IR 05000400/1982010

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IE Insp Repts 50-400/82-10 & 50-401/82-10 on 820413-16. Noncompliance Noted:Improper Storage & Inadequate Maint on Fire Protection Sys Components
ML20054K226
Person / Time
Site: Harris  Duke Energy icon.png
Issue date: 05/05/1982
From: Conlon T, Miller W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20054K207 List:
References
50-400-82-10, 50-401-82-10, NUDOCS 8207010311
Download: ML20054K226 (10)


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UNITED STATES

NUCLEAR REGULATORY COMMISSION o

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REGION 11 101 MARIETTA ST., N.W., SUITE 3100 o,

s ATLANTA, GEORGIA 30303 s

Report Nos. 50-400/82-10 and 40-401/82-10 Licensee:

Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name:

Harris 1 and 2 Docket Nos. 50-400 and 50-401 License Nos. CPPR-158 and CPPR-159 Inspection at Harris site near Raleigh, North Carolina Inspector-W

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W. H. Miller, Jr.

Date Signed Approved by

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M S-S~-8Z-T. E. Conlon, Section Chief Date Signed Engineering Inspection Branch Division of Engineering and Technical Programs SUMMARY Inspection on April 13-16, 1982 Areas Inspected This routine, unannounced inspection involved 29 inspector-hours on site in the areas of fire protection / preventions.

Results Of the areas inspected, no violations were identified. One apparent deviation was found (Improper storage and inadequate maintenance on the fire protection system components paragraph 6.a).

8207010311 820610 PDR ADOCK 05000400

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REPORT DETAILS 1.

Persons Contacted Licensee Employees

  • R. M. Parsons, Project General Manager
  • A. M. Lucus, Sr. Resident Engineer

"N. J. Chiangi, Manager Engineering & Construction QA/QC

  • G. L. Forehand, Director QA/QC
  • E. E. Willett, Resident Engineer - Mechanical
  • W. J. Szuba, Mechanical Construction Inspection Supverisor D. Whitehead, QA Representative S. Freshwater, Mechanical Piping Systems W. Harris, Mechanical Maintenance R. Williams, QA Inspector D. Shockley, QC - Mechanical Other Organizations
  • W. D. Goodman, Project Manager, Daniel Construction Co.

E. Schmeltar, Safety / Fire Protection, Daniels Construction Co.

D. Poole, Safety Engineer, Daniels Construction Co.

  • Attended exit interview 2.

Exit Interview The inspection scope and findings were summarized on April 16, 1982, with those persons indicated in paragraph 1 above.

3.

Licensee Action on Previous Inspection Findings Not inspected.

4.

Unresolved Items Unresolved items are matters about which more information is required to I

determine whether they are acceptable or may involve violations or devia-tions. New unresolved items identified during this inspection are discussed in paragraph 5.a and 6.d.

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5.

Construction Fire Protection / Prevention Program a.

Procedures The inspector reviewed the following licensee's procedures for the construction site fire protection program:

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NUMBER TITLE AP-VII-02 Fire Prevention, Protection and Control (Revision 2)

AP-VII-03 Construction Fire Brigade (Revision 4)

AP-VII-05 Fire Protection Systems Inspection and Maintenance (Revision 10)

These procedures describe the program and provide the requirements to implement this program.

However, the procedures do not adequately address or fail to require accomplishment of a number of important fire protection items such as the following:

(1) Safety procedures for welding and cutting operations. Guidelines for safeguarding these operations are included in National Fire Protection Association (NFPA) Standards 241, Building Construction Operations, and 51B, Cutting and Welding Process.

(2) Procedures for the control of combustible temporary enclosures, building and scaffolding within the permanent power plant struc-tures. Refer to NFPA-241 Section 2 for details.

(3) Control and safety procedures for temporary heating equipment inside the plant structure.

Basic guidelines are included in NFPA-241 Section 3-2.

(4) Procedures for the control, use and storage of combustible and flammable liquids and gases inside the plant structure.

Guide-lines are included in NFPA-241 Section 3-5, NFPA-30, Flammable and Combustible Liquid Code, and NFPA518.

(5) Procedures for weekly operational tests and annual full load or capacity test on the fire pump.

Refer to NFPA-20, Centrifugal Fire Pumps, Section 12-3 for details.

