IR 05000327/1980010

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IE Insp Repts 50-327/80-10 & 50-328/80-06 on 800318-21. Noncompliance Noted:Fire Fighting Procedures Not Provided for All safety-related Areas
ML19323H901
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 04/11/1980
From: Conlon T, Miller W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19323H880 List:
References
50-327-80-10, 50-328-80-06, 50-328-80-6, NUDOCS 8006170228
Download: ML19323H901 (7)


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UNITED STATES

NUCLEAR REGULATORY COMMISSION

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E REGION 11

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o 101 MARIETTA ST., N.W.. SUITE 3100 o

ATLANTA, GEORGIA 30303

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APR 141980 Report Nos. 50-328/80-10 and 50-328/80-06 Licensee: Tennessee Valley Autnority 500A Chestnut Street

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Chattanooga, TN 37401

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Facility Name: Sequoyah Docket Nos. 50-327 and 50-328 License Nos. DPR-77 and CPPR-73 Inspection at Se oyah site r Chattanooga, Tennessee Inspector:

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W. H. Miller,' Jr(,-

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Date' Signed Approved by:

/ cfD T. E. Conlon, Section Chief, RC&ES Branch Date Signed SUMMARY Inspection on March 18-21, 1980 Areas Inspected This special, unannounced inspection involved 30 inspector-hours on-site in the

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areas of fire protecticn/ prevention.

Results Of the areas inspected, no items of noncompliance were identified; however, two

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deviations were found (Substandard fire protection administrative control proce-

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dures; and, Substandard supervision of fire protection control valves).

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t DETAILS 1.

Persons Contacted Licensee Employees

  • W. Popp, Assistant Plar.t Superintendent
  • G. G. Wilson, Nuclear Power Operations
  • W. J. Glasser, Operations QA

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  • R. L. Hamilton, Operations QA
  • E. A. Craigge, Safety / Fire Protection J. M. Munns, Supervisor Construction QA R. Bruce, Construction QA NRC Resident Inspectors
  • W. T. Cottle
  • S. D. Butler
  • Attended exit interview.

2.

Exit Interview The inspection scope and findings were summarized on March 21, 1980 with those persons indicated in Paragraph I above.

3.

Licensee Action on Previous Inspection Findings (Open) Unresolved Item (50-327/79-34-01 and 50-328/79-19-01), Substandard a.

fire pump installation.

NRR is reevaluating the adequacy of the fire pump installation. This item remains open.

b.

(Closed) Deviation Items (50-327/79-34-02 and 50-328/79-19-02), Sub-standard automatic sprinkler systems. NRR memorandum for H. D. Thornburg, Director, Division of Reactor Construction, Inspection I&E from V. Benaroya, Chief, Auxiliary Systems Branch, DSS dated February 13, 1980 advised that the substandard design and installation of the automatic sprinkler systems at Sequoyah were acceptable to NRR. This item is closed and the futur,e evaluation of the sprinkler systems at Sequoyah by this

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Inspector will be

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restricted to the areas of maintenance, inspection

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and tests to assure that the installed systems will be properly main-

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tained to function in the event of a fire.

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(Open) Deviation Item (50-327/79-34-03 and 50-328/79-19-03), Inadequate c.

QA documentation of inspections and tests conducted.on, fire protection system installations.

The licensee has provided test data for the hydrostatic tests conducted on the fire pro.ection systems; however, these tests were not witnessed by an independent inspection group.

Also, records are not available to indicate that flushing tests were

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conducted on the fire protection piping systems. The flushing require-

ment for the systems are outlined in the applicable National Fire Protection' Association (NFRA) standards which are referenced on various TVA construction drawings. The flushing requirements for fire protection

piping systems are also included in TVA Procedure SNP II No. 48,

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"Cleanings Inspection of Fluid Handling Systems" and TVA Procedure

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G-39, " Cleaning During Fabrication of Fluid Handling Componets".

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These procedures were used as the flushing criteria for the piping

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systems at Sequoyah. Section A.8.d of SNP II-48 requires fire protec E tion piping systems to be flushed nd Section 11.1 of G-39 requires adequate records to be provided to document that the piping systems had been properly flushed. In view of the lack of adequate documentation, this item will remain open.

d.

(Closed) Deviation Item (50-327/79-34-04 and 50-328/79-19-04), Failure to provide housing for reactor coolant pumps. The NRR memorandum of

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February 13, 1980 referenced in above paragraph 3.b also advised that i

the provision of the heat shield above each reactor coolant pump and the small catch basin beneath each pump in conjunction with the fire suppression system for each pump were adequate and provided acceptable

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protection for the pumps in lieu of the pump housing previously required to be provided. Therefore, this item is closed.

