FIRE BARRIERS - Paragraph 3.d.
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(Closed) Violation 325,324/93-08-01, INAPPROPRIATE POST
MAINTENANCE TEST REQUIREMENTS FOR FIRE PROTECTION SYSTEMS -
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Paragraph 4.a.
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(Closed) Violation 325, 324/93-201-01, INADEQUATE TEST PROGRAM FOR THE ALTERNATE SAFE SHUTDOWN (ASSD) SOUND POWERED j
COMMUNICATIONS SYSTEM - Paragraph 4.b.
6.
Acronyms and Initialisms ACR Adverse Condition Report ASSD Alternate Safe Shutdown i
BNP Brunswick Nuclear Plant BSEP Brunswick Steam Electric Plant (see BNP)
CP&L Carolina Power & Light EER Engineering Evaluation Reports FSAR Final Safety Analysis Report GL Generic Letter LCO Limited Condition for Operation LER Licensee Event Reports
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NAD Nuclear Assessment Department NCR Nonconformance Report NED Nuclear Engineering Department NFPA National Fire Protection Association NRC Nuclear Regulatory Commission NUMARC Nuclear Management and Resources Council PLP Plant Program PT Periodic Test TS Technical Specifications WR/JO Work Request / Job Order
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