(6) Minimum water supply requirements for fire protection at the plant structure and requirements for installation of fire hose stations at each elevation and all areas of the plant structure. NFPA-241 Section 5-3.1 suggests a minimum water supply of 500 gpm and Sec-tions 5-4 and 5-7 require temporary fire hose stations for all portions of the plant structure.

(7) The description of the water supply system in existing procedure AP-VII-02 Section 4.3.1 is not correct.

(8) Procedure AP-VII-05 Section 4.2.1 requires all fire protection water control values to be locked with a breakable pad lock, but Exhibit 1 to this procedure does not require the valves from the water and fire pumps to be locke,

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The licensee agreed to review the existing procedures to determine what revisions should be made.

These revision should bring the pro-cedures up to the NFPA standards as required by ANSI N45.2.3 (1973)

Section 3.2.3.

This item is identified as Unresolved Item (400/82-10-01 and 401/82-10-01) Inadequate Fire Protection / Prevention Admin-istrative Procedures, and will be reviewed during a subsequent NRC inspection.

The licensee stated that procedures should be revised and implemented by August 1, 1982.

b.

Fire Protection Systems and Equipment (1) Water Supply System Water for construction and fire protection requirements is sup-plied from the same system.

A 2500 gpm at 125 psi fire pump, a service water pump rate at approximately 400 gpm and a small pressure maintenance jockey pump take suction from a large open pond reservoir and discharge into a single, dead end 12-inch water main.

The pumps are installed to start on pressure demand with the service water pump being the lead pump. The system supplies water to the construction and warehouse areas through 12 and 8 inch fire mains. Water for the permanent power plant is supplied through two long 3-inch dead end water lines each of which will supply only one fairly good Ih-inch hose stream at grade level.

Temporary fire hose stations are provided throughout the plant structures except hose stations have not yet been provided for the 261', 286' and 305' elevations of the auxiliary building and s

261' elevation of the waste process building. These systems are scheduled to be installed by June 1, 1982. This is identified as Inspection Followup Item (400/82-10-02 and 401/82-10-02) temporary fire hose stations to be installed throughout the power plant structures, and will be reviewed during a subsequent NRC inspec-tion.

Control and sectional valves are installed in the system to control or sectionalize portions of the system for maintenance testing or repairs.

However, a large portion of the system consists of a single supply main. All of the valves except the valves at the pumps are maintained locked in the correct position.

(2) Fire Alarm System An electric siren is provided to alert the fire brigade and other plant personnel in the event of fire. The siren is located north of the plant structure and the licensee stated that the siren can ce heard in most areas of the plant.

(3) Fire Extinguishers A total of approximately 660 fire extinguishers are distributed throughout the plant site. Approximately 90% of the extinguishers are of the dry chemical type and the remainder are carbon dioxide unit _

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c.

Fire Brigade (1) Organization

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A fire brigade was provided for the day (first) and evening i

(second) shifts. Normally a total of 14 trained brigade members are available for first shif t and 7 trained brigade members are

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avaiable for the second shift. The brigade size appears adequate for a first response team in the event of fire.

Offsite fire

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departments are also available upon request.

(2) Training

The licensee's procedure AP-VII-03 requires each brigade to participate in a monthly drill or training session. Currently a

training session or drill is conducted for each brigade approxi-

mately once per week. The inspector reviewed the training records for January - March 1982 and verified that most members had par-

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ticipated in the weekly training sessions and that all had I

participated in at least one monthly session.

l (3) Fire Brigade Equipment A sufficient quantity of turnout gear (coats, pants, boots, i

helmets, etc.) was provided to equip ten fire brigade members.

This equipment was stored in equipment lockers in the construction area north of the plant structure. A total of four self contained breathing apparatus and two spare cylinders, foam equipment, fire extinguishers and miscellaneous fire fighting equipment was also stored in this area. This equipment is considered adequate for a construction site fire brigade and appeared to be satisfactorily stored and maintained.

d.

Fire Brigade Drill

The inspector witnessed a fire brigade drill conducted on April 14, 1982 for the second shift. A fire was simulated on the south side of the turbine building. One noted area of possible improvement would be

to have all of the fire equipment stored on a vehicle which could be i

driven close to the scene of the fire.

Presently the fire fighting equipment must be relocated from the storage cabinets to any vehicle that may be available for use by the brigade.

It took approximately

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five minutes during this drill to locate a vehicle and place all of the fire equipment on to the vehicle.

