IR 05000395/1982009
| ML20041C521 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 02/02/1982 |
| From: | Conlon T, Miller W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20041C518 | List: |
| References | |
| 50-395-82-09, 50-395-82-9, NUDOCS 8203020163 | |
| Download: ML20041C521 (10) | |
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'o UNITED STATES 8"
*t NUCLEAR REGULATORY COMMISSION
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REGION 11 o,
101 MARIETTA ST., N.W., SulTE 3100
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ATLANTA, GEORGIA 30303 Report No. 50-395/82-09 Licensee: South Carolina Electric & Gas Company P. O. Box 764
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Columbia, South Carolina 29218 Facility Name:
Summer Docket No. 50-395 License No. CPPR-94 Inspection at Summer site near Columbia, South Carolina
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Inspect C Y h _ /2 m + &
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247 9 ~ 3 ~ 0Z*
W. H. Miller, Jr.
Date Signed Approved b pr J
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T. E. Conlon, Section Chief Date Signed Engineering Inspection Branch Engineering and Technical Inspection Division
SUMMARY Inspection on January 19-22, 1982 Areas Inspected
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This routine, announced inspection involved 28 inspector-hours on site in the i
areas of fire protection / prevention.
j Resdits Of the areas inspected, no violations or deviations were identified.
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8203020163 820205
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PDR ADOCK 05000395
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I REPORT DETAILS 1.
Persons Contacted Licensee Employees
- W. A. Williams, Jr., General Manager Nuclear Operations
- 0. S. Bradham, Plant Manager
- J. Connelly, Deputy Plant Manager
- A. R. Koon, Technical Service Coordinator
- L. F. Storz, Assistant Manager Operations
- D. Moore,. Manager QA
- H. I. Donnelly,.ISEG Engineer
- 0. W. Dixon, Group Manager, Production Engineering, QC and Construction
- V. R. Albert, Assistant Manager - Support Services
- B. G. Croley, Assistant Manager - Technical Support
- M. W. Clonts, Manager QC/ Construction
- P. V. Fant, Director Stati an QC
- G. M. Webb, Engineer / Nuclear' Engineer
- S. S. Howz, Licensing B. E. Tunnehill, Fire Protection Coordinator W. R. Hollace, QC C. Price, QC C. Turkett, QC NRC Resident Inspector
- J. L. Skolds
- Attended exit. interview 2.
Exit Interview
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The inspection scope and findings were summarized on January 22, 1982 with those persons indicated in paragraph I above.
3.
Licensee Action on Previous Inspection Findings
a.
(Closed) Deviation Item (395/79-17-01) - Fire Pump Installation Does Not Meet the Requirements of National Fire Protection Association (NFPA) Standard 20, " Centrifugal Fire Pump": The licensee has revised the Fire Protection Evaluation (FPE) to describe the actual fire pump installation including the power supply arrangement which does not meet
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i the locked rotor requirements of NFPA-20.
This data and pump design
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and installation has been reviewed by NRR and found acceptable. Refer j
to Section 9.5.1 (page 9-4) of the Safety Evaluation Report (SER),
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Supplement 3, dated January 1982. Therefore, this item is closed.
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b.
(Closed) Unresolved Item (395/81-13-01) - Discrepancies Between. Fire Protection Features Provided and Those Listed in the SER. The licensee met with NRR to discuss these problems and has revised (Revision 7 -
December 4, 1981) the Fire Protection Evaluation Report to correct these discrepancies. NRR has revised the SER (Supplement 3) to correct the previous discrepancies. Therefore, this item is closed. However, the licensee has identified some new discrepancies or misunderstandings in the revised SER and has referred these items to NRR.
Refer to paragraph 5.d for additional information on this item.
c.
(Closed) Deviation Item (395/81-13-02) - Inadequate QC Document of the Fire Alarm System Installation.
The licensee has conducted a detail inspection of the fire alarm system installation and found a number of discrepancies.
These have been identified by Nonconformance Notice 1396E which has been reviewed and found acceptable by Nuclear Project Engineering except for a number of minor changes. Disposition of these items are scheduled to be accomplished under the licensee's normal QA/QC program. This item is closed.
