IR 05000382/1999018

Insp Rept 50-382/99-18 on 990830-0902.Violations Noted.Major Areas Inspected:Implementation of NRC-approved Fire Protection Program

ML20212J705
Person / Time
Site:	Waterford
Issue date:	09/29/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20212J695	List: IR 05000382/1999018 ML20212J692
References
50-382-99-18, NUDOCS 9910050264
Download: ML20212J705 (9)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-382 License No.: NPF 38 Report No.: 50-382/99 18 Licensee: Entergy Operations, In Facility: Waterford Steam Electric Station, Unit 3 Location: Hwy.18 Killona, Louisiana Dates: August 30 through September 2,1999 Inspectors: Rebecca L. Nease, Senior Reactor inspector Engineering and Maintenance' Branch Accompanying Javier Rodriguez, Project Engineer Personnel: Projects Branch C Approved By: Dr. Dale A. Powers, Chief Engineering and Maintenance Branch i Division of Reactor Safety I

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ATTACHMENT: SupplementalInformation

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9910050264 990929 I PDR ADOCK 05000382 8 PDR

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-2-EXECUTIVE SUMMARY Waterford Steam Electric Station, Unit 3 NRC Inspection Report No. 50-382/99-18 in this announced, routine inspection, two NRC inspectors reviewed the licensee's implementation of the NRC-approved fire protection progra Plant Support

• Inspectors identified, on August 31,1999, that neither the shift superintendent nor the control room supervisor followed the requirements in Procedure UNT-005-013. " Fire Protection Program." Specifically, they failed to ensure that fire brigade members on their shift were qualified. This was a violation of Section 2.C.9 of the Waterford Steam Electric Station, Unit 3, Facility Operating License, which states that Entergy Operations, Inc., shall implement and maintain in effect all provisions of the approved fire protection program. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as Condition Report CR WF3-1999-0907. The inspectors verified that the fire brigade members on shift August 31,1999, were actually qualified, therefore, this violation did not affect the fire brigade's ability to respond to a fire (Section FS).

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Fire response equipment was well maintained, plant housekeeping for control of transient combustibles was good, and procedures were adequate for implementing the fire protection program. Fire brigade personnel were qualified and performed adequately during the observed fire drill. The inspectors concluded that, with the exception of the noncited violation discussed above, for the aspects of the fire protection program reviewed, the licensee's fire protection program was properly controlled, implemented, and maintained in accordance with the approved fire protection program (Sections F1, F2, F3, F4, and FS).

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3-Report Details Summary of Plant Status The plan operated at full power during the inspectio LV. Plant Suncort F1 Control of Fire Protection Activities (64704)

The inspectors reviewed the licensee's fire protection program to verify that the licensee had properly implemented and maintained the fire protection program as required by the op3 rating license. The inspectors reviewed fire protection procedures, administrative controls, fire reports, fire brigade qualifications, and fire brigade staffing to determine if they were in accordance with approved fire protection program. The inspectors also

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conducted tours of the facility and observed a fire drill to verify licensee implementation of the fire protection progra The inspectors concluded that, for the aspects of the fire protection program reviewed, the licensee's fire protection program was properly controlled, implemented, and maintained in accordance with the approved fire protection progra F2 Status of Fire Protection Facilities and Equipment (64704) l l Insoection Scoce The inspectors performed a walkdown inspection of the accessible areas of the facility containing safe shutdown equipment and fire protection equipment, including fire suppression and detection equipment, fire-rated assemblies, emergency lighting, and fire brigade and operator emergency response equipment. In addition, the inspectors reviewed maintenance and surveillanco procedures and records of selected fire protection equipment to verify that the' equipment was maintained in an operable  !

conditio Observations and Findinas The inspectors observed that fire protection equipment was maintained in good condition. Hose reels were maintained with weather covering in place and hoses properly installed. Fire brigade equipment cabinets were well stocked and accessible with breakaway locks or plastic security devices that could be readily broken for immediate access. Motor-driven and diesel-driven fire pumps appeared to be in good working order, Emergency lighting was standard throughout the areas of the plant, and appeared to be properly positioned. Laydown areas for equipment staging and storage were marked, and inventory was kept current to ensure transient fire loading did not exceed that assumed in the fire hazards analysis. The inspectors observed good housekeeping and material condition in areas toured. Fire brigade response equipment L

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was well maintained and ready for use. The fire protection staff conducting the tour were able to appropriately address specific questions posed by the inspectors regarding fire protection equipmen Conclusions Fire protection equipment required for program implementation was well maintained and available for use. Plant housekeeping for control of transient combustibles was satisfactor F3 Fire Protection Procedures and Documentation (64704)

