IR 05000338/1980003
| ML19323B757 | |
| Person / Time | |
|---|---|
| Site: | North Anna |
| Issue date: | 03/03/1980 |
| From: | Conlon T, Miller W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19323B737 | List: |
| References | |
| 50-338-80-03, 50-338-80-3, 50-339-80-03, 50-339-80-3, NUDOCS 8005140197 | |
| Download: ML19323B757 (9) | |
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NUCLEAR REGULATORY COMMISSION ) ,, 800514010
{ .E REGION il [ 101 MARIETTA ST., N.W., SUITE 310o {
o ' ATLANTA, GiORGIA 3o3o3 i s
MAR 1F.1980 Report Nos. 50-338/80-03 and 50-339/80-03 Licensee: Virginia Electric and Power Company Richmond, VA 23261 Facility Name: North Anna Docket Nos. 50-338 and 50-339 License Nos. FPF-4 and CPPR-79 Inspection at No th Anna site near Mineral, Virginia . " Inspector: [[. /3 d O L V. H. ? filler', } Dath Sdgned Approved b / w j - 3 -[o . E. Conlon,'Section Chief, RC&ES Branch Date Signed SUMMARY Inspection on February 12-15, 1980 Areas Inspected This special, unannounced inspection involved 25 inspector-hours onsite in the areas of fire protection / prevention.
Results Of the area inspected, three items of noncompliance were found [ Infraction-Excessive time between inspections of carbon dioxide system for fuel oil pump hours-Paragraph 6.b(5); Infraction-Excessive time between inspections of fire hcse stations-Paragraph 6.b(9); and, Infraction-Inadequate fire brigade drills for 1979-Paragraph 6.d(1)] and three deviations were found [ Inadequate admin- - ' istrative fire protection procedures-Paragraph 6.a; Combustible wood used in safety-related areas-Paragraph 6.e(1); and, Substandard supervision of fire protection control valves-Paragraph 6.e(2)]. . D a t < _.
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? ! DETAILS 1.
Persons Contacted
1 !
- W. R. Cartwright, Station Manager
- E. W. Harrell, Superintendent Maintenance
- E. R. Smith, Superintendent Technical Services
- J. W. Ogren, Superintendent Administrative Services
- W. R. Madison, NRC Coordinator
- M. Stokes, Fire Marshal
- D. L. Smith, Resident QC Engineer K. Chrisman, Welding Foreman
' Other Organizations ' ' l J. Daly, Stone and Webster .' P. Griffin, Stone and Webster NRC Resident Inspectors
- M.
S. Kidd
- A.
P. Tattersall
- Attended exit interview.
2.
Exit Interview The inspection scope and findings were summarized on February 15, 1980 with those persons indicated in Paragraph 1 above.
3.
Licensee Action on Previous Inspection Findings (0 pen) Unresolved Items (338/79-06-03) and (339/79-08-01) fire door a.
modifications and inspector followup items (338/79-06-02) and (339/79-08-01), functional fire doors. The licensee has inspected all fire doors in the plant and is in the process of repairing all doors which have inoperative builders hardware or are in need of repairs to meet.
' the criteria of National Fire Protection Association Standard 80 (NFPA-80), Fire Doors and Windows. Section IV.D.I.j of the licensee's Fire Protection Systems Review for North Anna Power Station (FPSR) states that all fire doors in the plant will meet the provisions of NFPA-80.' 'These items remain open and will be reevaluated during a subsequent NRC inspection.
b.
(0 pen) Unresolved Item (339/7 -03-01), Fire Rating of Dampers Between Battery Rooms.and Control Room. Sectips.III.d.7 of the FPSR states that all penetrations in the walls, floor and ceiling of the battery i rooms (Fire Areas 7A, 7E, 7C and 7D) have a 3-hour fire rating. The ! licensee's response to Question 14.b in Supplement No. 3 to the FPSR , l ' . I L
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(Open) Noncompliance (Deficiency) Ites (338/79-45-01), Records of c.
training received by mechanical and electrical maintenance employees as part of the Mechanical Development Programs are not stored as required (Item B in the Notice of Violation-NRC/IE Report No. 338/79-46).
The licensee's response of December 27, 1979 to the Notice of Violation advised that the training records for the electrical and mechanical maintenance employees would be properly stored prior to March 31, 1980. This response did not address the storage of training rec,ords for other plant staff members. However, during this inspection the training and drill records for the plant fire brigade were found located in the office of the site training department and not in a standard vault nor was a duplicate record syrtem maintained.
