IR 05000338/1987037

Insp Repts 50-338/87-37 & 50-339/87-37 on 871019-23. Violations & Deviation Noted.Major Areas Inspected:Fire Protection

ML20195H184
Person / Time
Site:	North Anna
Issue date:	12/21/1987
From:	Conlon T, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20195H171	List: IR 05000338/1987037 ML20195H166 ML20195H173 ML20195H180
References
50-338-87-37, 50-339-87-37, NUDOCS 8801150317
Download: ML20195H184 (13)

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UNITED STATES c

c[g youq' NUCLEAR REGULATORY COMMISSION

[S- REGION il f ', b, ,,

101 MARIETTA STREET, "-. ATLANTA, GEORGI A 30323 g,+.v p

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Report Nos.: 50-338/87-37 and 50-339/87-37 Licensee: Virginia Electric and Power Company Richmond, VA 23261 Docket Nos.: 50-338 and 50-339 License Nos.: NPF-4 and NPF-7 Facility Name: North Anna 1 and 2 Inspection Conducted: October 19-23, 1987 Inspectors: 2r els h /2[N!87 Date Signed G. R. Wiseman'

Accompanying Personnel: D. C. Ward Approved by erht /V)/

T. E. Conlon, Chief

_ /ZDate'1[d'7 Signed Plant Systems Section Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection as in the areas of fire protaction Results: Two violations and one deviation were identified - Failure to Develop and Implement Surveillance Procedures for Appendix R Fire Barrier Wrap Enclosures, Fire Stops, and Radiant Energy Shields, paragraph 5.b.; Failure to Implement Fire Brigade Training and Timely Corrective Action for Fire Protection QA Audit Findings, paragraph 5.e(2).; and, Installed Fire Detection System in Unit 2 Quench Spray Pump House is not in Conformance with Commitments for Full Area Coverage, paragraph 5.f(2).

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8801150317 880106 PDR 0 M ADOCK 05000330(hk ,

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REPORT DETAILS Persons Contacted

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Licensee Employees

• E. Douberly, Director - Loss Prevention

• H. Harrell, Station Manager

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J. Leberstien, Licensing Engineer

• G. Morcarski, Loss Prevention Coordinator

• W. Robbins, Corporate - Loss Prevention

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Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security force members, and office personne NRC Resident Inspectors J. Caldwell L. King

• Attended exit interview Exit Interview The inspection scope and findings were sumarized on October 23, 1987, with those pert.,ons i .dicated in paragraph 1 above. The inspectors described the areas inspected and discussed in detail the inspection findirigs. No dissenting coments were received from the licensee. The following new items were identified during this inspection: Violation Item (338, 339/87-37-01) - Failure to Develop and Implement Surveillance Procedures for Appendix R Fire Barrier Wrap Enclosures, Fire Stops, and Radiant Energy Shields, paragraph Inspector Followup Item (338, 339/87-37-02) - Emergency Lighting Surveillance Procedure Does Not Include Light Beam Aiming Details for Safe Shutdown Equipment Illumination -

paragraph Violation Item (338, 339/87-37-03) - Failure to Implement Fire Brigade Training and Timely Corrective Action for Fire Protection QA Audit Findings, paragraph 5.e(2). Deviation Item (339/87-37-04) - Installed Fire Detection System in the Unit 2 Quench Spray Pump House is Not In ConforTnance with Commitments for Full Area Coverage, paragraph 5.f(2).

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The licensee-did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspectio . Licensee Action on Previous Enforcement Matters 4

. (0 pen) URI (338, 339/85-24-01), Review PWR Station,_ Appendix R, Reanalysis and Fire Protection Program. During this inspection, items 85-24-03, 04, 05, 06, 07, 08, 09, 11, 12, 13, and 15 were close These items had been tracked as part of this Unresolved Item. The following three items remain open as part of 85-24-01:

