IR 05000341/1999005
| ML20204E423 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/19/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20204E410 | List: |
| References | |
| 50-341-99-05, 50-341-99-5, NUDOCS 9903250033 | |
| Download: ML20204E423 (12) | |
Text
_.
._
_
.__
__
. _ _ _
._._
_.
_. _ - -.
.
-
_. - _ _
.
'
U.S. NUCLEAR REGULATORY COMMISSION REGION lil
Docket No:
50-341 License No:
NPF-43 Report No:
50-341/99005(DRS)
Licensee:
Detroit Edison Company Facility:
Enrico Fermi, Unit 2 Location:
6400 N. Dixie Hwy, Newport, MI 48166 Dates:
March 8 to 11,1999 Inspectors:
D. Chyu, Reactor Engineer
Approved by:
Ronald Gardner, Chief, Engineering Specialists Branch 2 Division of Reactor Safety l
I
.
DR G
'
-
-
-.. -
.__
.
._
-
.... -
.
_. ~
.
. - - -.
l
.
- ,
1
.
l EXECUTIVE SUMMARY Enrico Fermi, Unit 2 NRC Inspection Report 50-341/99005(DRS)
,
This inspection reviewed the fire protection program, an aspect of Plant Support. This was an announced inspection conducted by one regional inspector. The following strengths and weaknesses were identified:
Minimal amounts of combustible material were acted in the plant and the material
.
condition of most fire protection equipment appeared to be good. The fire brigade tumout gear was well controlled (Section F2).
,
The inspector concluded that the fire protection procedures reviewed provided adequate
.
fire protection controls and were adequately implemented by station personnel (Section
'
F3.1).
The response from engineering personnci concerning the lack of trending of suppression
.
system coefficient of friction (C-factor) values used to compute hydraulic flow was prompt and demonstrated good engineering practices. One inspection followup item was identified to review the actual C-factor obtained from the next water suppression system surveillance (Section F3.2).
The inspector considered the performance of the fire drill to be good with the exception
that brigade memoers delayed entering the simulated fire area due to radio problems.
Fire protection and engineering personnel exhibited in-depth knowledge of the plant design and fire potection issues (Section F4).
The training for the onsite and offsite fire brigade members was acceptable. The
.
requirements for drill participation and medical examination were met with one minor exception (F5).
The inspector considered the fire protection audits to be acceptable (Section F7).
.
l.
i 4-e.,
. - - -....
..
.
-.
. -..-
.
\\
.
Report Details
IV, Plant SUDDort F2 Status of Fire Protection Facilities and Equipment a.
Inspection Scope The inspector toured the areas of the turbine, auxiliary, and reactor buildings and the control complex to observe the adequacy and control of combustibles, dampers, fire doors, hose stations, detection equipment, extinguishers, sprinkler systems, emergency lights, and housekeeping. The inspector reviewed NUREG 0798, Supplements 5 and 6,
" Safety Evaluation Report related to the operation of Fermi-2," dated March and July 1985 and Operations Conduct Manual MOP 11, " Fire Protection," Revision 3.
b.
Observations and Findinas Minimal amounts of combustible material were noted in the plant. At the time of the inspection, there were only six fire barrier impairments in the plant. The inspector verified that fire protection features as stated in the SERs were installed in various areas in the reactor and auxiliary buildings such as fire zones 1,2,4,5,6,7, and 13. No deficiencies were noted. The inspector also verified that administrative control for the separation zones as stated in SERs for fire zones 5 and 6 were established in MOP 11.
The material condition of most fire protection equipment appeared to be good. The primary and secondary fire brigade dress-out areas contained proper turnout gear and appeared to be well controlled.
c.
Conclusion Minimal amounts of combustible material were noted in the plant and the material condition of most fire protection equipment appeared to be good. The fire brigade tumout gear appeared to be well controlled.
F3 Fire Protection Procedures and Documentation
.
F3.1 Administrative Control and Surveillance Procedures a.
Insoection Scooe The inspector reviewed the following fire protection procedures to ensure that proper administrative controls were in place and that smillance was being performed on fire protection equipment:
Fire Protection Procedure (FPP) 28.508.01," Monthly Portable Fire Extinguisher
-
inspection," Revision 9 FPP 28.506.01, "Emoigency Lighting 30 Day inspection," Revision 17
-
FPP 28.501.08, ' Fire Hose Station Monthly inspection," Revision 2
-
.
.
.
-
-
..~
.
l
.
