IR 05000346/1989012

Ack Receipt of Informing NRC of Steps Taken to Correct Violation Noted in Insp Rept 50-346/89-12 Re Failure to Assemble Fire Brigade Immediately Upon Receipt of Any Unplanned Fire Alarm

ML20247D687
Person / Time
Site:	Davis Besse
Issue date:	07/18/1989
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Shelton D TOLEDO EDISON CO.
References
NUDOCS 8907250278
Download: ML20247D687 (2)

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' JUL 'l 81989 Docket Ho. 50-346 Toledo Edison Company ATTN: 'Mr. Donald Shelton-Vice President-Nuclear Edison Plaza 300 Madison Avenue Toledo, 0H 43652

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Gentlemen:

l Thank you for your letter dated June 5, 1989, regarding your response to l violation number 346/89012-02 which we brought to_your attention-in our letter

. dated May 5,.1989. This violation regarded the failure to' assemble the fire brigade immediately upon receipt of any unplanned fire' alar The gcVerning fire protection criteria relating to fire procedures for'-

Davis-Besse are contained in the document' entitled " Nuclear Plant Fire Protection

. Functional Responsibilities, Administrative. Controls, and Quality Assurance",

I dated June 20, 1977. This document, which you are committed to in your license, is based on the philosophy that delays in fire brigade response'could result in

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potentially more severe fire conditions, with'resulting adverse consequences for achieving safe shutdown-following a fire.. Based on our review of yo'ur

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license condition as well as the points you'make in-your response, we conclude l that'this violation is vali i Your response indicated that by September 30, 1989, you will submit a deviation-l request to NRR fe m your. license commitment. Based on existing fire protection features, including the special compensatory actions which have been put in place at Davis-Besse as well as your continuation of the practice of

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l dispatching an operator upon receipt of an alarm to determine the need for 1 brigade assistance, we believe that no further actions are necessary at this i time pending NRC review of your September 30,.1989 deviation reques "

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As you point out in your letter response, the greater area'of concern is the i spurious fire alarm problem that exists at Davis-Besse. This issue was first j raised by the NRC in 1987 during a fire protection inspection (Inspection 1 Report No. 50-346/87027). We understand that you are now giving increased '

management attention to promptly resolve this issue. However, recent " Dail Status Reports" show an unacceptably high number of spurious fire alarms. We i believe the frequency of these spurious fire alarms brings into question the- 1 operability and reliability of the' fire detection' system. Until you-resolve !

this problem, we expect that you will take the action required by your Technical l Specifications when operability of the fire detection system is suspect based j on excessive, frequent spurious fire alarms. This may include institutin i special roving fire watche !

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Toledo Edison Company 2 JUL 181989 Furthermore, we expect'that your planned July 31, 1989 submittal of an evaluhtion of nuisance fire alarms will include an explanation of the root cause of the spurious alarm problem and an expeditious schedule for implementing appropriate corrective action. We will continue to closely monitor your efforts to correct this proble With regard to your response to violation number 346/89012-06 regarding fire watch deficiencies, we are continuing to monitor your oversight of the fire watch progra Should you have any further questions regarding this ma ter, we will be glad to discuss them with yo

Sincerely,

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OmGlHAL SIGHED BY HM l'

Hubert J. Miller, Director

. Division of Reactor Safety .

cc: L. Storz, Plant Manager cc w/ltr dtd 06/05/89:

DCD/DCB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII James W. Harris, State of Ohio Roger Suppes, Ohio Department of Health A. Grandjean, State of Ohio, Public Utilities Commission il RI R IIg RIII RIII, RIII RIIjI RIII M

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TOLEDO-Docket Number 50-346 her EDISDN

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License Number NPF-3 .

