IR 05000387/1989009
| ML17156B193 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/01/1989 |
| From: | Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17156B192 | List: |
| References | |
| 50-387-89-09, 50-387-89-9, 50-388-89-09, 50-388-89-9, NUDOCS 8906130255 | |
| Download: ML17156B193 (8) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-387/89-09 50-388/89-09 Docket Nos.
50-387 50-388 License Nos.
NPF-14 NPF-22 Licensee:
Penns lvania Power 8 Li ht Com an 2 North Ninth Street Allentown Penns 1 vania 18101 Facility Name:
Sus uehanna Units 1 and
Inspection At:
Berwick Penns ivan'ia Inspection Conducted:
il 3-7 1989 Inspector:
A.
rasop los, Reactor Engineer date Approved by:
C.
. Anderson, Chief, Plant Systems Section g slat date Ins ection Summar
Inspection on April 3-7, 1989 (Combined Report Nos.
50-387/89-09 and 50-388/89-09)
d.
i i
i i
i d
and implementation of the licensee's Fire Protection Program.
The inspection included a review of the following aspects of the fire protection program:
combustible material control, housekeeping conditions, surveillances and testing performed on fire suppression and detection equipment, and fire brigade training.
Also, a review and a walkdown of the fire suppression systems was performed.
Results:
The inspector identified a concern regarding the adequacy of the carbon dioxide systems.
The adequacy of these systems was questioned because it could not be demonstrated that adequate initial acceptance tests for these systems had been performed.
An additional'concern identified was the adequacy of the training provided to some members of the fire brigade.
Specifically, the security personnel that are members of the fire brigade do not participate in the same number of drills required for all other brigade member,1.0 Persons Contacted DETAILS Penns lvania Power and Li ht Com an
" R.
G.
Byram, Plant Superintendent
" D. Roth, Sr.
Compliance Engineer
" D. Klinger, Appendix R Manager
" R. Prego, gA Supervisor Operations
" S. Davis, Site Fire Protection Engineer
" J.
Liev, Nuclear General Training Supervisor
'. Markawski, Dayshift Supervisor
" G. Stanley, Assistant Superintendent Outages
- G. Kuczynski, Technical Supervisor United States Nuclear Re viator Commission NRC
- J. Stair, Resident Inspector
- Denotes those present at the exit meeting.
2.0 Follow-u of Previous Ins ection Findin s
U dated Violation 50-387/85-06-10 and 50-388/85-06-10 The licensee did not erform a functional test of the fire dam ers to assure closure.
The NRC determined that the licensee does not functionally test fire dampers to assure that the dampers will close when required.
A violation was issued against a license condition requiring the licensee's fire protection program to encompass the testing requirements specified in the National Fire Protection Association (NFPA) standards.
These standards specify that fire dampers be functionally tested every 12 months.
The licensee, in a letter sent to NRC on May 30, 1985, disagreed with the violation.
The licensee stated that the reference of the NFPA testing requirements in their procedures does not apply in this instance because it is in the appendix of the standard.
A specific note in the NFPA states that the appendix is not part of the standard.
The licensee stated that the testing specified in their procedures only applies to acceptance testing.
The inspector requested the results of the initial acceptance tests and test methodology.
The licensee was not able to provide this information during the inspection.
This issue remains open pending the licensee providing information to establish that the dampers will close under operating condition Closed Violation 50-387/85-06-11 De raded fire doors.
This violation involved inoperable fire doors on designated fire barriers.
Three fire doors were degraded.
These doors either had broken.latch mechanisms or the automatic closers would not work.
In addition, the NRC observed that doors to enclosed stair wells were held open with fusible links.
The inspector observed that the licensee took actions to repair the doors involved and did not observe any other fire doors that were degraded.
The inspector also observed that the stairwell doors were maintained closed.
The licensee plant staff stated that it is plant policy to keep all fire doors closed.
Based on the above, this violation is closed.
Closed Unresolved Item 50-387/87-14-01 and 50-388/87-14-01 Corrective
,actions to LER 85-15.
The NRC identified the concern that the licensee did not complete the work associated with the fire proofing of structural steel members.