,
FPP 28.501.07, " Fire Hose Station Hydrostatic Test - BOP," Revision 5
-
l FPP 28.508.05," Monthly Fire Protection inspection," Revision 8
.
FPP 28.504.03," Fire Suppression Water System Simulated Automatic Actuation
.
l Test," Revision 7
!
Surveillance Procedure 28.504.02, " Diesel Fire Pump Engine Operability Test,"
.
Revision 13 FPP 28.504.01, " Electric Fire Pump Operability Test," Revision 8
-
FPP 28.504.05, " Fermi i Diesel Fire Pump Weekly Test," Revision 9
.
Material Management Conduct Manual MMM07, " Material issue, Control, Return l
.
and Delivery Offsite," Revision 4 Operations Conduct Manual MOP 10 " Fire Brigade," Revision 0
-
Operations Cmduct Manual MOP 11. " Fire Protection," Revision 3
.
b.
Observations and Findinas.
Through the review of surveillance procedures for fire hose and extinguisher inspection, the inspector verified that surveillance requirements were established not only for the fire hoses in hose reels but also for the ones located in various response carts and locker locations. In addition, requirements were established for dry chemical extinguishers located in the gang box to be used during hot work activities.
,
Operations Conduct Manual (MOP) 11, " Fire Protection," Revision 3, described various administrative controls within the fire protection program. Materials Management Conduct Manual MMM07, " Material issue, Control, Retum and Delivery Offsite," Revision 4, described the administrative control for material used in the plant. When personnel
.
needed to stage material (both noncombustible and combustible) in the plant for work, the material had to be requisitioned from the storeroom if quantity requested was greater than maximum quantity as specified in the storeroom computer, a bulk issue authorization form would be required to be reviewed by the fire protection specialist and chemistry personnel to ensure that the quantity of material did not pose any hazards.
Depending on the type of material being introduced, the fire protection specialist has the discretion to issue a transient combustible permit. The licensee indicated that the review for transient combustibles did not have a set of criteria but the fire protection specialist would review the amounts of combus'; %s being introduced into areas such that fire loading for that area would not be excu.49d. Based on this review, the permit would be issued and would identify possible limitations such as having a fire watch, staging of additional fire fighting equipment, etc. If the specialist was not certain that the amounts of combustible material would exceed the fire loading in that area, engineering review
,
would be requested to er sure that the fire loading limit was not exceeded. The inspector considered the administrative control for transient combustible material to be acceptable.
'
c.
Conclusion The inspector concluded that the fire protection procedures reviewed provided adequate i
fire protection controls and were adequately implemented by station personnel, i
i
1
,.y-.,
. - - - - -.
,,
,.s,--
,
-.--
.r.
- - _ _. - -
er w,
+
-, - - -
s.~..
-
- .----, -
__
_ _ _ _ _
. -
_. _
____.- _ _ _ _ _ _
_._._._____.m
_
'
,
F3.2 Hydraulic Calcu'ation and Surveillance for Fire Sucoression Water System
i
.
a.
Inspection Scoce i
The inspector reviewed FPP 28.504.10, * Hydraulic Profile for Fire Protection
'
Underground Fire Header," Revision 3 and FPP 28.504.04," Fire Suppression Water System Flow Test," Revision 1.
l b.
Observation and Findinas UFS AR Section 9A.6.2.2.1.g stated that the fire suppression water system shall be demonstrated operable by performing a flow test of the system in accordance with Chapter 8 Section 16 of the Fire Protection Handbook,15* Edition, published by the National Fire Protection Association at least once per three years.
Chapter 8, Section 16 of the Fire Protection Handbook stated that the major purpose of flow testing is to determine whether or not the available water supply could meet the water demand required for acceptable protection of identified fire areas. Section F of this chapter discussed plotting the test data on log paper, extrapolating water supply minus the 500 gpm hose demand, and correcting the data for elevation differences between the ground level and the top line of the sprinkler. Section G of this chapter discussed the
!
,
method of utilizing hydraulic gradient and pipe profile to calculate actual coefficient of friction (C-factor).
I The inspector reviewed FPP 28.504.04 which impl6mented the requirement of the subject UFSAR section. This procedure contained acceptance criteria of flow 21850 gpm with residual pressure 2 98 psig. The procedure did not contain an analytical tool to calculate actual C-factors as described in the Fire Protection Handbook. When questioned, the licensee could not readily determine the basis of the acceptance criteria as to the value of C-factors used. CARD 9912772 was initiated to document the lack of an analytical tool within the surveillance procedure to trend actua; C-factors as described in the Fire Protection Handbook.
