IR 05000341/1987040

Insp Rept 50-341/87-40 on 870922-25 & 1223.Violations Noted. Major Areas Inspected:Fire Protection Program & Organization Including Administrative Controls,Maint & Test Program,Qa, Tech Spec Review,Deviation Event Rept & Requirements

ML20235A460
Person / Time
Site:	Fermi
Issue date:	12/21/1987
From:	Gardner R, Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235A446	List: IR 05000341/1987040 ML20235A443 ML20235A447
References
50-341-87-40, NUDOCS 8801120260
Download: ML20235A460 (10)

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U. S. NUCLEAR REGULATORY COMMISSION REGION RIII Report No. 50-341/87040(DRS)

Docket No. 50-341 License No. NPF-43 Licensee: The Detroit Edison Company 2000 Second Avenue Detroit, MI 48224

Facility Name: Fermi 2 L l

Inspection At: Fermi Site, Monroe, Michigan Inspection Conducted: September 22-25 and December 23, 1987

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Inspector:

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.wA 4 M ODD Approted By: Ronal N. Gardner, Chief '

Plant Systems Section Date Inspection Summary )

i Inspection on September 22-25 and December 23, 1987 (Report No. 50-341/87040(DRS))

Areas Inspected: Routine, unannounced inspection of the licensee's fire protection program and fire protection organization including action on previous inspection findings, fire protection organization, administrative controls, fire protection system inspection, maintenance and test program, quality assurance, fire protection technical specification review, fire protection deviation event report, and fire protection program requirements (30703 and 64704).

Results: Of the eight areas inspected, no violations were identified in six areas. Two violations were identified in the remaining areas, (failure to conduct quarterly fire brigade classroom instructionmeetings - Paragraph 3; ,

and discovery of the critical diesel fire pump discharge valve (F007) in the l unlocked open position - Paragraph 5).

8801120260 871230 PDR ADOCK 05000341 G PDR

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DETAILS l

1. Persons Contacted I

Detroit Edison 1

• R. C. Anderson, Plant Engineer L. P. Bregni, Senior Engineer, Licensing j

• S. Cashell, Licensing  !

• D. S. Eason, Fire Protection Engineer i

• D. J. Holland, Nuclear Fire Protection Specialist

• J. D. Leman, Director, Plant Safety

• R. S. Lenart, General Director, Nuclear Engineering

• R. D. Olson, Fire Protection Engineer

• E. Preston, Plant Safety Group

• W. Tucker, Superintendent, Operations

• J. J. Wald, Supervisor, Project Quality Assurance US NRC I

l M. E. Parker, Resident Inspector W. Rogers, Senicr Resident Inspector The inspector also contacted other licensee personnel during the inspection visi j

• Denotes persons attending the exit interview of September 25, 1987.

l 2. Action on Previous Inspection Findings

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The inspector attempted to review the status of two open items related to l fire protection. These open items were documented in Inspection Report

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No. 341/84049-04 (regarding a walkdown which identified an NFPA code deviation requiring installation of two and Inspection Report No. 341/84049-22regarding (gaugesthe in the Reactor approved Building),

revision of an emergency lighting surveillance procedure increasing the number of lighting units tested to twenty percent of the units required for safe shutdown). According to the licensee's staff neither of these items were ready for closure. However, during subsequent discussions between a Senior Licensing Engineer and the inspector on December 30,1987, the licensee committed to performing the necessary actions to resolve these two open items prior to startup from the upcoming Local Leak Rate Test scheduled for March 198 . Fire Protection Organization The inspector examined the activities of certain fire protection organization members. This examination included an interview with

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one fire watch individual, the witnessing of a fire brigade drill, and I

a review of certain fire brigade training record During this inspection there was no on-going cutting, welding, grinding or open flame work which would have allowed the inspector to observe accompanying fire watch activities. The inspector did interview an

