IR 05000346/1982003
| ML20054D134 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/24/1982 |
| From: | Grobe J, Mendez R, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20054D120 | List: |
| References | |
| 50-346-82-03, 50-346-82-3, TAC-48364, NUDOCS 8204220371 | |
| Download: ML20054D134 (10) | |
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l U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report No. 50-346/82-03(DETP)
Docket No. 50-346 License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza, 300 Madison Avenue Toledo, OH 43652.
Facility Name: Davis-Besse Nuclear Power Station Inspection At: Oak Harbor, OH Inspection Conducted: January 11-15, 1982 f0W [b l
3 / AM,/[1 Inspectors:
J. A. Grobe i
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(Ph %
skf 3/AJ//[.1 R. Mendez
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Approved By:
C. C. Williams, Chief 3/ A /!
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Plant Systems Section
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Inspection Summary Inspection on January 11-15, 1982 (Report No. 50-346/82-03(DETP))
Areas Inspected: Routine unannounced inspection to review the imple-mentation of the licensee's fire protection and and prevention programs including review of fire fighting equipment and systems; fire protection and prevention administrative controls; and fire brigade, general employee, and contractor fire protection and prevention training. The inspection involved 88 inspector-hours onsite by two (2) NRC inspectors including 16 inspector-hours off-shift.
Results:
In the three areas inspected, six apparent items of noncompliance were identified (Violation of the limiting condition for operation for fire barriers - Paragraph 2; Lack of fire suppression system in the control
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room - Paragraph 2; Lack of implementation of administrative controls over combustible materials, ignition sources and fire briagde training - Para-graphs 3 and 4; Lack of formulation of adequate administrative controls over the fire protection program, fire protection / prevention training, combustible materials, ignition sources, and fire brigade training -
Paragraphs 3'and 4; Incomplete quality assurance audits of the fire protection program - Paragraph 3; Lack of corrective action on identified deficiencies in the fire brigade training program - Paragraph 4).
8204220371 820401 PDR ADOCK 05000346 G
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DETAILS
'1.
Persons Contacted
- T.
Murray, Station Superintendent
- B.
Werner, Administrative Coordinator
- D.
Miller, Operations Engineer
- F. Ross, Fire Marshall
- W. Nissen, Fire Protection Coordinator E. Wasil, Fire Protection Engineering Consultant J. Hanson, Instrumentation and Control Maintenance J. Nixon, Surveillance Coordinator
- J. Walczak, Quality Assurance Engineer B. Franka, Training Supervisor J. Lammon, Shift Supervisor T. Meyer, Licensing Manager R. Peters, Station Licensing Engineer T. Hart, Facility Engineer - Fire Protection
- Indicates those persons present at the exit interview on January 15, 1982.
2.
Fire Protection and Emergency Systems and Equipment The inspectors examined the licensee's fire protection and emergency systems and equipment including the fire detection system, fire sup-pression water supply system, spray, sprinkler and water curtain systems, emergency lighting system, penetration fire barriers, hose and standpipe stations, portable fire extinguishers, and self-contained breathing apparatus. These systems and equipment were reviewed using the commitments and requirements in Amendment No. 18 to License No. NPF-3 including the Fire Protection Safety Evaluation Report, issued July 26, 1979, the Fire Hazards Analysis Report (Revision 6),
issued May 15, 1980, the plant Technical Specifications for the fire protection systems, 10 CFR 50.48 and 10 CFR 50, Appendix R.
a.
Areas of Inspection (1) Procedures Number Title Dates ST 5016.01 Fire Protection System 12/03/81, 12/10/81, Diesel Pump Weekly 12/17/81, 12/24/82, Surveillance Test 12/31/81 ST 5016.02 Fire Protection System 11/29/81, 12/06/81, Electric Pump Weekly 12/13/81, 12/19/81, Surveillance Test 12/27/81
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Number Title Dates
ST 5016.04 Accessible Detector 04/20/81, 10/19/81 Channel Functional and Supervisory Circuit Checks ST 5016.07 Fire Protection System 01/16/81, 04/07/81, Automatic Sprinkler System 07/16/81 Test ST 5016.08 Electric Fire Pump 10/09/80, 11/04/81 Annual Flow Test ST 5016.09 Fire Hose, Fire Hose 08/21/81, 09/29/81, Station and Fire 10/21/81, 11/27/81, System Valve Testing 12/23/81
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ST 5016.12 Diesel Fire Pump Annual 10/09/80, 31/03/81 Flows Test ST 5016.15 Diesel Generator and 11/25/81 Water Curtain Deluge Annual Surveillance Test
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Fire Door Surveillance 10/81, 11/81 Inspection (2) Plant Tours The inspectors examined fire protection and emergency systems and equipment during tours of the turbine and auxiliary buildings on January 13,14 and 15,1982.