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(Closed)
Inspector Followup Item (395/81-13-03) Review of QC Documentation for HVAC Fire Protection Equipment. The fire detection systems associated with the HVAC systems have been removed from consideration as part of the plant fire detection systems and are no longer referenced by the Fire Protection Evaluation Report.
The inspector has no further questions on this item'at this time. The fire dampers for non safety related systems were inspected by the licensee during the system QC walkdown inspection.
Documentation of these inspections was provided in the system turnover work packager. This is considered acceptable for the level of QC requirements that were in effect for these systems at the time of construction and installation.
This item is closed.
4.
Unresolved Items Unresolved items are matters about which more information is required to
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determine whether they are acceptable or may involve violations or devia-tions. New unresolved items identified during this inspection are discussed in paragraph 5 d.-
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Fire Protection Feature - Permanent Plant The inspector reviewed the licensee's accomplishments on the fire protection commitments made to the NRC.
The licensee's Fire Protection Evaluation
Report (FPER), Revision 1-7 and the NRC SER, Supplements 1-3 were used in
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this review.
Plant QA/QC documentation, construction documents and procedures were reviewed and a tour was made of the plant by the inspector to review the follcwing:
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a.
Fixed Fire Protection Systems:
(1) Automatic Sprinkler Systems
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Installation of the piping portion of the sprinkler systems 'is practically complete, except protection has not yet been provided beneath the suspended fire barrier above service water booster pump A.
Also, the actuation. circuit to each deluge / pre-action valve has not yet been changed to a Class A supervised circuit as required by the SER. This modification requires the installation of five new control panels (XPN79-FS, XPN91-FS, XPN98-FS, XPN99-FS and-XPN100-FS).
The sprinkler system installation and modifications are schedule to be completed by February 26, 1982.
QC documentation for the inspection of the sprinkler systems was previously reviewed by the inspector and reported in NRC 395/81-13. The inspector reviewed the following test data during this inspection.
DATE FLUSH FLUSH TEST HYDROSTATIC SYSTEM NO.
LOCATION TEST NO.
COMPLETED TEST FS-09 Diesel'
SUM-C-05 10-8-79 Not dated Generator Building FS-02 & 22 Fire Pump No Record 5-6-80 l
Bldg.
FS-24 Service Water No Record 2-18-81
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This licensee identified in QA Type II~ Surveillance Report II-40-81 of September 21 - October 8, 1981 that documentation was
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not adequate on the flushing of the automatic sprinkler piping i
systems. The contractor stated that the systems had been flushed but not documented. Therefore, the licensee flushed a random
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sample of three systems.
These flush tests were satisfactory and
were documented by QA' Type I Surveillance Report 1827..The licensee stated that further reflushing was not considered necessary.
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(2) Exterior Fire Protection Water Distribution System The inspector reviewed construction documents which indicated the (
location and installation requirements for-the fire protection water system.
Documentation was not available to substantiate i
that the system installation was in conformance with the
construction documents. This system was installed prior to the
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NRC QA/QC requirements for fire protection systems. Therefore, this does not appear to be an enforcement item. The inspector reviewed the following available test data:
SYSTEM NO.
TYPE TEST DATE FS-01 Hydrostatic 7-13-78 FS-12 Hydrostatic 8-16-78 FS-01 to 04 Hydrostatic 3-05-81 FS-01 Flush 1-17-79 Two hydrant equipment houses have not yet been permanently installed. These are to be installed by February 26, 1982.
The hydrant houses will be inspected during a subsequent NRC inspection.
(3) Fire Detection Systems Installation of the fire detection systems is practically complete. A modification is in process to change the sprinkler system actuation circuits to a Cla:s A system.
Refer _to above paragraph 5.a.(1).
Also, the fire detection system is to be extended to provide coverage in the battery room ventilation equipment rooms in the intermediate building and over the
'ectrical equipment area on the 436' elevation of the auxiliary building.
These items are to be completed by February 26,-1982.
The inspector reviewed the QA/QC inspection documents on the detection installation.
As noted in above paragraph 3.c, the licensee had issued Nonconformance Notice 1396E which identified a number of discrepancies. These discrepancies'are being corrected or the identified discrepancies have been -reviewed and found acceptable by Nuclear Project Engineering.