URI 85-24-02 IFI 85-24-10 IFI 85-24-14 This item remains open pending resolution of the open issue (Closed) URI (338, 339/85 24-03), Review of Seismic Gap Fire Barrier Penetration Seal The licensee has performed an engineering evaluation addressing the design and fire testing of the seismic gap fire barrier penetration configuration This evaluation was submitted to NRC/NRR for review by VEPC0 letter Serial No.86-065 (W. L. Stewart to H. R. Denton) dated March 21, 1986. Based on these i licensee actions, this item is close (Closed) DEV 338, 339/85-24-04, Installed Penetrstion Seals Are Not In Conformance With Approved Tested Configuration. The licensee's respense to the deviation dated December 13, 1985, was reviewe This indicat(d that the licensee has performed a Generic Letter 86-10 *

engineering evaluation to justify the penetration seal designs and installation. The evaluation was submitted to NRC/NRR for review by '

letter Serial No.86-065 (W. L. Stewart to H. R. Denton) dated March 21, 1986. The licensee indicated that the FSAR Section 8.3 did not accurately reflect the requirements of fire resistance testing for the penetration fire seal The FSAR was revised in a 1986 amendment revision to reflect the penetration fire seal design for the plant. Based on these licensee actions, this item is close , (Closed) URI 338, 339/85-24-05, Re-entry Into Fire Areas to Perform Appendix R Hot Standby Shutdown Function The licensee has performed engineering evaluations for justification for operator access to the charging pump cubicles and motor driven auxiliary feedwater pump rooms to perfonn actions for hot standby. These evaluations were submitted to NRC/NRR for review by letter ,

W. L. Stewart to H. R. Denton (Serial No.86-065) dated March 21, l

1986. Based on these licensee actions, this item is close (Closed) URI 338, 339/85-24-06, Submittal and Review of an Exemption Request from Providing a Suppression and Detection System in the Area of Valves MOV 1115B and MOV 2115B in Fire Area 1 The charging pump l

suction valves MOV 11158 and MOV 2115B are located on the 244'-6"

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elevation of the auxiliary building (Fire Area 11). The licensee by letter dated May 1, 1984, and , supplemented by letters dated October 31, 1984, August 21,1985, March 21,1986, and September 30, 1986, requested an exemption from the requirements of Appendix R,Section III.G.3 to the extent that full area' fire detection and fixed suppression systems are not installed throughout the fire area. Fire .

detection is provided in the vicinity of the charging pump power

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cables and other cable concentrations on elevations 244'-6" and 259'-6". By letter dated November 6,1986, the NRC issued a-supplemental Safety Evaluation Report ~ (SER) which granted the exemption for full area detection coverage. Based upon this action, this item is closed.

c (Closed) URI 338, 339/85-24-09, Review and Resolution of Appendix R Exemption Requests. By letter dated May 1,1984 and as supplemented by letters dated October 31, 1984, August 21,1985, March 21,1986 and September 30, 1986, the licensee requested from the NRC 34 -

exemptions from Appendix R to 10 CFR Part 50. By letter dated November 6,1986, the NRC 1ssued to the licensee the NRC exemption ;

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SER which indicated that 12 exemptions were granted, three exemptions were determined to not be needed, and 9 exemptions were found to be .

equivalent to the guidelines of BTP 9.5.1, and therefore were deemed ,

acceptable, and ten exemptions had been withdrawn. Based upon issuance of this supple.nental SER, this item is considered close , (Closed) URI 338, 339/85-24-11, Licensee's Re-evaluation of Conduit Penetration of Fire Barriers to Determine if Penetrations Are Properly Sealed. The licensee's criteria for conduit penetration seal configuration was reviewed by NP.C/NRR &nd determined to be acceptable as denoted fri Section 14.2.9 of the NRC exemption request SER dated November 6, 1986. Based upon this review and acceptance, this item is considered close (Closed) URI 338, 339/85-24-12 Suhetandard Fire Barrier Penetration Seal The licensee has performed an engineering evaluation addressing the penetration fire seal configurations which have not been laboratory approved. This evaluation was submitted by VEPC0 to the NRC/NRR for review by letter dated March 21,1986, (Serial No. 86-05). Based on the licensee action, this item is considered close . (Closed) URI 338, 339/85-24-15, Direct Reading of RWST Level Not Available Outside the Control Room. An exemption was requested by the licensee from the requirement of Section III.L.2.d. of Appendix R to the extent that it requires process monitoring to be capable of providing direct readings of process variables necessary to perform and control required functions. The level monitoring of the RWST does not meet the Appendix R requirements because a fire can damage L_