The licensee stated that the reason for not'completing this work was that a
new engineering analysis was being developed defining the fire areas that need fire protection.
This new analysis was completed June 1988.
The work on the fire proofing was completed February 1989.
The licensee, while developing this analysis, had in place fire watches as required by the Technical Specifications.
Fire watches are still in place where work on the fire protection systems is incomplete.
This item is closed.
3.0 Controls of Combustibles and I nition Sources The licensee has procedures that control the use or introduction of combustibles and flammables in safety-related, areas.
The licensee also has procedures that control the use of ignition sources such as from welding, cutting or grinding operations.
The plant inspection by the inspector did not identify any deficiencies with these procedures.
4.0 Housekee in The inspector toured the plant to observe the housekeeping conditions and did not identify any unacceptable conditions.
The plant was clean of combustibles.
Trash is hauled away regularly.
5.0 E ui ment Maintenance Ins ection and Tests The inspector reviewed surveillance and testing procedures to determine whether the licensee has developed an adequate surveillance and mainte-nance program for the fire protection equipment.
The inspector also
reviewed test records to verify compliance with the applicable license and technical specification requirements.
This review identified the follow-ing concern:
The inspector reviewed the surveillance test procedures for the carbon dioxide (C02) system.
The licensee's Fire Protection Program for Susquehanna 1 and 2 identifies the areas to be protected by C02 and states that the C02 systems shall be designed in accordance with the National Fire Protection Association (NFPA) 12.
These areas, identified in the Units 1 and 2 Technical Specification Section 3.7.6.3 are listed below:
Control Room Under Floor, Unit
Control Room Under Floor, Unit 2 Lower Relay Room, Unit
Lower Relay Room, Unit 2, Upper Relay Room, Unit
Upper Relay Room, Unit 2 South Cable Chase Center Cable Chase North Cable Chase Room C-411 Soffit Control Room Soffit, Unit
Control Room Soffit, Unit 2 Room C-413 Soffit Room C-412 Soffit Room C-414 Soffit The design of the C02 systems for these areas is based on achieving a
50%
concentration for each area.
NFPA 12 1977 Section 1-7.3 specifies that C02 system installation be adequately tested to determine that the system has been properly installed and will function as intended for the approval of the installation.
The licensee in the Final Safety Analysis Report (FSAR) committed to perform tests of the C02 systems to demonstrate proper operation of the systems.
The acceptance criteria specified in the FSAR state that the systems would be accepted if the performance parameters of the systems are in accordance with the applicable codes and design documents.
During the inspection, the inspector observed that the licensee could not locate the C02 systems acceptance test records.
Licensee engineering.records, Bechtel Corporation Technical Specification 8856-M-344, specify that acceptance tests be performed.
A follow-up telephone call on April 18, 1989 between the inspector and the licensee determined that a full discharge initial acceptance test was performed in the North Cable Chase
~
Initial acceptance tests for the other areas were not performed.
The licensee, during the April 18, 1989
telephone call, indicated that the decision was made during the pre-opera-tional phase not to test the -other systems because of concerns that C02 cooling could adversely effect sensitive electrical equipment.
The licensee stated that since the North Cable Chase C02 system passed the acceptance test, additional testing of the other C02 systems
.was unneces-sary.
It was their view that the other systems will perform as well as the tested area.
The NRC, during a telephone call on May 10, 1989, again discussed this issue with the licensee.
The licensee stated that all of the C02 systems were designed with a 25% margin with regard to the design basis of achiev--
ing a
50% C02 concentration in each of the affected areas.
The licensee agreed to discuss this issue further with the NRC in a meeting currently scheduled for June 13, 1989.
Pending resolution of this issue, the licensee committed to establish and maintain one hour roving fire watches in the subject areas.
This is an unresolved item (50-387/89-09-01 and 50-388/89-09-01).
6.0 ualit Assurance A
Audit Review The inspector reviewed the gA department audits of the fire protection program.
No deficiencies were identified with these audits.
7.0 Fire Bri ade Trainin The inspector reviewed the fire brigade training program to verify that this program includes:
a.
Requirements for announced and unannounced drills; b.