During the plant tour _ the inspector noted a number of areas containing safety related equipment, components and cables which were not provided with fire detection. These areas included:
Auxiliary Building
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RHR spray pump room coolers
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Safety Related cable on 374, 397, 400, 412, 426, 446 and 463 foot elevations i
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Valves LCV-115B and LCV-1150 on 400' elevation
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RHR heat exchangers
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Boric acid tanks i
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1 Intermediate Building
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Battery changer room
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Battery rooms
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Service water booster pump area cooling equipment
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Steam relieve valve IPV-2010
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Component cooling water pump speed switchgear rooms
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Switchgear cooling Units A and B
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Speedswitch room cooling units
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Reactor trip switchgear
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Safety Related cables on 426, 436 and 463 foot elevations Control Building
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Control building HVAC equipment rooms The SER Supplement 3 (pages 9-4) states that " fire detection systems will be installed in all areas having safety related equipment." The licensee considers this statement to be in error and by letter dated January 18, 1982 f rom T. C. Nichol s, Jr.,
SCE&G to H. R. Denton, NRR has requested that this SER statement be deleted or modified. This item is identified as an unresolved item pending resolution. Refer to paragraph 5.d for details.
(4) Carbon Dioxide System (Relay Room)
The carbon dioxide piping system installation is complete.
The carbon dioxide storage tank has a leak and was empty. Also, the licensee stated that a portion of the actuation and control components are the wrong type (AC in lieu of DC) and must be replaced. Installation and functional and concentration tests are scheduled to be completed by February 26, 1982.
Construction documentation records and test data will be reviewed during a subsequent NRC inspection.
(5)
Fire Barriers for Cables The installation of the lh hour fire barriers for redundant cables located within 20 feet of each other is approximately 70*;
complete. This work is scheduled to be completed by February 26, 1982.
(6)
Fire Doors The fire doors for all stair shafts and fire wall penetrations are installed.
However, none of the stairway doors and many of the other doors are not equipped with the required hardware and wire glass windows. Installation of all fire doors is scheduled to be completed by February 26, 1982.
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(7) Fire Extinguishers The licensee stated that all of the permanent plant fire extinguishers are on -site and are scheduled to be properly distributed and installed by February 26, 1982..The inspector will veri fy during a future inspection that the location and
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spacing will meet the requirements of NFPA-10, Fire Extinguishers.
The reinspection of the above permanent plant fire protection equipment and features will be accomplished during a subsequent NRC inspection prior to fuel load. This item is identified as Inspector Followup Item (395/82-09-01) Installation of Permanent Fire Protection Equipment and Systems Required Prior to Fuel Load.
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I b.
Emergency Breathing Air Supply The inspector reviewed the emergency breathing air supply available for the fire brigade. A total of 55 self contained breathing apparatus (43-on site 12 on order) and 55 spare cylinders will be available.
The units are to be recharged by a fixed air compressor which the licensee i
states has a capacity to refill about eight 60 minute cylinders per
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hour. Section 5.D.4(h) of the Fire Protection Evaluation (page 5.0-25)
states that at least two extra air bottles will be located on site for each self-contained breathing unit and that an 8-hour onsite supply of reserve air will be maintained to provide sufficient air for the fire
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brigade, damage control and control room personnel.
It appears that the equipment provided will not meet this commitment. The licensee has agreed to evaluate the equipment provided and to initiate any necessary modifications by February 26, 1982.
This is identified as Inspector Followup Item (395/82-09-02) - Evaluation of the Adequacy of Emergency Breathing Air Supply for Fire Brigade.
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Presently, the air compressor is not connected to a permanent power
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supply. The inspector advised the licensee that current NRC criteria, 10 CFR 50 Appendix R paragraph III.N, requires these air compressors to l
be operable assuming a loss of.offsite power.
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c.
Fire Protection Administration Procedures
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i The inspector reviewed the following licensee's administrative
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procedures:
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PROCEDURE NO.