The storage of the fire brigade drill and training records did not meet the requirements of Technical Specification 6.10.2.h for lifetime records and is another example of this noncompliance. The licensee was advised that appropriate storage practices for the training records of the plant staff must be implemented as part of the corrective actions taken on the above noncompliance. This item remains open and will be reevaluated during a subsequent inspection.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Fire Protection / Prevention Modifications The Fire Protection Safety Evaluation Report for this facility dated February 1979 which is part of Amendment No. 3 to Facility Operating License NPF-4 requires the implementation of a number of fire protection modifications following the second regularly scheduled refueling outage. Work on a portion of these modifications was accomplished during the rec,ent (first) refueling outage. The following items were reviewed during this inspection: Location / Item VEPCO Design Change No.
Control Room (Fire Area 2) Emergency Lighting /8 Hour 78-68L Cable Vault and Tunnel-Units 1 and 2 (Fire Area 3) Sprinkler System / Manual 78-68B Fire Extinguishers / Water Type ' 4 T-N/A ' Fire Dampers / Change 1\\-hour to 3-hour Type 78-68I Emergency Lighting /2-hour Type 78-68L d . I _ , ,_- ,. -. - ~. - - - ' *
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Location / Item VEPCO Design Change No.
Cable Spreading Room (Fire Area 4)
' Hose rack / provide 100' of Hose 78-68D Emergency Switchbear and Instrument Rooms-Units 1 and 2 (Fire Area 6) Hose Racks / Provide 100' of Hose 78-68D Fire Extinguishers N/A Eeergency Lighting 78-68L Battery Rooms (Fire Area 7) Ventilation Air Flow Alarm 78-68G Turbine Building (Fire Area 8) Hose Racks /100' of Hose at Entrance to Control ' Room and Diesel Generator Rooms N/A Auxiliary Building (Fire Area 11) Sprinkler System / Component Cooling Pumps 78-68B Hose Racks /100' of Hose N/A . Curb / Floor Opening to Charging Pumps Emergency Lighting 78-68L Although the installation work on the above items was apparently complete, the QA/QC inspection test, and record data on these items, was not complete.
This data will be reviewed during a subsequent NRC inspection and is identi-fled under the existing Outstanding Items List No. 338/78-11-07 which remains open.
, The sprinkler system in the high ceiling portion of the cable vault was designed to be an open head system. Presently, these heads are of the closed (fusible link) type. The licensee advised that the fusible links were to be removed prior to final acceptance. A number of the sprinkler heads provided for the protection of the component cooling pumps are located ' in open floor areas or an excessive distance from the ceiling structure and are not provided with heat collectors as required by Section A-3-16.8 of NFPA-13, Sprinkler Systems as committed to by Section IV.E.3.c of the FPSR.
The licensee advised that a final QA/QC inspection had not bee'n conducted j on these' systems but that these items would be evaluated at that time.
This item is identified as Inspector Followup Item (338/80-03-01 and 339/80-03-01), Sprinkler System Deficiencies.
No itema of noncompliance or deviations were identified in the areas examined.
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6.
Fire Protection / Prevention Program The following items of the fire protection / prevention program for the operating plant (Unit 1) were reviewed.
a.
Administrative Procedures All of the licensee's fire protection / prevention procedures have been included in a single manual entitled " North Anna Power Station-Fire Protection Plan" (FPP) dated December 21, 1979. Response to question I No. 31 in Supplement No. 3 to the FPSR states that the North Anna Power Station procedures comply with the NRC fire protection guidelines contained in NRC's document entitled " Nuclear Plant Fire Protection
Functional Responsibilities, Admin'istrative Controls and Quality, Assurance" dated June 14, 1977. However, the licensee's procedures do not fully meet the NRC guidelines due to the following: (1) Section 3.8 of the FPP does not require fire brigade members to i pass a physical examination for performing strenous activities and does not list the qualifications for brigade members as required by Section 2.b of Attachment I to the NRC's fire protec-tion guidelines.
(2) Section 4.6 of the FPP does not designate the areas within the plant in which smoking is prohibited and does not restrict smoking
in safety-related area to designated areas as required by Section 4 of Attachment 4 to NRC's fire protection guidelines.
' (3) Section 4.6.3 of the FPP does not require the responsible foreman or supervisor to physically survey the area in which welding, open flame or grinding operations are to be conducted prior to operations to assure that adequate safety procedures will be followed as required by Section 2 of Attachment 4 to NRC's fire protection guidelines.
, (4) Section 7 of the FPP does not require all brigade members to participate in at least one practice session per year involving an actual fire extinguishment activity and in the use of emergency breathing apparatus under strenuous conditions as required by Section 2 of Attachment 2 to NRC's fire protection guidelines.