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individual who performed fire watch dutie This fire watch individual was able to talk-through the necessary emergency actions required upon spotting a fire conditio Additional inspector discussions were held with the fire watch training instructor and Nuclear Fire Protection Specialist regarding the instruction provided fire watch personne According to the fire watch training instructor, the fire watch training I course consists of approximately four hours of instruction involving both classroom lecture and practical exercise As a result, the inspector determined that the fire watch individual level of knowledge and the related fire watch training appeared to be in accordance with the fire protection program approved by the NR As part of the fire protection organization review, the inspector requested an unannounced fire drill be conducted utilizing the on-duty operations shift personnel. As committed to by the licensee, Attachment No. 2 of the NRC document entitled, " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance," dated August 1977 indicated that fire brigade drills should be performed in the plant so that the fire brigade can practice as a tea This document further entailed other drill parameter The licensee commitment to the NRC document is described in the original Safety )

Evaluation Report (SER) and SER Supplement Nos. 2 and l j

The inspector requested a fire scenario which would require the fire brigade to demonstrate firefighting techniques (including fire hose handling) and which also would verify the adequacy of the communication interface between the fire brigade and Health Physics technician personnel during fire emergency conditions involving a radiation hazar The fire drill postulated the Reactor Recirculation system Motor Generator 8 lube oil pump B line rupturing causing a fir Also postulated was a contaminated water spill on the fire floor, the fourth floor of the Reactor Buildin The inspector reviewed the fire drill scenario and pre-fire plan which included a walkthrough of the " fire" area prior to the dril In preparing to witness the fire drill, the inspector also reviewed appropriate portions of licensee procedures which relate to fire discovery and subsequent fire extinguishment as follows: 1

+ Plant Operating Manual (POM) Procedure No. POM 20.000.22, " Plant Fires," Revision 9, dated May 22, 1987; and e POM 12.000.36, " Fire Brigade Facilitating Guidelines," Revision 10, dated August 11, 198 This fire drill was an unannounced drill initiated on September 23, 1987, at approximately 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br />. The inspector was stationed initially in the control room to observe the actions taken by the control room operators upon receipt of the fire alarm (a manual pull fire alarm station in the  ;

" fire" area was activated by licensee personnel).

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The inspector then proceeded to the fire brigade station and followed the fire brigade to the " fire" area observing their actions until the fire drill was terminate Approximately six fire brigade members and one health physics technician were observed assembling and donning protective clothing and Self-Contained Breathing Apparatus (SCBA) at the fire brigade station (fire equipment cage).

The inspector evaluated the fire brigade personnel actions in determining and observing the following: (1) fire brigade members'

conformance with established plant firefighting procedures; (2) an assessment of the fire brigade leader's direction of the firefighting efforts; (3) actual donning and simulated use of the SCBA; (4) actual donning of protective clothing; (5) simulated use of two 1 " fire hose stations; (6) use of portable radio communication equipment; (7) brigade timeliness in response and numbers of personnel responding with proper firefighting equipment; and (8) brigado leader interaction with the Health Physics personnel and other support personnel (e.g. security on scene).

The inspector determined the above act' ions were performed satisfactoril During the post-drill critique the inspector provided the following observations: Positive Observations

• Adequate manning and donning of fire protective clothing including SCBA was performed in a timely manne * Once activated the fire brigade responded promptly to the

" fire" scen Areas Needing Improvement J

l * The fire hose hand pulled to the " fire" floor was bunched up )

(dangled) which could have resulted in an ineffective fire l attack (kinked fire hose) if the fire hose was charged with i wate l

• A Health Physics Technician had difficulty in donning the assigned SCBA (breathing air line appeared to have been

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disconnected).

The two observations made regarding improvement being needed are considered an Open Item (341/87040-01) pending witnessing of additional fire drill (s) by a resident inspector and the determination of the drill (s) adequac Although timely assembly of the fire brigade and response to the fire scene occurred (orice the fire brigade was activated) a deficiency was identified regarding the " Plant Fires" Procedure No. POM 20.000.22, Revision 9, dated May 22, 1987. When an unplanned fire alarm activation (manual pull station or fire detector activation) is received on the control room annunciator panel an operator is dispatched to the fire alarmed area to investigate whether an actual fire is present or no .