Serial Number 1-881 DONALD C. SHELTON Vee Prescent-%cea-(419} &G23C l June 5, 1989-l

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United States Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555

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I Subject: Fire Protection -' Reply to Notice of Violation transmitted'in-Inspection Report 50-346/89-012-

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Gentlemen:

Toledo Edison- has received the subject Notice of Violation transmitted by Nuclear Regulatory Commission (NRC) letter dated May 5,.1989 (Loc Number 1-2091) Attachment 1 contains the Company's response to the alleged violatic Violation 89012-02 involves failure to assemble the Fire Brigade'immediately upon receipt of any' fire alarm received in the Control Room. For'the reasons identified in Attachment 1, Toledo Edison' does not believe this' activit constitutes a violation and does not believe immediate assembly of the fire bricade for all alarms to be in the best interest of plant safety. Eovever, at discussed with NRC Region III staff, Toledo Edison vill not contest the i

ric,lation at this time.

l l Based on discussion with the inspector during and after his inspection and subsequent review by the Company, of greater cor.cern than the specific violation is the excessive number of nuisance' alarms received in the Control Room. Toledo Edison agrees that the number of nuisance alarms is excessive and is committed to determine the underlying cause and to reduce the number of

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these nuisance alarm :

If you have any questions concerning this matter, please contact i

Mr. R. V. Schrauder, Nuclear Licensing Manager, at (419) 249-236 s I q Very truly yours, j l

AL/d m b( 'I Attachment i cc: . M. Byron, DB-1 NRC Senior Resident Inspector' )

A. B. Davis, Regional Administrator, NRC Region III j

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D. J. Kubicki, NRC/NRR Staff Reviewer J. M. Ulie, NRC/ Region Inspector T. V. Vambach, DB-1 NRC Senior' Project Manager ,

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THE TOLEDO ED SON COMPANY EDISON PLAZA 300 MADSON AVENUE TOLEDO. DHIO 43652 >'

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c Attachment 1 Response to Notice of Violation

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! ,,.. Dockat Numbar 50-346

.. Licznse Number NPF-3 Serial Number 1-881

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Attachment 1 Page 1 '$

I Violation 89012-02: Paragraph 2.C.(4) of Amendment Number 18 to Plant Operating l License Number NPF-3 requires the licensee to complete those

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modifications identified in Section 1 of the Safety Evaluation (SE) dated July 26, 1979, including those modifications specified in Table 1 of the SE.' Section B.14 of Table 1.of the SE requires that the fire protection' administrative controls be revised to follow the NRC document, " Nuclear Plant Fire' ,

Protection Functional Responsibilities, Administrative Controls' l and Quality Assurance." Paragraph 2.0 of Attachment Number 6. .o i this document states in part, " ... administrative controls ...- I that govern the fire protection program shall be prescribed by documented instructions (and) procedures." Further, Attachment J Number 5' states,.in part, that "the fire. fighting procedures .)

should identify ... the need for brigade assistance upon ... .

receipt of an alarm on the control room annunciator. panel ..."

Contrary to the above, Procedure Number AB 1203.37, " Fire :

Procedure," did not prescribe the need for fire brigade ,

assistance upon receipt of an alarm in the control room. This )

allowed an unacceptable time delay in fire brigade response to a ]

fire through the licensee's established practice of dispatching an individual to an alarmed area without assembling the fire {

brigade after the annunciation in the control roo Response: Admission or Denial of Alleged Violation

Toledo Edison acknowledges that the Davis-Besse procedures do I not require the immediate assembly of the Fire Brigade upon the receipt of a fire alarm in the Control' Room, but does not consider this to be a violation of its commitment to Attachment 5 of the cited 1977 regulatory document (NRC letter, Vassallo to Roe, dated August 29, 1977, Log Number 280, " Nuclear Plant Fire ]

Protection Functional Responsibilities, Administrative Controls j snd Quality Assurance"). Toledo Edison, however, recognizes ;

that NRC's Office of Nuclear Reactor Regulation has recently ]

reviewed a denial of this same violation by another licensee and I has upheld Region III's interpretation. Therefore, Toledo l Edison vill not contest the matter further at this time,

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j Pending submittal of a request for deviation from the NRC's i i

interpretation of tne cited 1977 regulatory document and the subsequent NRC's review and approval of the deviation, Toledo j Edison considers that its ability to achieve and maintain saf shutdown in the event of a fire is adequate. The basis for this position is contained in the-description of the current Davis-Besse Fire Brigade program and assessment of its adequacy,