(5) Section 7.2.3 of the FPP does not require that the brigade for each shift be drilled during a back shift at least once per year and at least one drill for each brigade to be unannounced each year as required by Secti6n 3.f of Attachment 2 to NRC's fire protection guidelines.
..m . (6) Section 7.2.2 of the FPP does not' require that fire brigade drills at three year intervals be critiqued by qualified indi-viduals independent of the utility's staff as required by Section 3.f of Attachment 2 to NRC's fire protection guidelines.
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- . . -S- , (7) Section 8 of the FPP does not require records of training provided to each brigade member, including site classroom training, drills and practice sessions, to be recorded in each brigade member's training records as required by Section 4 of Attachment 2 to NRC's fire protection guidelines. This data is needed to assure that each member receives training in all parts of the training program.
(8) The FPP does not identify the leaders of the fire brigade (" scene leaders") and the organizational structure of the brigade as promulgated by the FPP does not provide sufficient guidance to assure that a brigade leader will be on duty at the site at all times as stipulated by Section 1.f of Attachment 1 to the NRC's fire protection guidelines. The above discrepancies in the licensee FPP are a failure to meet a commitment to the NRC'and are identified as Deviation Item (338/80-03-02), Inadequate Administrative Fire Protection Procedures.
b.
Periodic Test Procedures for Fire Protection Systems The following periodic test procedures and recorded test and inspection data were reviewed and discrepancies noted: (1) 1-PT-100.1.1, Motor Driven Fire Protection Pump (FP-P-1) Weekly Inspection and test data from July 2, 1979 through February 4, 1980 were reviewed and found satisfactory.
(2) 1-PT-100.1.2, Diesel Driven Fire Protection Pump (FP-P-2) l Weekly inspection and test data from July 3, 1979 through February 5, 1980 were reviewed and found satisfactory, except records were not available to indicate that the pump was operated between September 4 and September 18, 1979 and between October 30 and November 13, 1979.
PT-100.1.2 requires this pump to be operated
weekly whereas Section 4.7.14-1 of the Technical Specifications only requires the pump to be operated monthly. The licensee was advised of the two instances in which the pump was riot operated as required by the test procedure.
(3) 1-PT-100.5, Fire Pump Diesel Inspection The required inspection and maintenance was accomplished on October 29, 1979. No discrepancies were noted.
^ (4) 1-PT-100.4, Fire Suppression Water System-Valve Cycling ' g.!, . The most recent test of these valves which was conducted on December 7, 1979, listed a number of valves that were not operated - , i--
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or inspected due to inaccessibility, or valves which had incortect numbers. The licensee has initiated a deviation port (DR 79-627) and is currently evaluating this problem.
This item is identified as Inspector Followup Item (338/80-03-03) l Review of DR 79-627 and will be reevaluated during a subsequent NRC inspection.
(5) 1-PT-104.1, Fire Protection High Pressure Carbon Dioxide System-Fuel Oil Pump House The most recent inspection of this system was conducted on August 10, 1979. A total of 8 months and 18 days existed between the recent inspection and the previous inspection of Novemher 22, 1978. Section 4.7.14.3 of the Technical Specification requires this system to be demonstrated operable by weight test of the i cylinders at least once each 6 months. The 8 months and 18 days between the last two inspections exceeded the maximum time of 7.5 months permitted by the Technical Specifications (6 months plus 25% extension allowed by Section 4.0.2.a of the Technical Speci-fications) and is identified as Noncompliance (Infraction) Item 338/80-03-04). Excessive time between the inspection and test of carbon dioxide fire protection system for fuel oil pump house.
(6) 1-PT-102.1, Low Pressure Carbon Dioxide System (Zones 1-1, 1-3,
2-3, 2-5 and 2-7) The most recent test conducted on this system was on December 6, 1979. The test report listed a number of minor discrepancies which were documented by Deficiency Report DR-79-633 and it appeared that appropriate corrective action was initiated.
(7) 1-PT-102.2, Low Pressure Carbon Dioxide System-Zones 2-8 and 2-9 The most recent inspection of this system was conducted on January 10, 1980. No discrepancies were noted.
(8) 1-PT-105.1.4, Fire Barriers The most recent inspection was January 13, 1980. No discrepancies were noted.