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The immediate operator actions required by the plant procedure are to sound the fire alarm; announce the alarm over the Hi Comm System; and verify that the fire brigade has been activate Subsequent to the fire drill exercise having been completed, the inspector requested the control room operator to talk-through those actions taken upon receipt of the unplanned fire alarm on the control room annunciator panel. The control room operator as supported by the assistant shif t supervisor (and a Plant Safety Group member at the exit interview of September 25, 1987),

specifically made mention of delaying the activation of the fire brigade until confirmation by the dispatched operator that the fire condition was confirme As a result, the inspector determined the control room operator failed to follow the " Plant Fires" procedure to immediately activate (assemble) the fire brigade following receipt of the unplanned fire alarm on the control room annunciator pane As discussed during the exit interview on September 25, 1987, the fire detection system is installed to p; ovide early notification of a fire condition. The licensee's operations staff was unable to provide justification for not relying on this indication upon initial receipt and take action to immediately assemble the fire brigad Faiiing to follow the " Plant Fires" procedure may provide for an unacceptable time delay in the fire brigade's response to a fire if an individual is dispatched to an alarmed area without immediately activating and assembling the fire brigade after the annunciation on the control room panel of the activation of a fire alar At the exit interview the Nuclear Fire Protection Specialist indicated that observations made during other fire drills showed that control room operators followed the plant procedure as written by taking immediate action to verify the fire brigade was activate As described in the SER and Supplemental Nos. 2 and 5, the licensee committed to the NRC " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance" documen Attachment No. 5 of this document identified that the firefighting procedures identify actions to be taken by the control room operator and the need for fire brigade assistance upon receipt of a fire alarm on the control room annunciator pane The failure of the control room aperator to follow the " Plant Fires" procedure is considered an Unresolved Item (341/87040-02) pending further internal NRC revie By LER Report No. 87-049-01 dated November 6, 1987, the licensee indicated that training of each shift began on October ?, 1987 regarding the correct actions to take upon the receipt of a fire alar The licensee actions exhibit a technically sound and thorough approach to resolution of this issue from a safety standpoin Further review by the inspector in this area included a selected review of the fire brigade training record As requested by the inspector, the licensee provided records demonstrating the following: (1) that the 1985 and 1986 offsite fire department training drills were held as required; (2) that seven fire brigade members have been performing the necessary uumber of fire drills and classroom training as is specified by the licensee's Updated Finnl Safety Analysis Report (UFGAR); and (3) that Shift Six has been performing the necessary number of fire drills and classroom training as specified by the licensee's UFSA _ _ _ _ _

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However, regarding the fire brigade classroom requalification program, the licensee at mentioned previously is committed to the NRC " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance" document. The Fire Brigade Training Section which is Attachment No. 2 to that document specifies that " regular planned meetings held every three (3) raonths should repeat the classroom instruction program over a two year period". The current licensee policy specifies (as described in Section 13.2.4.1 of the UFSAR) that this classroom instruction program take place only once every two years. This classroom instruction program policy was also specified by the fire brigade training instructor and the Nuclear Fire Protection Specialis Since the NRC intended this training to be held quarterly as specified above, this is considered a Violation (341/87040-03) of the Facility Operating License as described in the Notice of Violatio The licensee submitted Licensee Event Report (LER) No. 87-049-01 detailing certain corrective actions to resolve this concern that will be reviewed during a future inspectio . Administrative Controls The inspector examined, in part, the licensee's fire protection administrative control procedure and the implemer<ation of this procedure while performing plant tours on September 22, 23, and 24, 198 The procedure reviewed was Procedure No. P0M 12.000.014, " Industrial Hazards Awareness," Revision 11, dated June 2, 1987. This procedure covers work involving ignition sources; the use, handling and storage of flammable and combustible materials; the designation of certain plant areas as no smoking or no open flame areas; and other fire prevention and safety topics. The inspector's review determined this procedure to be generally well writte During a plant tour on September 22, 1987, the inspector, while accompanied by members of the licensee's staff, performed a walkthrough of certain areas in the Reactor, Auxiliary, Turbine and RHR Complex Buildings to determine the licensee's implementation of the fire protection administrative procedure. The areas toured were determined to be in accordance with the administrative procedure, however, small amounts of rags were observed in the Reactor Building due to on going painting being performed while the plant was shutdown. Also, one 55 gallen drum of turbine oil was observed being stored in the Railroad Bay of the Reactor Building. The plant Nuclear Fire Protection Specialist contacted the responsible individuals explaining the hazards involved and had these materials promptly remove Since the amount of combustible observed was low or the safety significance of the identified combustibles was determined to be low, a violation of the above observations was deemed inappropriate. Licensee personnel at the exit interview of September 2(