The C-factor assumed in the hydraulic calculation was 90 for undergrot'
.ir'. ig.
This value correlated to a piping age factor of 20 years which was cont
- h the
.
Fermi operating history of 15 years. After questioning the lack of trending for actual C-facters, the licensee, using test data obtained from FPP 28.504.10, preliminarily determined that the current actual C-factor was about 90. This preliminary result showed that the water suppression system althougti currently operable, may have experienced accelerated degradation. The licensee planned to review the surveillance procedure and to validate the testing methodology to determine whether changes l
needed to be made to the surveillance procedure. This is considered an inspection l
followup item (IFl 50-341/99005-01) pending inspector review of actual C-factors obtained from the next performance of FPP 28,504.04 in 1999 to ensure that the C-factor was still within the bounds of the hydraulic calculation.
i
' 5 l
--.-44 a,.
-
s-m..-,
-,
r,.
,,,.
-
--,c
r
.,
- -..-
, -,
,-
- - - - -,, - - -
.
-. - -
....
_ - - _. -. -. - _.. -
.. -. - -. - - - - - -
.
.. - -
'
.
.
.
c.
Conclusion The inspector considered the engineering response to the lack of trending for actual C-factors for the suppression system to be prompt and demonstrated good engineering practices. One inspection followup item was identified to review the actual C-factor obtained from the next fire suppression water system surveillance.
F4 Fire Protection Staff Knowledge and Performance
,
a.
Inspection Scooe On March 9, the inspector observed an unannounced fire drill in the Unit 2 main lube oil reservoir area and the subsequent critique meeting. During the inspection period, the inspector also interviewed several fire protection and engineering personnel to understand the extend of their involvement in the fire protection program b.
Observations and Findinas Prior to the fire drill, the inspector reviewed the drill scenario and found it to be thorough.
After sounding the fire alarm, four brigade members and one brigade leader responded to the dress-out area in a timely fashion. The brigade leader exhibited good leadership and command and control of the brigade members. The brigade leader designated one two-person team to use foam and the other two-person team to use water as a backup to the first team for the simulated oil fire in the room. The team members also exhibited good team work by checking each other's equipment prior to entering the simulated fire area. However, the brigade members hesitated entering the area due to radio problems and did not employ other alternate communication methods. During this drill, good coordination from the control room operator was also evident. About 15 minutes into the drill, the control room operator reminded the brigade leader of the SCBA capacity for the brigade members and of possible additional relief personnel for the brigade members.
After the simulated fire was extinguished, the brigade members also simulated actions to i
ventilate the area.
During the critique meeting, all members participated and gave their comments freely.
The evaluators were critical of the excessive amount of time for the brigade members to enter the fire affected area. Expectations were given during the critique meeting for future radio problems so that effective fire fighting activities could take place earlier.
During several discussions with engineering personnel concerning the water suppression system, penetration seal deficiencies, and the fire hazard analysis, personnel exhibited in-depth knowledge of the plant design and fire protection issues.
The fire protection and engineering personnel appeared to have a good working relationship.
l
f
.- - -
.
-.
.-
_ _.
-.
.
..
.. - _... _
__
_ _ _
. _ _ _ _. _. _
_
m
_
.
__ _. _ _..
.
.
c.
Conclusion I
The inspector considered the performance of the drill to be good with the exception that brigade members delayed entering the simulated fire area due to radio problems. Fire protection and engineering personnel exhibited in-depth knowledge of the plant design and fire protection issues at the site.
F5 Fire Protection Staff Training and Qualification a.
Inspection Scope The inspector interviewed the fire protection training coordinator and reviewed the outlines for fire brigade member training and off-site fire department training.
b Observations and Findinas
,
The fire brigade members consisted of operators, fire protechon inspectors and security officers. The initial brigade training consisted of five-day classroom and hands-on exercises of fire protection equipment. The brigade leaders would also receive an additional 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of onsite classroom training on fire strategies and tactics. The contents of the initial training would be repeated in quarterly training sessions over a i
period of two years. The licensee also planned to include a fire extinguisher simulation to enhance training sessions. During the course of the second quarterly training session,
'
training utilizing live fire conditions would be given at an offsite facility. The inspector considered the contents of initial, annual, and quarterly training sessions to be acceptable.