4.

Unresolved Items Unresolved - items are matters about which more information is required to determine whether they are acceptable or may involve noncompliance or deviations.

New unresolved items identified during this inspection are discussed in Paragraphs 5.b(3), 5.b(8), 5.c(1) and 5.c(2).

5.

Fire Protection / Prevention - Unit 1 (Operating)

a.

Procedures The licensee has promulgated administrative fire protection procedures for the operating plant. These procedures adhere to the NRC guidelines contained in the NRC document entitled, " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality

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(1) Fire fighting procedures are not provided for all safety-related

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areas of the plant as required by Paragraph d of Attachment No. 5

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of the NRC guidelines.

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(2) Fire brigade classroom instruction / lectures are not scheduled for

brigade members each quarter as required by Paragraph 1.0.d of Attachment No. 2 of the NRC guidelines.

(3) The licensee's procedurer do not require at least one fire brigade

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drill per year per shift to be conducted on the back shift as require.d by Paragraph 3.C.e of Attachment No. 2 of the NRC guide-lines.

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(4) The procedures do not require all wood used within the plant to be of the pressure impregnated fire retardant treated type as

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required by Paragraph e of Attachment 3,,i the NRC fire protection i

guidelines. The licensee advised th u normal plant policy is for all plywood to be of the fire r xardant treated type and all other wood to be painted with a fire retardant paint. However, the procedures as currently written permit the use of wood which has only been provided with a flame retardant coating.

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TVA's response to NRC's question No. 2 in the Fire Protection Program Reevaluation (FPPR) report states that TVA's fire protection administra-tive procedures will be revised to comply with the NRC guidelines listed in the document, " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance". The failure to meet this commitment with the NRC is identified as Deviation

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Item (50-327/80-10-01), substandard fire protection administrative control procedures.

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b.

Inspection and Test of Fire Protection Systems The following inspection and test procedures for the fire protection systems were reviewed and discrepancies noted:

(1) SI-180, Fire Pump Start Test (31 days)

Test data sheets from January 2,1980 through February 21, 1980 were reviewed and no discrepancies noted.

(2) SI-167, Fire Header Line-Up Inspection (31 days)

1 Inspection data sheets from January 8, 1980 through March 4, 1980 were reviewed and no discrepancies noted. However, this procedure does not require all valves in the fire protection water system to be locked in their normal position as stated by Section A.3(b)

of the FPPR. This discrepancy is a failure to meet a commitment j

to the NRC and is identified as Deviation Item (50-327/80-02),

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substandard supervision of fire protection control valves.

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(3) SI-171, Fire Header Riser and Outlet Flush (6-Month)

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The data sheets for tests of November 1, 1979 were reviewed.

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This procedure does not require the 2-inch drain test as specified by NFPA-13, Sprinkler Systems, to be conducted as committed to by Paragraph C.2 of the Enclosure to TVA's'~16t}dr of November 21, 1979 from L. M. Mills, Manager, Nuclear Regulations and Safety to J. P. O'Reilly, Director, NRC Region II. This item is currently being evaluated by the licensee and is identified as Unresolved Item (50-327/80-10-03), two-inch drain test for sprinkler systems, and will be reviewed during a subsequent NRC inspection.

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(4) SI-172, Fire Systems Testable Valves (12 months)

The data sheets for tests conducted on August 15, 1979 were reviewed and no discrepancies noted.

(5) SI-176, Fire Suppression Water System Functional Tests (18-Months)

The data for the tests conducted on August 15, 1979 were reviewed, and no discrepancies noted; however, refer to paragraph 5.b(6)

for comment on the tests of unsupervised fire detection / actuation'

circuits.

(6) SI-177, Sprinkler System Functional Tests (18 Months)

The data sheets for the tests conducted on December 6,1979 were reviewed and no discrepancies noted. However, this procedure is conducted every 18 months whereas Section 4.3.3.8.3 of the Technical Specifications require unsupervised circuits between fire detection controls panels and actuated equipment (i.e., fire pumps, sprinkler systems, etc.) to be demonstrated operable at least once per 6 months. The licensee is evaluating the existing inspection and test procedures and advises that the inspection and test of these circuits will be incorporated into the precedures. This item is identified as Inspection Followup Item (50-327/80-10-04), tests of unsupervised fire protection system circuits, and will be

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inspected during a subsequent NRC inspection.