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RWST level indicatio The NRC ' exemption request SER dated November 6, 1986, granted this exemption based on the licensee's evaluation that there is sufficient margin of RWST water volume to achieve Appendix R safe shutdown, therefore, this item is close . Unresolved Items Unresolved items were not identified during this inspectio . Fire Protection / Prevention Program (64704) Fire Prevention / Administrative Control Procedures The licensee's fire protection / prevention procedures are denoted in the Fire Protection Manual entitled, "North Anna Power Station - Fire Protection Program," dated August 29, 1986. This procedure was reviewed by the inspectors and found to meet provisions .of the applicable NRC guidelines provided in the Branch Technical Position CMEB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants." Fire Protection Surveillance Procedures The inspectors reviewed the following Fire Protection System Surveillance Procedures:

Procedure No2 Title 1-PT-100.2, Rev. 9 Fire Protection Puinps - Annual Testing 1-PT-100.3, Rev. 20 Fire Suppression Water System - Valve Position Veriification 1-PT-103.1, Rev. 15 Fire Protection - Deluge Systems, Post Indicator Valves, Hydrants, and Low Pressure CO, valves 1-PT-105.3, Rev. 3 Hose House Inspection 2-PT-109.1.3, Rev. 2 Fire Protection - Deluge and Sprinkler System - H, seal Oil Unit The above surveillance procedures were reviewed to determine if the various test outlines and inspection instructions adequately implement the surveillance requirements of the plant's Fire Protect'on Technical Specification In addition, these procedures were ree. awed to determine if the inspection and test instructions followed general industry fire protection practices, NRC fire protection program guidelines and the guidelines of the National Fire Protection Association (NFPA) Fire Code Based on this review, it

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appears that the Fire Protection System surveil?ance procedures are satisfactory, except, it was identified that surveillance procedures had not been developed for the periodic inspection of fire barriers, fire stops, and radiant energy shields. These fire protection features were installed to satisfy the separation requirements of 10 CFR 50, Appendix R, Section III.G. The fire barriers, fire stops, ano radiant energy shields were installed under Design Change DC-84-2 This Design Change required the development of inspection procedures; however, no such procedures were developed or implemented. This is identified as Violation Item 338, 339/87-37-01, Failure to Develop and Implement Surveillance Procedures for Appendix R Fire Barriers, Wrap Enclosures, Fire Stops, and Radiant Energy Shield In addition, the incpectors expressed concern that there appeared to be no comprehensive plant program developed for the surveillance and limiting conditions for operation of Appendix R remote auxiliary shutdown panels, switchgear, instrumentation, and othe'

transfer / isolation panels. This equipment was installed to t'+u fy the remote shutdown requirements of 10 CFR 50 Appendix R, Section III.L. Surveillance of the remote shutdown equipment would provide assurance that the remote shutdown system is operable to accomplish it's intended safety function when required. The licensee indicated that this issue would be reviewe Procedures E11-ELT/M-1 and E21-ELT/M-1 outline the surveillance requirements for emergency lights installed to satisfy the illumination requirements of 10 CFR 50, Appendix R, Section III.J. A review of the procedures found that inadequate information is provided regarding the aiming of the lights and the safe shutdown equipment to be illuminated. This is identified as Inspector Followup Item 338, 339/87-37-02, Emergency Lighting Surveillance Procedures Does Not Include Light Beam Aiming Details for Safe Shutdown Equipment Illuminatio c. Fire Protection System Surveillance Inspections and Tests The inspectors reviewed the following surveillance inspection and test records for the dates indicated:

1-PT-10 Fire Protection Pumps - Annual Testing Test Results Between 3/84 and 10/87 1-PT-100. Fire Protection - Deluge System PIVs, Hydrants, and Low Pressure CO, Tanks (7 days)

1-PT-10 Fire Protection - Main Fire Loop Flow Test (3 year) Test Results between 8/78 and 7/85