b.
Findings Noncompliance (50-346/82-03-01): Technical Specification Limiting Conditions for Operation 3.7.10 requires that all penetration fire barriers protecting safety-related areas be functional at all times.
If a penetration fire barrier is not functional, a continuous fire watch must be established within one hour on at least one side of the affected barrier.
Contrary to the above, on January 14 and 15, 1982, the inspectors observed three non-functional fire doors which protect areas that contain cabling and/or equipment necessary for safe shutdown of the plant:
Door No. 312 which protects Fire Zone U-2 (Spent Fuel Pool
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Pump Room 312) on Elevation 585' was obstructed from
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closing by cabling run through the doorway.
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Door No. 319A which protects Fire Zone L-1 (Diesel Generator
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Day Tank Room 320A) on Elevation 595' was obstructed from closing by temporary ventilation " elephant" trunk run through the doorway.
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Door No. 400 which protects Fire Zones V-8 (Passage 400)
and V-9 (Corridor 404) on Elevation 603' was found standing open on two occasions due to a non-functional closure
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mechanism. The closure device was not strong enough to counteract the ventilation system leakage when the door was opened. This prevented the door from closing.
A continuous fire watch had not been posted on either side of these non-functional penetration fire barriers.
Noncompliance (50-346/82-03-02):
10 CFR 50.48 states in part,
"Each operating nuclear power plant shall have a fire protection plan that satisfies Criterion 3 of Appendix A to this part...
Appendix R to this part established tire protection features required to satisfy Criterion 3 of Appendix A to this part..."
In areas of the plant where the protection of systems whose function is required for hot shutdown does not satisfy the requirements of Paragraph G.2 of Section III of Appendix R to 10 CFR 50, Paragraph G.3 requires that alternative shutdown capability be provided independent of the area and that fire detection and fixed fire suppression systems be installed in the area.
Contrary to the above, the licensee did not provide a fixed fire suppression system in the control room which is an area that does not satisfy the hot shutdown protection requirements of 10 CFR 50, Appendix R, Section III.G.2, nor did the licensee submit a request for exemption from this requirement as permitted in 10 CFR 50.48(c)(6).
c.
Discussion Unresolved Item (50-346/82-03-03): On January 14 and 15, 1982, the inspector observed two doors into areas that contain cabling and/or equipment necessary for safe shutdown of the plant which did not have the required qualification rating label:
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Door No. 206 which protects Fire Zones G-11 (Passage 227)
and G-12 (Passage 241) on Elevation 565' is required in the Fire Hazards Analysis Report to possess an Underwriters Laboratory Class B level fire rating. Door No. 206 was not affixed with any label designating its fire rating.
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Door No. 311 which protects Fire Zone U-1 (Passage 310 and Hatch Area 313) on Elevation 585' is required in the Fire Hazards Analysis Report to possess an Underwriters Laboratory Class A level fire rating.
Door No. 311 was not affixed with any label designating its fire rating.
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This item remains unresolved pending licensee verification that these doors actually possess the necessary fire resistance cap-abilities to qualify for the appropriate Underwriters Laboratory'
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rating.
3.
Fire Protection and Prevention Administrative Controls The inspectors examined.the licensee's fire protection and prevention administrative controls including the control of combustible and flammable materials, the control of ignition sources, fire emergency response procedures and fire protection audits and inspections. The administrative controls were reviewed using the commitments and re-j quirements in Amendment No. 18 to License No. NPF-3 including the Fire Protection Safety Evaluation Report, issued July 26, 1979, and the fire protection Technical Specifications.
a.