(7) SI-175, Low Pressure Carbon Dioxide System Level and Pressure Verification (7 Days)

The inspection data sheets from January 1, 1980 through March 4, 1980 were reviewed. The time between the February 26, 1980 and March 4, 1980 inspections was 9 days which appeared to exceed the maximum limit of 8.75 days permitted by the technical specifications (7 days + 25% time extension permitted). However, it is possible, depending on the time of day that the inspectione were conducted, that the time interval did not exceed the 8.75 days. The licensee has initiated action to monitor the short interval inspections and tests required by the technical specification to help prevent

future Technical Specification violations.

Also, the pressure

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and level of the carbon dioxide tanks were verified and recorded

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in the shift engineer's log on March 5, 1980, which indicated e.-

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that the systems were in service.

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(8) SI-190, Fire Hose Station Inventory (31 Days) *

The inspection data sheets for inspections made-from January 2,

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1980 to February 27, 1980 were reviewed. The equipment provided for each of the exterior fire equipment houses does not comply with the equipment listed in TVA response to NRC question No. 26

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in the FPPR. The licensee is reevaluating this commitment. This

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item is identified as Unresolved Item (50-327/80-10-05), Equipment for exterior fire equipment hoses, and will bc reviewed during a subsequent NRC inspection.

(9) SI-234, Fire Detection Systems (6 Months)

The test data sheets dated November 9, 1979 were reviewed and no discrepancies noted, except the procedure did not require a test.

of the supervisory functions of the alarm panels. The licensee advised that these tests were conducted during the start-up and "

functional tests phase and that the procedure will be revised to include this requirement prior to the next test scheduled for April 1980. This item is identified as Inspector Followup Item (50-327/80-10-06), test of supervisory features of fire alarm control panels, and will be reviewed during a subsequent NRC inspection.

c.

Plant Tour A tour was made of the plant to verify that the fire protection systems in service and to review the general housekeeping of the plant.

were The following discrepancies were noted:

(1) Inspection of the sprinkler and fire hose systems for the contain-ment of Unit 1 indicated that the containment isolation valves for these systems were in the closed position which resulted in these systems being out of service. These systems are not required to be in service during Mode 6 (refueling) phase of the plant operations; therefore, this item was not considered an item of noncompliance. A review was made of Section V.C of TVA's procedure SQI 88.1B, Containment Isolation System. This procedure requires valve checklist 88.1B-1 to be used to return the isolation valves to normal following a phase "A" containment isolation. Checklist 88.lB-1 does not list the valves on the fire protection piping systems which penetrate the containment.

A temporary change request has been issued and the procedure is to be revised to require the fire protection valves to be returned to their normal open position upon recovery from a containment isolation.

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Section A.3(b) of the FPPR requires all control valves in the

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fire protection system to be locked in their normal position. It

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is not feasible to lock the fire protection containment isolation a.-

valves in the open position and retain the capability to automat-ically close these valves in the event of *a untainment isolation.

Therefore, the licensee is evaluating the prdblem to determine if these valves should be electrically supervised or the commitment to t.ne NRC for valve supervision (locked valves) be changed for i

these valves. This item is identified as Unresolved Item (50-327/

80-10-07), supervision of containment fire protection valves, and will be reviewed during a subsequent NRC inspection.

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(2) Inspection of diesel generator building indicated that an unprotec-ted electrical / mechanical penetration, approximately 2 x3 feet in size existed in the fire wall around the fuel oil transfer room.

The licensee is investigating to determine if the construction of this room is complete and will take the appropriate action to assure that the required fire rating of this fire wall is provided.

This item is identified as Unresolved Item (50-327/80-10-08 and 50-327/80-06-08), unprotected penetration in fire wall of fuel *

oil trausfer room at diesel generator building.

d.

Fire Protection QA Program / Construction Site A review was made of Audit Report G-79-06 dated March 1979. This audit did not include a full audit of the fire protection QA program described in TVA's response to NRC Question F421.1 of the Fire Protec-tion Program Reevaluation. The licensee advised that an audit will be conducted of the Unit 2 fire protection program beginning June 9,1980.

This item is identified as Inspector Followup Item (50-328/80-06-09),

Audit of the fire protection QA program at Unit 2, and will be reviewed upon completion of the audit.

Except as noted above, no additional items of noncompliance or deviations were noted in the areas examined.

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