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1-PT-10 Hose House Inspection (31 days) Test Results between 1/87 and 9/87 ,

The surveillance test record data and testing frequency associated with the above- fire protection cystem surveillance test / inspections t were found to be satisfactory with regard to meeting the requirements of the plant's Fire Protection Technical Specifications, Fire Protection Audit The triennial audit report of the North Anna . Fire Protection Program was reviewe The audit identified several fire' protection discrepancies and unresolved items, and recommended several program improvements. With the exception of the violation item identified in paragraph 5.e., the licensee has either implemented the corrective actions associated with these audit findings or a scheduled date for '

completion of the correction actions had been establihsed. The licensee appears to be taking the appropriate corrective actions on  ;

the other audit finding ! Fire Brigade (1) Organization ,

i The total station fire brigade is composed of approxirstely 75 :

personnel from the operations and security staff. The on duty i 4 shift fire brigade leader is normally one of the opertors and the remaining four fire brigade members are composed of operators and security personne The inspectors reviewed the shift brigade on duty October 21, 1987, and verified that sufficient qualified fire brigade personnel were on duty to meet l the provisions of the plant's Techical Specificatio l (2) Training

The inspectors reviewed the training and drill records for five i

brigade leaders and 11 brigade members for the period from 1/86 through 10/87. The records reviewed indicated that each of these leaders and members had received an annual medical review, attended the required training and participated in the required numoer of drills. The fire brigade training records inspected

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for these brigade members were found satisfactory.

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Tha inspectors reviewed the shift drill records for 1986 and 1987 to establish that each brigade sh'.ft participated in one drile per quarter in accordance with thu licensee's Technical

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Specifications and Fire Protection Progra The records indice.ted the following fire brigade shifts did not participate in starterly drills as indicated:

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Shift Quarter Operations A 2nd 87- i Operations B 2nd 87

' Operations C 2nd and 3rd 87 Operations D 4th 86 Operations E 2nd 86 Security B 2nd 87 Security C 2nd and 3rd 87

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Failure to complete quarterly drills was previously identified as a finding in the licensee's Triennial Fire Protection Audit; however, no corrective action has been taken to correct this finding. . This item is identified as Violation Item 338, T 339/87-37-03, Failure to Implement Fire Brigade Training and Timely Corrective Action for Fire Protection QA Audit Finding i In addition. the inspectors observed a fire brigade training i session dealing with fire event heat and smoke ventilation. The

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raterial covered during this session appeared to be adequat t (3) Fire Brigade Fire Fighting Strategies The inspectors reviewed the following plant fire fighting strategies:

1-FS-A-3 Auxiliary Building Elevation 274'

1-FS-CP-1 Charging Pumps Elevation 244'-6"

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1-FS-MS-1 Main Steam Valve House Unit 1 1-FS-0-2 Auxiliary Feedwater Pumphouse #1  !

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i 1-FS-5-8 Diesel Rooms - Service Building Elevation 271' -

Except as noted in paragraph 5.e.(4) of this report, the inspectors determined that the above fire fighting strategies .

adequately addressed the fire hazards in the area, the type of  !

fire extinguishants to be utilized, the direction of attach,  ;

systems in the room / area to be managed in order to reduce fire ,

damage, heat sensitive equipment in the room / area, and specific

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fire brigade duties with regard to smoke control and salvage, j (4) Fire Brigade Drill  ;

, i During this inspection, the inspectors witnessed an unannounced i backshift fire brigade dril The drill fire scenario was a i fire in the Unit 1 Motor Driven Auxiliary Feedwater Pump (MDAFWP) House which was apparently caused oil leak in the Train  :

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Five fire brigade members responded to the pending fire ,

1 emergenc The brigade assembled outside the pumphouse in full i

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protective fire fighting turnout clothing and self-contained breathing apparatus. An initial size-up of the fire condition was made by the fire brigade leader and one li inch fire attack hose line was advanced into the MDAFWP room. The fire attack hose _ line was placed in service on the fire and the fire was ,

placed under control in approximately 15 minutes. In addition, the fire brigade initiated fire victim search and rescue, smoke r control, and water control operation :

The fire brigade utilized proper manual fire fighting methods and reacted to the fire drill scenario in an effective and efficient manne .