The licensee also administered annual training to the local fire department personnel to familiarize them with plant operations, radiation protection practices, onsite fire protection equipment, licensee brigade training, and hazardous materials. The inspector considered the training with the off-site fire department to be acceptable.
The inspector reviewed the fire brigade drill record forms in 1998 and verified the following :
1.
Each shift had performed the required number of unannounced and backshift drills.
2.
Only fire brigade members responding in tumout gear were credited as having participated in fire drills.
3.
The onsite brigade members had participated in the required annual fire drill with the offsite fire department in 1998.
l The inspector also reviewed the physical examination due dates for the brigade members. The requirement for the annual examination was met with one minor exception. One security officer had a physical examination done in January 1999. which
did not include an EKG as required for fire brigade medical certification. The licensee
l
!
.. _ - - - -. _. _ - -... -
.
d
,
immediately denied the individual's qualification as a brigade member and initiated CARD 99-12322, * rong medical exam."
c.
Conclusion The inspector concluded the training for onsite and offsite fire brigade members was acceptable. The requirements for drill participation and medical examination were met with one minor exception.
- F7 Quality Assurance in Fire Protection Activities Per the quality assurance program, the licensee was required to perform a fire protection programmatic control audit once per 24 months. In addition, the fire protection e.quipment and program implementation audit, utilizing a qualified offsite engineer was to be conducted at least every third year. The inspector reviewed the triennial fire protection program audit reports in 1995 and 1997. The audit reports lacked details and specificity regarding the scope and audit assessments and the overall audit conclusion was not supported by the findings. The inspector reviewed the audit checklists to ensure that the scope included required elements. The licensee recognized the weakness in the report format and had since revised subsequent audit reports to include detailed scopes and assessments. The inspector considered the fire protection audits performed to be
,
acceptable.
F8 Miscellaneous Fire Protection issues F8.1 Closed LER 50-341/98003-01: Inadequate review of the dedicated shutdown system. In LER 50-341/96019, the licensee identified that a combination of multiple hot shorts could potentially open a drain path to the hotwell and cause a loss of CST inventory required for dedicated shutdown. This LER was closed in Inspection Report 50-341/98011. The licensee initiated a Temporary Change Notice (TCN) T09897 to close two P11 valves to isolate the drain path. Subsequently, operations determined that three other N2000 valves would provide better isolation due to ease of operation. However, this change was not reviewed by fire protection personnel with respect to spurious operation of equipment and locations of emergency lights. The abnormal operating procedure (AOP)
revision process did not require. review by fire protection personnel at that time.
Engineering personnel had since performed an evaluation and concurred with the decision to isolate N2000 valves instead of the P11 valves. This evaluation also identified the need to install additional emergency lighting in the pathway required for isolating the N2000 valves. The inspector considered the corrective actions to be acceptable. This item is closed.
F8.2 Closed URI 50-341-99002-02: Maintenance rule functional failure for emergency lighting battery. The inspectors determined that the emergency light unit performanc.e criteria included the monthly surveillance as well as the two-vear battery discharge tests without differentiation. By combining these two types of surveillance failure rates, the battery discharge failure rate could be masked by the monthly surveillance failure rate. On February 16,1999, the licensee separated these two types of surveillance activities into
.
-.
-
_. _ _
_
..
_
.,
-
.- -
-
--
.-. - -- -
. -
- -..-
-
--
.
e its own performance criteria. For the monthly surveillance, the criterion is now 97 percent success rate based on 2400 tests conducted every year. For the two-year test, the performance criterion is now 90 percent success rate based on 162 tests conducted over two years. There were six failures since 1996 (test population of about 200); this failure rate met the performance criterion for the two-year battery discharge tests. The inspector considered the separation of the performance criteria acceptable.
This item is closed.
F8.3 (Closed) LER 50-341-97014-00 and 01: Turbine building and auxiliary building mezzanine not fully meeting license condition 2.C.9. During independent design verification, unsealed electrical penetrations were identified in the auxiliary and turbine building walls which were rated three-hour fire barriers. Some penetrations were sealed from the auxiliary building side and others were sealed from the turbine building side. In addition, there were some penetrations of small sizes that were not sealed from either side. The inspector considered that a fire in the turbine building would not adversely affect the safe shutdown equipment in the auxiliary building due to the expected natural propagation of fire and hot gases and the high ceilings in the turbine building. The licensee had since repaired the penetrations. The inspector considered the corrective actions to be acceptable. This item is closed.
V. Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the inspection results to the members of licensee management at the conclusion of the inspection on March 11,1999. The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any material examined during the inspection should be considered proprietary. No proprietary information was identified, l
l l
.
_ _
-.-
-
-
._ -
_.-
- -..
. -.
--...__-
- -. -.
'
l l
,
..
PARTIAL LIST OF PERSONS CONTACTED Licensee R. Anderson, PSE-Electrical T. Bergner, Operations Superintendent J. Bragg, Audits Supervisor -
L. Chinavara, NUC Operations-Fire Protection P. Fester, Nuclear Operations R. Gaston, Compliance Supervisor K. Howard, Plant Support Engineering M. McDonough, PSE-Electrical Engineer J. Moyers, NQA Director W. O'Connor, Assistant Vice President J. Pendergast, Principal Engineer, Licensing N. Petersons, Nuclear Licensing J. Plona, Technical Manager B. Sarago, NUC Operations-Fire Protection Training S. Stasek, ISEG Supervisor J. Strausser, PSE - Electrical Engineering A. Wojjowicz, System Er 'ineer NRC S. Campbell, Senior Re font inspector
.
INSPECTION PROCEDURES USED IP 64704:
Fire protection IP 92701:
Followup ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-341/99005-01 IFl Review of actual C-factors obtained from FPP 28.504.04 G91td 50-341/98003-01 LER Inadequate review of the dedicated shutdown system 50-341/99002-02 URI Maintenance rule functional failure for emergency light. battery 50-341/97014-0 & 1 LER Turbine building and auxiliary building mezzanine not fully meeting license condition 2.C.9
_
..
.
. -..
.
..
.
_
_. _ _
- -
..
-
.-.
._
__ -
_ _ -.
'
.
.
LIST OF ACRONYMS USED AOP Abnormal Operating Procedure CARD Corrective Action Resolution Document CFR Code of Federal Regulation DRS Division of Reactor Safety FPP Fire Protection Procedure IFl inspection Followup item IPEEE Individual Plant Examination-Extemal Event LER Licensee Event Report NOS Nuclear Quality Assurance SER Safety Evaluation Report TCN Temporary Change Notice URI Unresolved item i
i t
i
j j
\\
,
l l
_ _._
_ ___ _. _ _... _. _ _ _ _
___.....
._.._._ _ _ __. _ _ _______ _ _
'
4 l
LIST OF DOCUMENTS REVIEWED Individual Plant Examination (Extemal Event) dated March 1996
Fire Protection Procedure 28.508.01, " Monthly Portable Fire Extinguisher inspection,"
,
l
'
Revision 9, dated January 6,1999 Fire Protection Procedure 28.506.01, " Emergency Lighting 30 Day inspection," Revision
-
17, dated January 6,1999 Fire Protection Procedure 28.501.08, " Fire Hose Staticn Monthly inspection," Revision 2,
-
dated December 9,1998 Fire Protection Procedure 28.501.07, " Fire Hose Station Hydrostatic Test - BOP,"
-
Revision 5, dated January 6,1999.
Fire Protection Procedure 28.508.05, " Monthly Fire Protection Inspection," Revision 8,
-
dated January 6,1999.
Fire Protection Procedure 28.504.03, " Fire Suppression Water System Simulated
]
.
Automatic Actuation Test," Revision 7, dated December 11,1998.
Surveillance Procedure 28.504.02, " Diesel Fire Pump Engine Operability Test," Revision
-
13, dated September 14,1998 Fire Protection Procedure 28.504.01," Electric Fire Pump Operability Test," Revision 8,
-
dated January 6,1999 Fire Protection Procedure 28.504.05, " Fermi 1 Diesel Fire Pump Weekly Test," Revision
-
9, dated September 4,1998 Material Management Conduct Manual MMM07 " Material Issue, Control, Retum and
.
Delivery Offsite," Revision 4, dated January 19,1999 Operations Conduct Manual MOP 10," Fire Brigade," Revision 0, dated August 25,- 1995
.
-
Operations Conduct Manual MOP 11 " Fire Protection," Revision 3, dated December 1,
'
-
1998 Abnormal Operating Procedure 20.000.22, " Plant Fires," Revision 30, dated January 14,
-
1998.
NOS Audit Report 97-0122, " Fire Protection Program," dated September 17,1997
+
NUREG-0798 Supplements 5 and 6, " Safety Evaluation Report related to the operation
-
of Fermi-2," dated March 1985 and July 1985 l
!
!
!
i
!