The inspectors reviewed portions of the licensee's approved fire protection program, as documented in the Updated Final Safety Analysis Report (FSAR) for the facility, tc verify that the procedures adequately implemented the licensee's approved program. The ,

inspectors found that the procedures reviewed adequately implemented the approved fire protection progra F4 Fire Protection Staff Knowledge and Performance (64704)

The inspectors evaluated fire protection staff knowledge by conducting interviews and plant.walkdowns with staff members. Discussions with the fire protection design engineer, fire protection system engineer, fire brigade training instructor, and quality assurance fire protection auditor indicated that they had a good understanding of NRC requirements for the fire protection program. The fire protection staff also demonstrated j an extensive knowledge of the National Fire Protection Association Codes; a detailed j understanding of fire hazards associated with the facility; and familiarity with the facility's i fire protection systems, testing, and analyses. In addition, inspectors determined that the licensee's fire protection staff demonstrated a good sense of ownership of their assigned responsibilitie F5 Fire Protection Staff Training and Qualification (64704) Insoection Scope The inspectors reviewed the readiness of the onsite fire brigade personnel to fight fires, including fire brigade composition, qualifications, and training records. The inspectors ,

also interviewed licensee staff responsible for fire protection training, reviewed a fire drill lesson plan, observed the performance of the fire brigade during a fire drill, and attended the fire drill critique.

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. Observations and Findinas Fire brigade training requirements were implemented by Procedure NTP-202, * Fire Protection Training," Revision 7. The inspectors did not find any discrepancies with the I

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. training and qualification requirements for fire brigade members or their physical examination requirement Failure to Verifv Fire Briaade Members were Qualified The inspectors reviewed the licensee's process for selecting fire brigade members for

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each shift as described in Procedure UNT-005-013 " Fire Protection Program," l Revision On August 31,1999, the inspectors questioned the shift superintendent concerning how he ensured that the fire brigade members on his shift were qualified. The shift superintendent stated that he delegated this responsibility to the control room supervisor. The control roorn supervisor stated that the fire brigade leader ensured that fire brigade members were qualified. The inspectors then asked the fire brigade leader who stated that each fire brigade member was responsible for maintaining fire brigade qualification l Section 2.C.9 of the Waterford Steam Electric Station, Unit 3, Facility Operating j License, NPF-38, states that Entergy Operations, Inc., shall implement and maintam I in effect all provisions of the approved fire protection program as described in the FSAR for the facility through Amendment 36, and as approved in the safety evaluation report through Supplement 9. Section 9.5.1.3.1.B.1," Administrative Procedures, Controls, and Fire Brigsde," of the FSAR states,"[t]he Fire Protection Program )

(UNT 005-013) discusses the organization and methodology developed for maintaining the Performance of fire protection systems and fire response personnel at the station."

Procedure UNT-005-013, states that the shift superintendent or control room supervisor is responsible to ensure that five qualified fire brigade members are on duty at all time Based on the above, the inspectors determined that neither the shift superintendent nor the control room supervisor followed the requirements of Procedure UNT-005-013 to ensure that onshift fire brigade members were qualified. This is a violation of Section 2.C.9 of the Waterford Steam Electric Station, Unit 3, Facility Operating License NPF-38 (50-382/9918-01). This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as Condition Report CR-WF3-1999-0907. The inspectors verified that the five fire brigade members on shift l August 31,1999, were qualified, therefore, this violation did not affect the fire brigade's I ability to respond to a fir The inspectors noted that a computer-based listing of qualified fire brigade personnel was available, which provided a training status of each fire brigade member. This program was recently implemented to address condition report and quality assurance j audit findings that identified severalinstances in the past where the qualifications of fire brigade members on shift had expired. As part of the immediate corrective actions proposed in Condition Report CR-WF3-1999-0907, all shif t superintendents received {

instructions on how to access this electronic list of fire brigade members and the status l of their training.