Requirement for fire brigade training and retraining at prescribed frequencies; c.
Requirements for't least one drill per year to be performed on a
"back shift" for each brigade; d.
Requirements for maintenance of training records.
The inspector also reviewed the training records of fire brigade members for calendar years 1988 and 1989 to ascertain that they had attended the required quarterly training and participated in a quarterly drill, and received the annual hands-on fire extinguishment practice.
The inspector identified two potential deficiencies in the brigade training program.
One of these items concerns the licensee practice of not requiring all fire brigade members to participate in two drills per year.
In particular, the licensee requires that only members of the brigade from the operations department participate in the two drill The brigade is composed of five persons; three from the operations department and two from security.
According to the licensee's procedures, fire fighters from the security organization do not have to participate in the two drills by the licensee's Nuclear Training Procedure NTP-gA-53. 1.
This procedure states that "...Each individual from the operations section assigned to the fire brigade shall participate in at'east two drills per year.
~. Individuals from the security section assigned to the fire brigade duty at the time of the drill shall participate."
A records review performed by the licensee and requested by the inspector identified that 50% of the fire brigade members from the security section did not attend any drills, yet they are assigned fire brigade duty.
The NRC during the licensing process had reviewed the licensee's fire brigade training program and found it unacceptable.
At that time the NRC requested that the licensee provide a detailed description of the training program that meets several acceptance cri teria.
One of these acceptance criteria was the requirement that every brigade member participates in at least two drills per year.
The licensee's license condition for Unit 1, 2.C.(6), Fire Protection Program requires that the licensee "...shall maintain the fire protection program set forth in Appendix R to
CFR Part 50."
The licensee stated that with regard to the Appendix R license condition it is their understanding that they only need to satisfy Sections III. G and J of Appendix R.
This understanding is based on various correspondence between the licensee and NRC/NRR.
The licensee, during the inspection, could not locate this correspondence.
The licensee explained to the inspector that the reason the fire brigade training of the security personnel differs from the operations personnel is that security personnel are on a different shift schedule.
They could
.not readily provide the same training for every member because of schedular conflicts.
However, the licensee committed to review this concern and provide a prompt resolution of this issue.
This is an Unresolved Item (50-387,388/89-09-02).
Another concern regarding the brigade training identified by the inspector was the way certain. drills are conducted.
Specifically, the licensee performs only one drill where the brigade members respond in full gear.
The second drill is conducted with the brigade responding to the drill scene in street clothes and without the use of self contained breathing apparatus.
The licensee's FSAR indicates that drills would include the use of self contained breathing apparatus (SCBA).
However, the FSAR does not specify that all drills include SCBA.
The licensee agreed with the inspector that drills and drill scenarios would be more realistic with the use of the fire fighting gear.
They made the commitment that all future drills be conducted with the firefighters dressed in full fire fighting gear and wearing the SCBA.0 ~ill T
The inspector examined fire protection water systems, including fire water piping and distribution systems, post indicator valves, hydrants and contents of hose houses.
The inspector toured accessible vital and non-vital plant areas and examined fire detection and. alarm systems, automatic and manual fixed suppression systems, interior hose stations, fire barrier penetration seals, and fire doors.
The inspector observed general plant housekeeping conditions and randomly checked tags of portable extinguishers for evidence of periodic inspections.
No deterioration of equipment was noted.
The inspection tags attached to extinguishers indicated that monthly inspections were performed.
No deficiencies were identified.
9.0 Unresolved Items Unresolved items are matters for which more information is required in order to ascertain whether they are acceptable, violations, or deviations.
Unresolved items are discussed in Section 5.0 and 7.0.
10.0 Exit Interview The inspector met with licensee management representatives (see section 1.0 for attendees)
at the conclusion of the inspection on April 7, 1989.
The inspector summarized the scope and findings of the inspection at that time.
The inspector also confirmed with the licensee that the report will not contain any proprietary information.
The licensee agreed that the inspection report may be placed in the Public Document Room without prior licensee review for proprietary information ( 10 CFR 2.790).
At no time during this inspection, was written material provided to the licensee by the inspector.