1987, were reminded of the importance of controlling combustibles and flammable materials. Discussions between the inspector and resident inspector indicated that these observations appeared to be isolated instances having occurred while the plant was in a cold shutdown condition and while numerous work activities were on goin _ - _ _ _

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In addition, the inspector reviewed the completed inspection records of Procedure No. P0M 12.000.078, " Fire Protection Guideline," Revision 6, dated June 9, 1987 which was performed during May, June and July of 1987 to determine whether adequate fire protection administrative controls were being maintained. No problems were identified during this revie No violations or deviatior,s were identifie . Fire Protection System Inspection, Maintenance and Test Program The inspector reviewed, in part, the licensee's fire protection system inspection, maintenance and test program requirori by plant Technical Specifications (TS). Tha fire protection TS systems review consisted of an examination of completed surveillance packages and/or the witnessing of an in progress fire protection surveillance test of the following fire protection systems: (1) the diesel fire pump weekly battery inspection; (2) halon fire suppression system valve lineups; (3) eighteen month and .

nionthly fire hose station inspections; and (4) sprinkler fire suppression I system test including certain simulated autom? tic actuation test and valve ;

lineup verification i

• A weekly surveillance check of the diesel fire pump battery electrolyte levels, specific gravity and battery voltage were i performed to satisfy TS Surveillance 4.7.7. On September 25, !

1987, the inspector witnessed the satisfactory performance of this '

required surveillance tes Additional discussion regarding the diesel fire pump battery inspection is located in Paragraph 8 of the repor * The completed monthly halon valve lineup verification packages for the last quarter (October, November and December) of 1986 were provided to the inspector for revie The inspections were performed through the use of Procedure No. POM 24.504.01, Revision 4, dated April 14, 1986 and showed satisfactory completion so as to meet TS 4.7.7. * The most recently completed eighteen month and monthly fire hose station surveillance inspection packages performed were provided to the inspector for revie The May 1986 completed eighteen month surveillance and September 1987 completed monthly surveillance packages were provided showing satisfactory completion so as to satisfy TS 4.7.7.5.a and These inspections were performed through ;

the use of Procedure Nos. POM 24.501.09, Revision 5, dated March 19, j 1985 and POM 24.501.10, Revision 4, dated February 25, 198 ]

i The most recently completed eighteen month sprinkler system

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(simulated automatic actuation) surveillance test package was provided to the inspector for review. The test was performed through the use of Procedure No. POM 24.501.17, Revision 2, dated May 22, 1985 and showed satisfactory completion so as to satisfy i TS 4.7.7. l

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• The inspector, accompanied by licensee fire protection personnel, performed an unscheduled fire suppression water system valve lineup verificatio The inspector selected ten valves using Procedure No. P0M 24.501.02, Revision 11. datcJ December 29, 1986. During this valve lineup verification all valves were observed to be positioned in their proper position. however, the diesel fire pump discharge valve Numbered F007 was found unlocke Since the locked valves are designed to provide a positive control in assuring that the fire protection valves remain positioned in a manner to ensure availability of fire protection systems, the above mentioned unlocked valve is considered a Violation (341/87040-04) of TS Administrative Procedure Section 6.8.1 as described in the Notice of Violation. In addition, lengthy discussions were held during the inspection between the licensee's staff and the inspector rega-ding the acceptability of a lead seal in locking fire protection valves as is done at Fermi 2. It was learned that the NRC had issued an-interpretation through an NRC Manual Chapter indicating that any technique which provided evidence of unauthorized manipulation is acceptable including use of a lead sea Regarding the violation, the licensee submitted LER No. 87-049-01 which detailed certain corrective actions to resolve this concern that will be reviewed during a future inspectio { Quality Assurance  !