This item was discussed with

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the licensee during the exit interview.

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e.

Off Site Fire Departments Procedure AP-VII-02, Fire Prevention Protection and Control, Section 3.5 states that action is required to " assure that, if required, local fire departments are available to assist in fire fighting." However, the most recent visit to the plant by the local fire departments was on June 26, 1979 in which a total of 20 fire fighters from the Apex, Holly Springs and Fuquay-Varina Fire Depart-ments visited the site for a plant tour and general orientation. The inspector suggested the licensee attempt to have more frequent visits by the local fire departments to assure that the fire departments will be familiar with the plant complex in the event of a fire, f.

Records Review (1) Fire Protection Equipment Inspections: The following inspection and test data sheets on the fire protection systems were reviewed for indicated dates and discrepancies found are noted:

(a) AP-VII-05, Exhibit 1, Weekly Valve and Fire Hose Inspection Report: January 8 - April 9,1982.

Inspection report for week of January 11-16 was not available. However, AP-VII-05 Section 3.5 permits one missed inspection but not two in succession.

(b) AP-VII-05, Exhibit 4, Quarterly Fire Protection Inspection and Maintenance: March 1981 - January 1982.

No discrep-ancies noted on recorded data. However, the procedure does not require an operational test of the fire pump. As noted in above paragraph 5.a.(5) periodic fire pump operational tests are not required by the existing procedures.

(c) AP-VII-05, Exhibit 6, Annual Fire Protection Inspection and Maintenance: October 1980 and October 1981. The acceptance criteria for the fire pump tests conducted in December 1981 exceeded the requirements of AP-VII-05 Section 4.1.3.

This discrepancy was discussed with the licensee. The acceptance criteria is to be reviewed by the licensee to assure that it is not excessive. As noted in above paragraph 5.a.(5) this procedure does not require an annual full capacity test on the fire pump.

(d) AP-VII-05, Exhibit 10, Hose Test Report:

Test of the fire hose was in progress on date of this inspection. This test was added to the procedure in September 1981 and all hose had not yet been tested. The licensee stated that all hose tests are scheduled to be completed by August 1, 1982. This item will be reviewed during a subsequent NRC inspection.

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f (2) AP-VII-03, Fire Brigade Management Review: The Semiannual reviews of the fire brigade training and readiness conducted by the site and project managers on June 27 and December 1,1981 were reviewed

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by the inspector. 'It appears the review met the requirements of j

the procedure.

(3) Fire Brigade Training: Refer to above paragraph 5.c.(2).

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Audit Report

The fire protection / prevention report for the inspection conducted on

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February 24, 1982 by M&M Protection Consultant was reviewed by the L

l inspector.

This report did not contain any recommendations.

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insurance inspector conducts a fire protection and loss prevention

j inspection every 60 days.

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h.

Plant Tour

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The inspector conducted a tour of the plant to review the general

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housekeeping and fire prevention practices and to inspect the temporary fire protection systems and equipment. Fire hose stations 9, 11 and 12 were inspected and were found equipped with the. correct quantity of fire hose and nozzles. A total of 15 fire extinguishers located in various areas throughout the plant were inspected and found in service.

The inspection data tag attached to each extinguisher was up to date.

The fire extinguisher and fire hose inspection and maintenance program l

appeared satisfactory except annual service tests had not been con-ducted on all of the fire hose, but this test was in progress. Refer

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j to above paragraph 5.f(1)(d).

The inspector observed six welding operations in various locations of the auxiliary building,-waste treatment building and control room and

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noted numerous violations to the safe fire prevention criteria of NFPA-51B, Cutting and Welding Processes.

.These included welding directly over an accumulation of combustible trash, over combustible wood scaffolding and polyethylene, and over unprotected floor openings.

A fire watch was not provided for the observed welding operations. A paint mixing operation was observed in one of the future equipment

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enclosures on the 236' elevation of the auxiliary building. Air driven

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paint mixers were being used, but no forced ventilation was provided

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and ordinary electrical equipment and temporary lighting units were provided in the vicinity of the mixing operation.

Currently, the licensee does not have approved procedures to cover a number of fire

protection and prevention features. As noted in paragraph 5.a, the existing procedures are to be evaluated and revised as necessary to

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describe the construction fire protection / prevention program. These

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observed fire prevention discrepancies are considered a part of above Unresolved Item (400/82-10-01 and 401/82-10-01).