TITLE AP-1103 Fire Protection Emergency Training and Drills (Revision 1)
AP-1400 Fire Protection Program Plan AP-1401 Fire Protection Program EPP-013 Fire Emergency EPP-001 Fire Fighting Equipment FPP-002 Fire Report (Change 1)
FPP-003 Control of Transient Combustibles FPP-004 Duties of a Fire Watch FPP-005 Burn Permit FPP-006 Handling of Flammable Liquids and Gases FPP-007 Preparation and Distribution of Fire Protection Procedures FPP-100 Fire Protection Preplan Room RB 12-01 Outside Secondary Shield Wall Room FPP-209 Fire Protection Preplan Room 1812-12 Chiller Room "A" FPP-702 Fire Protection Preplan Room SWPH 25-05 Electrical Equipment Room These procedures in general comply with the NRC guidelines of the document entitled
" Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance" dated June 20,1977 except for the following:
(1) Physical examinations to assure that fire brigade members can perform strenuous fire fighting activities are not specified.
(Gu-:de'.ine Attachment 1 Paragraph 2.b)
(2) Removal of all waste, debris, scrap and other combustible, resulting from work activity at the end of the work shift or completion of job, whichever is sooner is not spacified.
(Guideline Attachment 3 Paragraph 1.c.)
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(3) Verification that all welding and cutting equipment and other open flame devices are in a safe working condition before being moved to the work area -is not specified.
(Guidelines Attachment 4, Paragraph 2.b.(4))
(4) Duration of welding and cutting permit is not indicated (10 CFR 50 Appendix R Paragraph III.k.5 states 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when plant _is operating and for the duration of a particular job when plant is shut down)
(5) Use of open flame for leak testing is not prohibited and acceptable leak test methods are not indicated.
(Guidelines Attachment 4 Paragraph 3)
The licensee agreed during the exit interview to evaluate the above discrepancies and to revise the existing procedures by February 26, 1982.
This item -is identified as Inspector Followup Item (395/82-09-03) - Revisions required on fire protection administrative control procedures, and will be reviewed _during a subsequent NRC inspection.
d.
Miscellaneous Items The licensee has identified to NRR by letter of January 18, 1982 from T. C. Nichols, Jr. SCE&G to H. R. Denton, NRR the following apparent differences or discrepancies between the SER Supplement 3 and previous
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fire protection commitments by SCE&G:
(1) Page 9-3 of the SER states that a water suppression system is to be provided - for the auxiliary building gas treatment-filters.
However, no charcoal filters for gas treatment in the auxiliary building are provided.
(2) Page 9-4 of the SER states that all fire hose stations in Zone 9 of the auxiliary building are to be increased to 100 feet.
However, only the hose station adjacent to the north stair tower is required to be increased to 100 feet.
Adequate hose is-provided on the remaining stations.
(3) Page 9-4 of the SER states that fire detection systems will be installed in all areas having safety related equipment.
The licensee only committed to install fire detection systems in the areas identified by the FPE.
The inspector found, as noted in above Paragraph 5.a(3), a significant number of areas which contain safety related equipment in which fire detection is not provided.
(4) Page 9-5 of the SER states that "where required" structural steel framing will be provided with a three hour fire rating.
The licensee has identified an area, Zone 5 of the intermediate
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building, in which the steel is not protected.
This area is-provided with automatic sprinkler protection and the licensee states that this was found acceptable by NRC during a July 7,1981-meeting.
(5) Page 9-5 of the SER states that the ladder opening between the "A"
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train switchgear cooling unit room and the train "B" switchgear room in the intermediate building was to be filled in with grout.
However, the licensee advised the NRC by letter dated August 21, 1981 that this opening was to be provided with a three' hour fire rated enclosure.
(6) Page 9-5 of the SER states that che licensee will provide test data to verify three hour rated construction of the dry-wall-on steel stud construction. The licensee stated that this data was provided to NRR on August 21, 1981.
(7) Page 9-9 of the SER states that the licensee is to provide eight hour emergency battery lighting in all areas which could be manned for sate shutdown and in access and egress. routes to - all
" fire areas".
The licensee states that the commitment was to provide these lighting units in areas that could be manned for safe shut down and in the access and egress routes to the safe shut down areas.
(8) Page 9-11 of the SER states that primary system depressurization and boration is controlled from the control room evaluation panel (CREP). The licensee states.that the CREP does have indication and control of charging flow but the charging pumps are not controlled from the CREP.
The apparent conflict between SER Supplement 3 and the licensee's understanding of its commitments is identified as Unresolved Item (395/82-09-04), Discrepancies Between the Fire Protection Features Provided and Those Listed in the SER.
This item is to remain ~ open pending NRR's evaluation.
Within the areas examined, no violation or deviations were identified.