Areas of Inspection
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l (1) Procedures
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Number Title AD 1810.00 Fire Protection Program AD 1810.01 Control of Combustibles AD 1844.00 Maintenance
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EP 1202.35 Fire Emergency Procedure FP 9319.00 Fire Preplan - Room 319 - Diesel Generator 1-2
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Room FP 9323.00 Fire Preplan - Room 323 - High Voltage Switchgear Room B FP 9321.00 Fire Preplan - Room 321A - Day Tank 1-1 Room FP 9115.00 Fire Preplan Room 115 - ECCA Pump Room No. 2 (East)
(2) Reports l
Title Dates l
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Fire Protection Quality June 19-26, 1979
Assurance Annual Audit No. 598
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j Fire Protection Quality April 21 - May 30, 1980 Assurance Annual Audit
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No. 666 i
Fire Protection Consultant August 20-22, 1980
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j Annual and Tri-Annual Audit
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No. 729 Fire Protection Quality March 23-25,1981 Assurance Annual Audit No. 744 l
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Title Dates Fire Protection July 20-22, 1981 Consultant Annual Audit No. 781 (3) _ Plant Tours The inspectors examined the implementation of the licensee's fire protection and prevention administrative controls during tours of the turbine and auxiliary buildings on January 13, 14, and 15, 1982.
Noncompliance (50-346/72-03-04(A)): Technical Specification 6.8.1.f requires that written procedures be established, implemented and maintained covering the fire protection program.
(1) Administrative Procedure AD 1810.01, Control of Combustibles, requires that storage of combustib'te gases, lubricants, solvents, fuels, and paints shall be prohibited in safety-related areas. Also, this procedure requires that all wood used in safety-related areas shall be treated with a flame retardant and that combustible waste, scrap, debris and oil resulting from a work activity shall be removed from the plant following the completion of the work activity or the end of the shift, whichever is sooner.
Contrary to the above, on January 13 and 14, 1982, between the hours of 1600 and 2000, the inspectors observed the following violations of these requirements:
(a) Accumulations of combustible materials including untreated wood, rags, trash, cardboard and paper in the following areas:
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2 Diesel Generator Room No. 1 Diesel Generator Room
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No. 2 Diesel Generator Day Tank Room
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Auxiliary Shutdown Panel Room
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"B" Low Voltage Switchgear Room
"B" Battery Room
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Diesel Generator Corridor
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Steam /Feedwater Rupture Control System dP Cell Area
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No. 3 Mechanical Penetration Room
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No. 4 Mechanical Penetration Room No. 1 Penetration Room
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Fuel Pool Area
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Component Cooling Water Pump and Heat Exchanger Room
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Diesel Fire Pump Room
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Elevation 623 Purge Room Cable Spreading Room Accass Area from RACA
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Control Room
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(b) Storage or accumulations of flammable liquids and/or gases in the following areas:
No. 1 Diesel Generator Room
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Diesel Generator Corridor
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Elevation 623 Purge Room Mechanical Penetration Room No. 4
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Fuel Pool Area
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(2) Administrative Procedure AD 1844.00, Maintenance, requires that a fire watch continuously monitor an area for a minimum of thirty minutes following open flame, cutting, grinding or velding work.
Contrary to the above, on January 15, 1982, during the lunch br.3ak, the inspectors observed that no fire watch was posted is the No. 2 Diesel Generator Day Tank Room where welding opa rations had been taking place prior to the lunch break.
Noncompliance (50-346/82-03-05(A)): Amendment No. 18 to License No. NPF-3 issued July 26, 1979, requires that the fire protection administrative controls be upgraded to bring them into conformance with the NRC guidance document, " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance." The implementation date for this modification was prior to startup after the 1980 refueling outage (approximately November 1, 1980).
i Contrary to the above, at the startup from the 1980 refueling outage, the licensee had not fully upgraded administrative
controls to bring them into in conformance with the NRC guidance document, " Nuclear Plant Fire Protection Functional Responsibili-ties, Administrative Controls and Quality Assurance," in the following areas:
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(1) The upper icvel offsite management position which has management responsibility for the assessment of the effectiveness of the fire protection program was not designated as required in Paragraph 1.a. of Attachment No. 1 to the guidance document.