The inspectors made the following recommendations based upon *

their evaluation of the drill:

- Health Physics personnel should participate in drills for I the radiological safety of the fire brigade member A backup line should always be provided prior to entering the area involved in the fir Although the fire fighting strategy drawing for the fire

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area indicated redundant safe shutdown equipment in the area, the text associated with the drawing should be t updated to include information on how to protect this equipmen This recommendation applies to all strategies for fire areas containing redundant safe shutdown equipmen This item was previously identified as '

Inspector Followup Item 338, 339/85-24-14, Licensee to Revise Pre-Fire Plans to Address Inadvertent Application of

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Suppression Agents to Redundant Equipment. This item

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remains open, f. Plant Tour and Inspection of Fire Protection Equipment l (1) Outside Fire Protection Walkdown

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were in service. The electric fire pump was inspected and all valves were found to be properly aligned for pump service, i The following sectional control valves in the outside fire

! protection water supply system were inspected and verified to be  ;

properly aligned and locked in position: [

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1-FP-97 Open 1-FP-105 Op en -

1-FP-73 Open 1-FP-110 Open 1-FP-53 Open 1-FP-71 Open The following fire hydrants and- fire hydrant equipment house were inspected: A, F, and The equipment houses contained the minimum equipment requirement-of that specified by NFPA-24, Private Fire Service Mains and Their Appurtenances, and/or the FSAR commitments. The equipment appeard to be adequately maintaine A tour of the exterior of the plant indicated that sufficient clearance was provided between permanent safety-related buildings and structures and temporary buildings, trailers, and other transient combustible materials. The general housekeeping of the areas adjacent to the permanent plant structures was satisfactor (2) Permanent Plant Fire Protection Features A plant tour was made by the inspector During the plant tour, the following safe shutdown related plant areas and their related fire protection features were inspected:

Fire Area 2 Control Room Fire Area 3-1 Unit 1 Cable Vault and Tunnel Fire Area 3-2 Unit 2 Cable Vault and Tunnel Fire Area 6-1 Unit 1 Emergency Switchgear Room Fire Area 6-2 Unit 2 Emergency Switchgear Room Fire Area 11 Auxiliary Building - Component Cooling Water Pump Area Fire Area 14B-1 Unit 1 Auxiliary Feedwater Pump House Fire Area 15-2 Unit 2 Quench Spray Pump House The fire / smoke detection systems, manual fire fighting equipment (i.e., portable extinguishers, hose stations, etc.) and the fire area boundary walls, floors and ceiling associated for the above plant areas were inspected and verified to be in service or functiona The inspectors reviewed the fire barrier cable enclosures and fire stop installation provided for the component cooling wrter (CCW) pump and charging pump separation. The barrier enclosures and fire stops appeared to be functional. A surveillance program for these fire protection features has not yet been

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develope This is identified in paragraph 5.b. as Violation Item 338, 339/87-37-0 In addition, the inspectors reviewed the fire detection system in the Unit 2 Quench Spray Pump Hous The licensee had committed to upgrade the detection system in this fire area to full area coverage in a letter dated May 1,1984, and as supplemented by letters dated October 31, 1984, August 21, 1985, March 21, 1986, and September 30, 1986. In these letters, the licensee requested an exemption from the requirement to provide area wide suppression in this area as required by 10 CFR 50 Appendix R, Section III. The justification for this exemption included the upgrade of the detection system to provide full area coverage. Revision 3 to the North Anna 10 CFR Appendix R report enclosed in the Virginia Power letter dated March 21,1986, to the NRC/NRR indicated in Section III-5 that the proposed detection modification was complete in construction. However, during the inspection, it was noted that this upgrade to provide additional detectors at the ceiling level of the upper compartment of the Quench Spray Pump Room had not been implemented. Through conversations with licensee representatives, on December 14, 1987, it was indicated that the additional detectors for the upper compartment were inadvertently not included in the scope of the Design Change Package DC-83-18 which provided other detection system modifications in the Quench Spray Pump Hous Based on tne above, it was concluded that the connitment to provide full area detection coverage in the Quench Spray Pump House was not fully implemented and the statement in the March 21,1986 letter, was in error. This is identified as Deviation Item 339/87-37-04, Instclied Fire Detection System In Unit 2 Quench Spray Pump House Is Not In Confonnance with Commitments for Full Area Coverag The automatic sprinkler systems installed protecting the CCW pumps and the C0, system installed in Unit 2 Diesel Generator Rooms were inspected and found to be in servic Based on this inspection, it appears that the fire protection features associated with the above plant areas are satisfactorily maintaine The plant tour also verified the licensee's implementation of the fire prevention administrative procedure The contr.' of combustibles and flammable materials, liquids and gases, and the general housekeeping were found to be satisfactory in the areas inspecte _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ - _ _ _ _