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as discussed later herei Reason for the Alleged Violation i

The basis for Toledo Edison's position that this matter does not constitute a violation was discussed during a conference call on

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, . Docket Number 50-346 License Number NPF-3 Serial Number 1-881

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Attachment 1 Page 2 May 12, 1989 between NRC staff members, Messrs. J. A. Grobe, J. H. Ulie and P. H. Byron and Toledo Edison representatives, Hessrs. R. V. Schrauder, H. A. Lalor and K. A. Spencer. When the initial commitment was made to the cited 1977 regulatory document, Toledo Edison and many other licensees aid not interpret the applicable wording to require immediate assembly of the Fire Brigade upon receipt of an alarm in the Control Roo Rather the vords " identify ... the need for fire brigade assistance ..." was understood to mean determine the need for brigade assistance. This common understanding is evidenced by the fact that many licensees who committed to this document initially established their program such that upon receipt of an alarm an operator was dispatched to determine the need for brigade assistance. This understanding of the meaning of the words seemed to be confirmed when subsequent rulemaking (i.e.,

10CFR50, Appendix R. Section K) explicitly used the words

" determine the need." As identified in NRC internal memorandum dated July 20, 1988, (Holahan to Miller) the more careful vording of Appendix R was provided in recognition of the NRC

" staff's realization that under certain circumstances, such as false fire alarms, fire brigade response might be detrimental to plant safety." Toledo Edison wholeheartedly agrees with the staff's positio Toledo Edison, and other licensees, committed to the cited 1977 regulatory document as early as 1978. Since that time, the NRC has performed numerous fire protection program inspections including the Fire Brigade. No violations regarding the immediate assembly of the Fire Brigade had been issued in the 10 years since the cited 1977 regulatory document was issued. This indicates that the NRC had given at least tacit agreemen; to the licensees' interpretation of the commitmen Consequently, Toledo Edison does not believe this activity l constitutes a violation nor is it in the best interest of plant l safet However, as discussed with NRC Region III staff, Toledo l Edison vill not contest the violation at this time.

l l Based on discussion with the inspector during and after his inspection and subsequent review by the Company, of greater concern than the specific violation is the excessive number of nuisance alarms received in the Control Room. Toledo Edison agrees that the number of nuisance alarms is excessive and is committed to determine the underlying cause and to reduce the number of these nuisance alarm Issues to be assessed in an evaluation of the underlying cause include: multiple messages received in the Control Room for a single plant alarm, detector sensitivity settings, and detector reliabilit .

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. Docket Numb:r 50-346

. Lic:nst Number NPF-3 Strial Number 1-881

. At'tachment 1 Page 3 Description of Current Fire Brigade Program Currently, Abnormal Procedure DB-0P-02529 (AB 1203.37) describes the personnel actions to be taken upon receipt of a fire alarm in the Control Room. This procedure states:

"The fire detection and radiat on console located in the control room vill alert the operator which fire detection zone and/or fire sprinkler system has been activated. The operator then can investigate the area affected as described on the CRT console."

The operator sent to investigate the plant area affected by a fire alarm is one who is a qualified watchstander and trained to respond to fire alarms received in the Control Room. This operator is knowledgeable of the procedure to contact the Control Room in the event of a fire, the plant fire detection and suppression system, and the operation of the plant equipment in the affected are In most cases this individual is or has been a trained Fire Brigade member. If a fire is identified, the operator is to notify the Control Room immediately, regardless of the size of the fire. The operator could then attempt to extinguish or control the fire, pending the arrival of the Fire Brigad Upon notification of an observed fire, the Control Room personnel vould activate the fire alarm on the plant P.A. System and give the location, in;ensity and type of fir The Fire l Brigade vould then assemble and quickly proceed to the affected area under the direction of the Fire Brigade Captai As noted in Inspection Report 88-028, positive observations of a j fire drill conducted in September 1988 was that the number of i fire brigade members responding exceeded NRC minimum '

requirements, the members wore proper protective clothing, and !