(2) The offsite management position which has direct respon-sibility for formulating, implementing, and assessing the effectiveness of the fire protection program was not designated as required in Paragraph 1.b.(1) of Attachment No. I to the guidance document.
(3) The onsite position responsible for implementing a program to indoctrinate contractor personnel in fire protection program administrative cpntrols and emergency procedures was not designated as required in Paragraph 1.d.(5) of Attachment No. 1 to the guidance document. The General
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Orientation Training program does not provide training in the fire prevention administrative controls over the use of combustible materials and ignition sources.
(4) Administrative controls over the use of combustible materials did'not include a requirement for the removal of all combustible materials at the completion of the work activity or the end of each work shift, whichever is sooner, as required in Paragraph'C of Attachment No. 3 to the guidance document.
(5) Administrative controls over ignition sources did not include the restriction that oxyacetylene equipment be checked for leaks prior to moving it into safety-related areas as required in Paragraphs 2.b(4) of Attachment No. 4 to the guidance document.
(6) Administrative controls over ignition sources did not include a requirement that the fire watch remain at the
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worksite for thirty minutes following the completion of work to check for smoldering fires as required in Para-graph 2.b.(3) of Attachment No. 4 to the guidance document.
(7) Administrative controls over ignition sources did not include fire watch qualifications as required in Para-
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graph 2.b(3) of Attachment No. 4 to the guidance document.
(8) Administrative controls over ignition sources did not include the stipulation that the responsible foreman or supervisor physically survey the area to assure that all precuations have been taken as required in Paragraph 2.b.
of Attachment No. 4 to the guidance document.
In addition, at the time of this inspection, Items 1, 2, 3, 5,
7 and 8, as listed above, had not been corrected in the current revisions to the appropriate procedures.
Noncompliance (50-346/82-03-06):
10 CFR 50, Appendix B, Criterion XVIII, requires that a comprehensive system of planned and periodic audits be carried out to verify compliance with all aspects of the quality assurance program.
Toledo Edison Company Nuclear Quality Assurance Procedure (QAP)
2180, " Audits," states in part, "A comprehensive system of planned periodic audits to verify compliance with QA program requirements and to determine QA program effectiveness shall be l
conducted...
The goals of the audit system are...to provide an objective assessment of compliance with established requirements."
Toledo Edison Company Nuclear Quality Assurance Manual, Volune I, Section 1.2.8, defines Audit Activity as, " Documented QA/QC j
activities to determine, through investigation, the adequacy of, l
and adherence to... licensing requirements."
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Contrary to the above, the quality assurance audits of the fire protection program performed in June 19-26, 1979 (Audit No. 598),
April 21 - May 30,1980 (Audit No. 666) and March 25, 1981 (Audit No. 744), only reviewed the adequacy of implementation of the existing plant procedures. Assessments were not made concerning the adequacy of these procedures as inspection guidance utilizing the fire protection licensing requirements. This narrow scope for the quality assurance audit permitted deficiencies in fire protection program administrative procedures to go undetected.
4.
Fire Protection and Prevention Training The inspectors examined the licensee's fire protection and provention training programs for contractors, general employees and fire brigade personnel. These training programs were reviewed using the commitments and requirements in Amendment No. 18 to License No. NPF-3 including the Fire Protection Safety Evaluation Report, issued July 26, 1979, the Fire Hazards Analysis Report (Revision 6), issued May 16, 1980, and the plant Technical Specification.
a.
Areas of Inspection (1) Procedures and Records Number Title Dates AD 1828.20 Fire Brigade Training
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Fire Brigade Training 1981 and Drill Record Forms (2) Observations The inspectors observed and participated in the General Orientation Training on January 11, 1982, and the Radiation Control Training on January 12, 1982.
b.
Findings Noncompliance (50-346/82-03-04(B)): Technical Specification 6.8.1.f requires that written procedures be established, implemented and maintained covering the fire protection program. Administrative Procedure AD 1828.20, Fire Brigade Training, requires that each fire brigade team participate in at least one fire drill each calendar quarter.