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(3) Appendix R Fire Protection Features The inspectors- visually inspected the fire rated raceway fire barriers required for compliance with Appendix R,Section III.G.2 in the CCW pumps and charging pumps areas of Fire Area 11. Based on the inspectors observations of the raceway fire barrier enclosure, it appears that the one hour

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fire barrier integrity associated with the above fire barrier assembly was being properly maintained in a satisfactory i conditio The inspectors made a walkdown of the Appendix R automatic

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suppression systems in the following fire areas and verified their operability:

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Fire Area 3-1 Total Flooding CO, Unit 1 Cable Vault and Tunnel l- Fire Area 3-2 Total Flooding CO, Unit 2 Cable Vault and Tunnel

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Fire Area 11 Wet Pipe Sprinkler CCW Pump Area The following eight-hour emergency lighting units were inspected:

Unit N I-ELT-TB-017 1-ELT-TB-016 1-ELT-TB-015 2-ELT-ES-003 2-ELT-ES-005 2-ELT-ES-006

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These units were in service and appeared to be properly maintained; however, many units observed did not appear to be l

properly aligned to fully illuminate safe shutdown equipment in the area. The surveillance procedure for these lights does not include details to direct the lights to specific pieces of safe shutdown equipmen This is identified in paragraph 5.b. of this report as Inspector Followup Item 338, 339/87-37-0 Except as noted above, within the areas inspected, no additional violations or deviations were identifie L

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! InspectorFollowupItems(IFIs) (Closed) IFI 338, 339/85-24-07, Verification of Fire Resistance Rating of Fire Dampers Between Switchgear Room By letter dated September 18, 1985, the fire damper vendor provided the licensee wit the proper three hour labels (nos. H483518 and H483519). The 11-hour labels were removed from the dampers and the new labels were affixe The remains of the li-hour labels were returned to the vendor. Based on this action, this item is close (Closed) IFI 338, 339/85-24-08, NRC Review of Completed Appendix R Fire Protection Modifications: This item was identified during the Appendix R inspection on September 198 At that time, Appendix R Modifications I-6 through I-13 had not been completed. During this inspection, the inspectors reviewed Design Change Packages DC-84-41, D0-84-42, DC-84-65, DC-84-66, DC-84-63, and DC-84-62 which implemented the completion of the above modifications. Revision 3 to the licensee's safe shutdown and fire hazards analysis submitted to NRC/NRR by letter dated March 21, 1986, indicated that Modifications I-6 through I-13 had been verified complete by the licensee. Based on the review of the completed design change packages and the plant walk through during this inspection, it appears that the modifications have been completed, therefore, this item is closed, (Closed) IFI 338, 339/85-24-13, Sensitivity Calibration Is Not Included As Part of Smoke Detector Maintenance Program: During this inspection the inspectors reviewed the ionization smoke detectors vendor manuals R-21 and R-22 for the Robertshaw Model F655 smoke detectors. The vendor indicates that the sensitivity of these detectors is factory set and no field testing for sensitivity is required. The vendor does recommend periodic field cleaning of the detector internal chambe The inspectors verified that this cleaning is performed during the conduct of Periedic Test PT-10 for the detection systems. Based on this review. it was verified that the sensitivity testing is not required by the vendor, therefore, this item is close .