the fire brigade response to the fire scene was timel l Additionally, the operations readiness area has been relocated )

closer to the Fire Brigade turnout area since the issuance of Inspection Report 88-028 in order to improve the timeliness of the Fire Brigade respons Assessment of Adequacy l The ability to achieve safe shutdown is not adversely impacted by Toledo Edison's practice of confirming that a . tire exists prior to assembling the Fire Brigade. The response of the Fire i Brigade is not the only means of fire protection for equipment necessary to achieve and maintain safe shutdow The fire protection program at Davis-Besse is based upon the defense-in-depth concept and is not dependent upon any one aspect of the fire protection program. The defense-in-depth program has the following objectives:

1) To prevent fires from starting;

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Docket Number 50-346

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License Number NPF-3 Serial Number 1-881

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Attachment 1 Page 4 2) To promptly' detect, control and extinguish these fires that do occur; and 3) To provide protection for structures, systems and components important to safety se that a fire that is not promptly extinguished by the fire suppression activities vill not prevent safe shutdown of the plan These objectives are identical to those specified in 10CFR50, Appendix To support the defense-in-depth objectives, Toledo Edison has installed significant fire protection systems to protect plant equipment in order to satisfy the requirements of Appendix A to BTP APCSB 9.5-1. Additionally, Toledo Edison is currently in the process of identifying and implementing various system modifications to satisfy the requirements of 10CFR50, Appendix R. Pending the completion of the Appendix R modifications, Toledo Edison has implemented certain compensatory measures including fire watches, that have been accepted by the NRC as adequate to assure safe operation as documented in letter dated September 23, 1983, (Log Number 1375).

The Nuclear Utility Fire Protection Group (NUFPG), of which Toledo Edison is a member, has developed the following criteria to be used in identifying those fire areas which should require the immediate assembly of the Fire Brigade upon receipt of a fire alarm that is transmitted to the Control Room:

1) Redundant trains of safe shutdown. equipment required to achieve and maintain safe shutdown in the event of a fire (SSDF equipment) are contained in the same area, and 2) The fire loading in the area is sufficient to

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threaten SSDF equipment, considering both quantity l and location of combustibles, and 3) The fire protection in the area does not meet the separation criteria of Appendix R,Section III.G.2, and 4) The exemption or deviation applicable to the area took credit for prompt response of the fire brigad Toledo Edison intends to follow these guidelines in determining which areas, if any, vould necessitate the need for immediately assembling the Fire Brigade upon receipt of an alarm. An initial evaluation using these criteria has been performed on Davis-Besse as it vill exist following the planned upgrade and additional fire protection features required to satisfy 10CFR50, Appendix R scheduled to be completed prior to restart from the

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.: -Docket Number 50-346 E

'. Licznse Numbar NPF-3  ;

Scrial Number 1-881 l

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Attachment 1 Fage 5 )

sixth refueling outage. This-initial review,.using the NUFPG criteria, indicates that' Davis-Besse would not have any fire

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area that requires the immediate assembly'of the Fire Brigade j upon the receipt of a fire alarm in the Control Room. Although

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Davis-Besse is currently implementing the requirements of .

10CFR50, Appendix R, those compensatory measures accepted by the 'I NRC in Log Number 1375 are in place. 'Therefore, the iritent of j t h'o NUFPG's criteria is currently satisfie ,

' Consequently, Toledo Edison considers that the existing' fire i protection features, supplemented by.the aforementioned compensatory measures, are adequate to protect structures, 1 systems and components important to safety and ensure safe shutdown of the plant pending the confirmation of a fire and the arrival-of the Fire Brigad Toledo Edison believes that the current practice of assembling the Fire Brigade only after confirmation of a fire is preferred i