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Within the areas examined, no violations or devations were disclosed.

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6.

. Fire Protection Yard and Piping System Approximately 20'e of the permanent fire protection water system was installed. Installation of the diesel engine driven' fire pump and south portion of the distribution system is scheduled to be completed by summer of 1982. The following items were reviewed during this inspection:

a.

Procurement Receipt Inspection and Storage The inspector reviewed the procurement documents, receipt inspection records and storage of the following fire protection components:

ITEM PROCUREMENT NO.

STORAGE LEVEL Fire Pump Not Available D

Diesel Engine Drive Not Available D

Batteries Not Available D

Pipe - 12" H-21126 D

Fittings - 12" H-21126 D

Post Valves - 8" H-21951 D

Curb Valves - 6" H-07950 D

Fire Hydrant H-21951 D

Procurement and receipt inspection documents were not available for the fire pump and diesel engine driver and batteries. This equipment was apparently ordered and received prior to the initiation of the fire protection QA program. The inspector found the fire pump, diesel engine batteries, and valves not sorted and maintained in conformance with licensee's storage procedures. PGD-001 (AP-XIII-05), Material and Equipment Storage Requirements and PGP-002 (AP-XIII-07) Material Main-tenance Requirements During Storage.

The diesel engine was stored outside and not adequately protected against entrance of water into the engine.

This was identified by the licensee in NCR M-176 of February 26, 1982.

The engine is being returned to the vendor for necessary repairs and maintenance prior to installation.

However, the following discrepancies were not identified by the licensee: fire pump was stored outside and pump internals were not protected against entrance of water and airborne debris; shaf t of fire pump was not being rotated on a periodic basis; diesel engine batteries were stored out-side in lieu of inside a Class B warehouse; fire protection valves were stored outside and valve internals were not protected against airborne contaminants; and bolts for valve assemblies were stored outside without a rust preventor.

PSAR Section 1.8.6(2) states that periodic inspection and tests at the site on the fire protection program will be prescribed by documented instructions, procedures and

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drawings and will be accomplished in accordance with these documents.

The failure to store and maintain the fire protection components in accordance with the plant storage and maintenance procedure is identified as Deviation Item (400/82-10-03 and 401/82-10-03).

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The above fittings for the fire protection system were not listed by Underwriters Laboratories, Inc. or approved by Factory Mutual. How-ever, the fittings were purchased from a supplier who was a CP&L's approved vendor, The licensee stated that the vendor met the QA/QC requirements of PSAR Section 1.8.6(3).

b.

License's Inspection of Completed Work The construction inspection group conducts inspections of the piping installation to verify that the piping is being installed in accord-ance with the construction drawings and specifications. Only a small portion of the system had been inspected but the inspector reviewed several incomplete inspection traveler sheets and the following completed data sheets and verified that the inspections were being accomplished:

DATE PIPE LINE NO.

YARD COORDINATE INSPECTION COMPLETED 8FP12-25-1-4 N848 to

'O 10-8-81 8FP8-5-1 N1122 to NISUS 03-4-82 c.

Hydrostatic Tests The yard piping is being hydrostatically tested at approximately 225 psi for two hours.

These tests are being witnessed by the QA group.

The following test data sheets were reviewed by the inspector and no discrepancies were noted:

DRAWING LINE NO.

PLANT COORDINATE DATE OF TEST 8FP4-309-1 N1409-N1411 09-21-81 W1312-W1339 8FP12-24-1-4 N843-N1046 07-02-81 8FP12-24-1-4 N534-N343 10-28-80 8FP12-423-1 W1343 - Bldg. Line IB 04-23-80 d.

Review of Work in Process The inspector inspected portions of the fire protection piping system being installed south of the plant.

The installation appeared to be being accomplished in accordance with the construction drawings and specification.

However, it was noted that the inspection of the cathodic protection was being accomplished by the coating inspector but there was no formal inspection procedure for this item and the

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inspections were not being documented.

The licensee is to evaluate this item to determine what procedure changes should be made.

This is identified as Unresolved Item (400/82-10-04 and 401/82-10-04),

Inspection Documentation Requirements for Fire Protection Water Supply Cathodic Protection, and will be reviewed during a subsequent NRC inspection.

Except as noted above, within the areas examined, no violatior-or additional deviations were disclosed.