Contrary to the above, fire brigade drills were not conducted in the first and third quarters of 1981 for any of the fire j
brigades.
Noncompliance (50-346/82-03-05(B)): Amendment No. 18 to License No. NPF-3 issued July 26, 1979, requires that the fire protection administrative controls be upgraded to bring them into conformance with the NRC guidance document, " Nuclear Plant Fire Protection l
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Functional Responsibilities, Administrative Controls and Quality Assurance." The implementation date for this modification was prior to startup after the 1980 refueling outage (approximately November 1, 1980).
Contrary to the above, at the startup following the 1980 refueling outage, the licensee had not fully upgraded administrative controls to bring them into conformance with the NRC guidance document,
" Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance," in the following areas:
(1) Fire Brigade practice sessions did not include practice in the proper method of fighting fires of similar magnitude, complexity and difficulty as those that could occur in the plant as required in Paragraph 2.0 of Attachment No. 2 to the guidance document.
(2) Fire Brigade practice sessions did not include practice in the use of emergency breathing apparatus under strenuous fire fighting conditions as required in Paragraph 2.0 of Attachment No. 2 to the guidance document.
(3) Documentation of fire brigade drill critiques was not maintained as required in Paragraph 4.0 of Attachment No. 2 to the guidance document.
Noncompliance (50-346/82-03-07):
10 CFR 50, Appendix B, Criterion XVI, requires that conditions adverse to quality be promptly corrected.
Contrary to the above, the fire fighting practice training for the fire brigade was documented as being deficient in Toledo Edison Audit No. 729, dated August 20-22, 1980, and in Toledo Edison Audit No. 781, dated July 20-22, 1981, but the necessary corrective action had not been taken at the time of this inspection to upgrade the fire fighting practice training program to satisfy the requirements in Paragraph 2.0 of Attachment No. 2 to " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance."
Toledo Edison Annual and 36 Month Fire Protection Audit No. 729, Section 4.4.7, states in part, "A fireground training facility should be provided to allow realistic " hands-on" training in other than the open pit fire situations. The training facility should provide enclosed areas with heat and smoke and should be able to simulate oil spill fires indoors."
The response to this audit finding states in part, "A fireground training facility is provided at Davissesse for fire brigade training on open pit fire situations. The Fire Protection Coordinator is developing the criteria for a fire / smoke building for fire brigade training on indoor fire situations.
In this
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regard, the usefulness and availability of the old Sewage Treatment Plant building for fire brigade training is being evaluated by the Fire Protection Coordinator."
This response was issued by the Station Superintendent in Memorandum M80-2299 dated December 11, 1980.
Toledo Edison Annual Fire Protection Audit No. 781, Section 4.4.5, states in part, "A fire ground training facility should be provided to allow for more realistic " hands-on" training. The training facility should provide enclosed areas with heat and smoke to simulate fires indoors."
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Section 4.4.3 states in part, " Fire Brigade practice sessions should include the uso of self-contained breathing apparatus under strenuous firefighting conditions."
The response to these audit findings states in part, "The Station fireground training facility does provide for " hands-on" training on pit fires. The Fire Protection Coordinator, with the coopera-tion of the Maintenance Engineer, will solve this problem of providing an area for fighting fires in an enclosed area with heat and smoke and use of SCBA under strenuous firefighting conditions in the near future."
This response was issued by the Station Superintendent in Memorandum M81-1442 dated August 18, 1981.
At the time of this inspection, no facility existed onsite which was designated for use to accomplish this type of fire fighting training and the training was not being provided to the fire brigade members as required through Amendment No. 18 to License No. NPF-3 issued July 26, 1979.
5.
Unresolved Items Unresolved Items are matters about which more information is required in order to ascertain whether they are acceptable or Items of Noncom-pliance. An Unresolved Item identified during this inspection is discussed in Paragraph 2.
6.
Exit Interview The inspectors met with the licensee representatives denoted in Paragraph 1 at the conclusion of the inspection on January 15, 1982.
The inspectors summarized the purpose and scope of the inspection and discussed the findings.
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