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-6-Fire Drill Observations The inspectors observed a fire drill conducted September 1,1999. Inspectors noted that control room announcements of the fire drill were accomplished as required. The fire brigade reported to the site of the fire within an acceptable time period, with fire fighting equipment suitable for the type of simulated fire. The fire brigade leader and fire brigade members consulted the fire strategy procedures, which were available in the fire brigade locker. Inspecars observed that fire brigade members checked each other to ensure that their fire protection clothing and equipment were properly donned. The number of personnel responding to the drill was more than that required to fight the fire, and it included a member of the security force for crowd control. The additional fire brigade personnel assisted in laying out and connecting fire hoses. Fire protection staff told the inspectors that the additional turnout was standard practic The inspectors were informed that to test the competence of the fire brigades without additional assistance, at least one fire drill per year was conducted on the backshift, when additional assistance was not available. Sommunications between the fire brigade leader and fire brigade members and between the fire brigade leader and the control room were accomplished through the use of radio lapel microphones. All fire brigade responders and security were equipped with radio equipment. A detailed methodical approach was utilized to fight the simulated fire. The inspectors found that the fire brigade responded in a timely and appropriate manner to the fire, were properly dressed-out, consulted fire strategy procedures, and took necessary precaution The fire brigade training was described in Procedure NTP-202, " Fire Protection Training," Revision 7. Procedure NTP-202 provided a drill planning checklist, as well as, a critique sheet. The fire drill scenario observed by the inspectors was formally documented in Lesson Plan W-3-LP-FPFB-DRL10, " Fire Drill - RCP "1B" Breaker," i Revision 1. This lesson plan included acceptable performance criteria for all participants j including the control room staff and security. The inspectors found that the fire drill and i the performance of the fire brigade were well documented, and the fire scenario was ,

sufficiently complex to demonstrate the required skills of the fire brigad l The critique of the exercise was conducted immediately following the drill. All fire brigade members contributed to the critique, as well as, the fire protection engineer and the fire protection training instructor. Inspectors observed that discussion was constructiv Conclusions The training and qualification of fire brigade members and the licensee's performance of fire drills met the requirements of the fire protection program. However, inspectors identified one noncited violation of the License Condition 2.C.9 for failure to follow procedure to ensure that a shift's fire brigade members were qualified.

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The fire drill scenario was formally documented and was sufficiently complex to demonstrate the required skills of the fire brigade. The response of the fire brigade to the fire drill was timely, and techniques used were appropriate to the fire drill scenari The fire drill critique discussion was constructiv F7 Quality Assurance in Fire Protection Activities (64704)

The inspectors reviewed the 1997,1998, and 1999 fire protection related audit reports, and discussed the results with a quality assurance auditor. The inspectors found that the licensee's annual, biannual, and triennial inspections and audits were properly staffed with knowledgeable personnel, and were conducted in accordance with the requirements of the fire protection program. Audit findings were clearly documented in the reports, and condition reports were generated to resolve the identified problem Condition reports initiated as a result of previous quality assurance audits were tracked and their resolutions reviewed for effectiveness in subsequent audit The inspectors concluded that the licensee's fire protection quality assurance program activities met the requirements of the NRC approved fire protection progra V. Manaaement Meetinos X1 Exit Meeting Summary i

The lead inspector presented the inspection results to members of licensee I management at the conclusion of the inspection on September 2,1999. Licensee l representatives acknowledged the findings presente The lead inspector asked the representatives of the licensee's management whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee M. Brandon, Acting Licensing Manager B. Collyer, Fire Protection Engineer, Design Engineering C. DeDeaux, Licensing Supervisor

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C. Dimarco, Quality Assurance Specialist R. Fill, Quality Assurance Manager R. Glaze, Senior Operations instructor P. Gropp, Design Engineering Manager -

J. Hoffpauir, Operations Manager

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A. Holder, Lead Senior Engineer, Fire Protection, Engineering Programs T. Leonard, General Manager Plant Operations S. Matharu, Electrical Engineering Supervisor, Design Engineering E. Perkins, Acting Director, Nuclear Safety and Regulatory Affairs )

O. Pipkins, Licensing Engineer '

A. Wrape, Director, Engineering NRC T. Farnholtz, Senior Resident inspector

'J. Keeton, Resident inspector D. Powers, Branch Chief. Engineering and Maintenance Branch IllSPECTION PROCEDURES USED 64704 Fire Protection Program ITEMS OPENED AND CLOSED Opened 50-382/9918-01 NCV Failure to follow procedure to ensure fire brigade members -

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l Closed 50-382/9918-01 NCV Failure to follow procedure to ensure fire brigade members were qualified (Section FS).

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2-LIST OF LICENSEE DOCUMENTS REVIEWED PROCEDURES REVIEWED Numbgr Title Revision FP-001-020 Fire Emergency / Fire Report 11 FP-001-017 Transient Combustibles 14 NTP 202 Fire Protection Training 7 OP-009-004 Fire Protection 11 l OP 903-057 Fire Protection System Flow Test 9 l

UNT-005-013 Fire Protection Program 7 MISCELLANEOUS LICENSEE DOCUMENTS REVIEWED Number Title /Descriotion Elevision or Date CR WF3-1999-0907 Condition report documenting the failure to September 9,1999 verify on-shift fire brigade members were '

qualifiec W-3-LP FPFB-DRL10 Fire Drill- RCP "1B" Breaker Lesson Plan 1 N/A Section 2.C.9 of the Waterford Steam Amendment 134 Electric Station, Unit 3 Facility Operating License NPF-38 l

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