The inspector requested the licensee to provide those audits performed to satisfy TS Sections 6.5.2.8.e and f. The licensee provided Quality Assurance Audit Report No. A-QS-P/TS-87-01, dated January 8, 1987 which wac usej to satisfy these TS requirement A review, in part, of this audit report indicated that the licensee performed the scheduled audit as required verifying certain programmatic and implementation aspects of the in place fire protection progra However, the inspector determined after review of the audit report and following discussions with the licensee's staff that an improved interface between the designated systems engineer and fire protection engineer relative to Appendix R criteria review is needed during the performance of future fire protection QA audit This is considered an Open Item (341/87040-05) pending NRC review of licensee actions regarding this issu . Fire Protection Technical Specification Review As a result of discussions with a resident inspector, the inspector performed, in part, a review of certain fire protection TS's including the Appendix R Alternate Snutdown Instrumentation and Controls, and Carbon Dioxide System Sections. This review was conducted to determine whether all appropriate fire protection systems protecting equipment required to be available for safe shutdown of the plant relative to 10 CFR Part 50, Appendix R, as applicable to Fermi 2 were incorporated in TS' It was learned in discussions with members of the licensee's staff knowledgeable in Appendix R requirements that additional fire protection systems should be added to the appropriate TS list of systems protecting

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0 safe shutdown equipmen These fire protection systems include: (1) the fire hose station (s) protecting a panel needed for safe shutdown Numbered H21-P623; and (2) the CO2 system protecting the Combustion Turbine Generator (CTG) No.11. The inspector requested the licensee to further evaluate the need to add the above two fire protection systems to the appropriate TS list of systems protecting safe shutdown equipment.

l It is expected that the licensee will evaluate the specific systems discussed with the inspector and perform an overall evaluation of fire protection systems in TS. This is considered a Open Item (341/87040-06)

pending NRC review of the licensee's action Since the licensee has requested, by license amendment, permission to incorporate the fire protection program requirements from TS's into the UFSAR as described in letters dated March 6, 1987 and May 1, 1987, any additions the licensee determines to be necessary may be more appropriately incorporated into the UFSA d. Fire Protection Deviatinn Event Reports The inspector requested the licensee to provide the inspector with any in progress Deviation Event Reports (DER's) related to fire. protectio Consequently, the licensee provided DER's No.87-274, Electric Fire Pump Breaker Closing Coil Failure;87-330, Diesel Fire Pump Battery Surveillance Testing; and 87-336, Reoccurring Failures of Penetration Seal. DER No.87-274 regarded the closing coil shorting out during a starting of the electric fire pum DER No.87-330 regarded defective batteries causing a start-failure of the diesel fire pump that resulted from low surveillance acceptance criteria (this low acceptance criteria is in accordance with TS's). DER NO.87-336 regarded three fare rated penetrations requiring to be reworked five times in a three month perio Regarding DER Nos.87-274 and 336 the licensee has taken appropriate interim measures to resolve these problems but the Corrective Action Review Board (CARB) has yet to approve final corrective actions.

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batteries and on September 24, 1987, the CARB committee approved proposed final corrective actions. Completion of the final corrective actions for these three DER's, including revision of the diesel fire pump battery surveillance procedure (updates the planned amended fire protection l TS being incorporated into the USFAR) is considered an Open Item l (341/87040-07) pending NRC follow-up of these action . Fire Protection Program Requirements In discussions with licensee staff, it appeared that confusion exists as to the applicability of certain 10 CFR Part 50, Appendix R requirements as to whether these requirements apply to the Fermi 2 Facility. At the exit interview of September 25, 1987, the inspector mentioned that additional discussions with NRC Headquarters staff is necessary and thereafter, further discussion on this subject with appropriate licensee staff would occur.

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10. -Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, or which involve some action on the part of the NRC or licensee or bot Open items disclosed during 1 the inspection are discussed in Caragraphs 3, 6, 7 and 8 of the repor J 1 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether it is an acceptable item, a violation, a failure to meet a licensee commitment, or a deviation. -An unresolved item disclosed during the inspection is discussed in Paragraph 3 of the repor . Exit Interview The inspector met with licensee repra entatives (denoted in Paragraph 1)

at the conclusion of the inspection on September 25, 1987, and summarized-the scope and findings of the inspection. The inspector also discussed the likely informational content of the inspection report with regard to 1 documents reviewed by the inspector during the inspection. The licensee did not identify any of the documents as proprietary. On December 23, 1997, additional discussions were held between a member of the licensee's licensing staff and the inspector regarding this fire protection inspection finding l i

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