(9) 1-PT-105.2.1, Hose Rack Inspection-Safety-Related Areas The monthly visual inspeciion records of the fire hose stations (standpipe systems) from September,7, 1978 through January 31, 1980 were reviewed and found satisfact:ry, except the time between the March 8 and April 19, 1979 inspections was 42 days and between the September 7, 1978 and October 24, 1978 inspection was 47 days whereas Section 4.7.14.5 of the Technical Specifications requires . o $ L
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. . - ,m ' . . -7-J . these inspections to be conducted at least every 31 days. The maximum time permitted between inspections is 38.75 days (31 days plus 25 percent extension allowed by Section 4.0.2.a of the Technical Specifications). This is identified as Noncompliance (Infraction) Item (338/80-03-05), excessive time between inspections of fire hose stations.
The inspection guidance on PT-105.2.1 as well as the procedures for other " hose rack systems" do not indicate the quantity of hose required for each hose station. The licensee advised that the existing procedures will be revised to list the amount of hose required for each station. This item is identified as Inspector Followup Item (338/80-03-06), revision to fire hose rack inspection procedure, and will be reviewed during a subsequent NRC inspection.
~ l (10) 1-PT-106, Smoke Detectors The semi-annual inspection reports of November 8, 1978, May 2, . 1979 and November 12, 1979 were reviewed and found satisfactory, c.
Fire Fighting Procedures The current fire fighting procedures are dated July 18, 1977 and do not include many of the fire protection modifications presently being installed and do not reflect the current physical arrangement of the plant site. These procedures are currently being revised; therefore, this item is identified as Inspector Followup Item (338/80-03-07), revisions to fire fighting procedure, and will be reviewed during a subsequent NRC inspection.
d.
Fire Brigade Records (1) A review was made of the fire brigade training and drill records for 1979. The records available do not fully meet the NRC guide-lines and are not properly stored. These problems are discussed in above paragraphs 5.a and 3.c, respectively. Also, records do not indicate that brigade drills were conducted by the brigades during the fourth quarter of 1979. Section 6.4.2 of the Technical Specifications require fire brigade drills to be conducted at least every 92 days. This item is identified as Noncompliance (Infraction) Item (338/80-03-08), inadequate number of fire brigade drills for 1979.
(2) On August 6, 1979, a totil of 47 fire fighters from the Spotsylvania, Louisa and Mineral Volunteer Fire Departments participated in a joint training and fire fightin'g-dfill on the site with the North Anna Fire Brigade. The licensee udvised that this meeting was beneficial in that it provided an opportunity for the volunteer fire fighters to become familiar with the construction and fire protection features of the plant.
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Facility Tour (1) A tour was made of the cable spreading room, battery rooms, control room, Unit 2 containment, cable vault and tunnel and the emergency switchgear rooms for Units 1 and 2.
During the tour, a number of wood scaffolds were noted in which the wood appeared to be of the non-fire retardant treated type.
Samples of wood were taken from scaffolding in the Unit I cable vault and tunnel, emergency switchgear room and air handling equipment room. When this wood was exposed to an open flame, it easily ignited.
Section IV.B.3.c of the FPSR states that only flame-retardant wood is allowed in safety-related areas of the plant. Section 4.3.3.c of the FPP states that only flame retardant wood shall be used inside a permanent structure. The use of combustible wood within the plant was previously addressed as Inspector Foll'owup Item (338/79-10-01) in which the licensee committed to analyze and revise, as necessary, the flammable control program for wood to preclude recurrence of the use of combustible wood within the plant. The continued use of combustible wood such as scaffolding is considered a failure to meet a commitment to the NRC and is identified as Deviation Item (338/80-03-09).
Combustible wood used in safety-related areas of the plant. This action closes previous Inspector Followup Item (338/79-10-01).
(2) While touring the plant and the fire pump houses it was noted that the control valves in the fire protection systems which were not electrically supervised were provided with tamper-proof seals to assure that the valves would be maintained in the correct position.
Inspection procedure 1-PT-100.3, Fire Suppression Water System-Valve Position Verification, lists a number of valves in the fire protection system which are only required to be inspected monthly.
Inspection procedure 1-PT-103.1, Fire Protection-Deluge System, Post Indicator Valves, Hydrants and Low Pressure Carbon Dioxide Tanks, list additional valves which are required to be inspected weekly. Section IV.E.3.b of the FPSR states that all valves in the fire protection system which are not electrically supervised are provided with tamper proof seals and are inspected weekly to assure that the valves a're in the correct position. This discrepancy is considered a failure to met a commitment with the NRC and is identified as Deviation Item (338/80-03-10), Substandard Supervision of Fire Protection Control Valves. The methods of supervising fire protection control valves are listed in Chapter 6 of NFPA-26, Supervision of Water Supply Valves.
~ Except as noted above, within the areas examined, no additional items of noncompliance or deviatipes were identified.
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