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to assembling the Fire Brigade for every alarm. .By screening fire alarms for possible false or. nuisance alarms, the Fire Brigade would be summoned only with cause.and have an enhanced attitude and be better mentally prepared for their' duties when called upon in the event of a1 actual fire. Toledo Edison considers that assembling the Fire Brigade without cause could unintentionally Sad to diminished response on the part of some Fire Brigade memoers. Additionally, the current Davis-Besse Fire Brigade is limited to members of the Operations staf This membership provides a Fire Brigade which has an enhanced familiarity of the plant configuration and cognizance of plant equipment potentially affected by a postulated fir Such a Fire Brigade membership exceeds the minimum regulatory l requirements and is superior to a staffing of dedicated Fire Brigade members. However, assembling the Fire Brigade for every fire alarm would unnecessarily disrupt the regular duties of plant operators who'are on call as Fire .Brigp& member Toledo Edison also believes that a uniform response to the receipt of a fire alarm in the Control Room is preferred. . l Toledo Edison considers it impractical to require the Fire Brigade to be summoned for an alarm for certain fire areas and not to summon the Fire Brigade for fire alarms'in other area Such a requirement to selectively summon the Fire Brigade could lead to confusion and be an added burden for the Control Room operators. Additional administrative controls to ensure Control l

Room operators selectively summon the Fire Brigade would simply ' j condme more Control Room operator time and more likely lead to j administrative' errors in implementing procedures for'an issue that would not significantly improvr. plant' safety in the event of a fir I i

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Page 6 In summary, Toledo Edison believes that confirmation of'a fire prior to assembling the Fire Brigade is adequate to ensure.the-safe shutdown of the plant in the event of a fire and is .

preferred to assembling the Fire Brigade for every alar l Corrective Actions Toledo Edison has reviewed AB 1203.37 and vill improve the Control Room response to fire alarms by requiring the Fire ]

' Brigade to immediately assemble if multiple confirming and' 'd diverse indications of a'fi're are transmitted to the Control j Roo This procedure revision vill improve the response to fire alarms i since assambling the Fire' Brigade for multiple confirming and-diverse alarms vould be a consistent practice for the Control Room operators to follow and minimize the number of unnecessary Fire Brigade' assemblies and disrupt'ons.in plant operatio Date When Full Compliance Will Be Achieved

.The procedure revision _ stated above vill be completed by August 31, 1989. An evaluation of nuisance fire alarms Mill be ;j addressed in the review of NFFA Code'72D to be' submitted to NRR by July 31, 1989. By September 30, 1989,. Toledo Edison vill also submit to NRR,a request for a deviation from NRC's recent interpretation of the cited'1977 regulatory document. This request vill contain a comparison of Davis-Besse to the NUFFG criteria to determine when the Fire Brigade is to immedia'tel assemble due to the receipt of a fire alarm.in the Control Roo l i

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Docket Number 50-346 License Number NPF-3 Serial Number 1-881 )

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Attachment 1 Page 7 Violation 89012-06: Paragraph 2.C.(4) of Amendment Number 18'to Plant Operating j License Number NPF-3, requires the licensee to complete those j modifications identified in Section 1 of the SE dated July 26, j

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1979, including those modifications specified in Table 1 of the SE. 'Section B.14 of-Table 1 of the SE requires that the fire protection administrative controls be revised to follow the NRC-document, " Nuclear Plant Fire Protection Functional

' Responsibilities, Administrative Controls and Quality

/.ssurance." Paragraph 8.0 of Attachment iumber 6 to this

'l document requires, in part, that ' conditions adverse to qualit be promptly identified and corrnted, q l

Contrary to the above, Toledo Edison Company. failed to' assure

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l that corrective actions taken in response to a previously j identified Severity Level IV violation (failure to establish {

required fire watches) were adequate in that on November 17, -

1988, and January- 12, 1989, the licensee failed to establish continuous fire watches within one hour as required by Technical Specification 3.7.1 Acceptance or Denial of the Alleged Violation .

Toledo Edison accepts the alleged violatio Reason for the Violation The reason for the violation is attributed to personnel error in not correctly following the established administrative control .

Corrective Actions Taken and Results Achieved The instances cited by the subject violation vere self-identified by Toledo Edison and reported to the NRC in Licensee Event Reports (LER) 88-0N and 89-002. These were attributed to personnel error ir. not correctly following the i procadure. The instance described in LER 88-024 involved the i failure of the Shift Supervisor to use the fire protection procedure in order to determine the correct fire watch to establish. The instance described in LER 89-002 involved the use of the fire protection procedure but the Shift Supervisor ,

J did not identify the room number requiring the fire watc Toledo Edison has evaluated each of these instances.and determined that they are isolated instances without a common-root cause. Appropriate individuals involved were counsele Toledo Edison promptly identified the personnel errors in both-instances and took the appropriate corrective actions.

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Docket Nu:bar 50-346

, Licansa Numbar NPF-3'

Sarial Number 1-881

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Attachmen Page 8-l The previously identified Severity Level IV violation involving fire watches was issued in NRC letter dated October' 19, 1988,

_(Log Number 1-1943) transmitting Inspection Report 88-028. This l violation identified four-instances 'where cont.4nuous fire vatches had not been established within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> as required by the Davis-Besse Technical Specifications.- .These'four instances were also self-identified by Toledo Edison and reported to the-NRC.in'LERs88-005, 88-009,88-010 and 88-011.- Two of these previous instances were attributed to an inadequate fire, protection procedure while the other two instances were due to personnel error in not following the procedur Ths instance described in LER 88-005 involved the failure to establish a continuous fire watch in accordance with'the Davis-Besse Technical Specifications. The Shift Supervisor was not'avare that the fire detection on cach side of an-inoperable fire barrier was inoperabl The instance described in LER 88-10 involved the failure to establish a continuous fire watch in accordance'with the Davis-Besse. Technical' Specification Ine Shift Supervisor did not recognize that a fire alarm in a sprinkler system, the result of maintenance on the system, would prevent the transmission of alarms from certain fire detection systems and render'those systems inoperabl Both cases vere the result of inadequate procedures to provide the Shift Supervisor with the'necessary guidance in determining the appropriate fire _vatches required by Technical Specification The instance described in LER 88-009 involved the failure i June 1986 to establish a continuous i se watch as a result of a deficient fire door. The necessary etntinuous fire vatch was subsequently established, but was inappropriately ~ terminated by the Assistance Shift Supervisor, following maintenance. This decision was made based on a review of another outstanding Maintenance Work Order failed to' identify that ongoing repair j vork had rendered the fire door inoperable. The instance j, l described in LER 88-011 involved the inappropriate termination f of a continuous fire watch following maintenance. The Shift Supervisor' failed to recognize that the partial performance of i the Surveillance Test, performed as post-maintenance testing,

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L was not adequate to satisfy the Technical Specification surveillance requirements and did not consult'the Critical Surveillance Test' Report which identified this surveillance requirement'as past due. Both instances were theEresult of Control Room personnel inappropriately terminating continuous

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fire watches following maintenance contrary to existing procedures and practice The only commonality between these occurrences is the significant changes taking place in-the' Davis-Besse fire protection program. To10do Edison has been upgrading the existing fire protection program at Davis-Besse, which has k resulted in significant procedute revisions and substantial number of fire protection components being de~clared inoperable, l

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,; Docket Number 50-346

. License Number NPF-3 Serial Number J-881

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mainly fire barriers, pending completion of repairs and testing.

l The number of inoperable fire protection components combined

! with significant procedure revisions created an increased I

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opportunity for failure on the part of Control Room personnel and resulted in repeated failures to establish the continuous fire watches. However, Toledo Edison believes that as more fire l protection equipment is restored to an operable condition and Control Room personnel become more familiar with the revised procedures, the number of failures to establish the correct fire watch required by Technical Specifications will be minimize The reduction in fire watch violations is corrently eviden In 1988, Toledo Edison issued 8 LERs due to fire watch violation Up to May 31, 1989, there has been unly 1 LER for a fire watch violation, which is a substantial reduction. Toledo Edison believes that the corrective actions taken to date have led to this reduction in fire watch violations and that no additional corrective action is necessar Date When Full Compliance Vill Be Achieved The corrective actions taken to date, as discussed above and individually in the LERs, have been effective in reducing the number of fire watch violations. Toledo Edison considers that it is presently in full compliance.

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