IR 05000412/1987011

Insp Rept 50-412/87-11 on 870203-06.No Violations Noted. Major Areas Inspected:Fire Protection/Prevention Programs, Including Insp of Fire Main Loop Installation,Procurement & Installation Procedures & Plans for QA

ML20205F046
Person / Time
Site:	Beaver Valley
Issue date:	03/12/1987
From:	Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20205F043	List: IR 05000412/1987011 ML20205F039
References
50-412-87-11, NUDOCS 8703310074
Download: ML20205F046 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-11 Docket N License N CPPR-105 Priority -

Category B Licensee: Duquesne Light Company Post Office Box 4 Shippingport, Pennsylvania 15077 Facility Name: Beaver Valley 2 Inspection At: Shippingport, Pennsylvania Inspection Conducted: February 3-6, 1987 Inspector: 3 /2 87 A. Kfasopoulos, Rea8 tor Engineer date Approved by: J 17 C. Anderson, Chief, Plant Systems Section date Inspection Summary: Inspection on February 3-6, 1987 (Inspection Report No. 50-412/87-11)

Areas Inspected: Routine unannounced inspection of the fire protection /

prevention program plans including an inspection of the fire main loop installation. The inspection included a review of: procurement and instal-lation procedures; plans for Quality Assurance (QA) audits and records; the combustible material control / hazard reduction program; programmatic adminis-trative controls; installation, operability and maintenance of fire protection systems; fire fighting capabilities; fire protection equipment maintenance inspection and tests and a facility tou Results: Of the eight areas reviewed, no violations were identified. Three items remain unresolve PDR ADOCK 05000412 G PDR

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DETAILS 1.0 Persons Contacted 1.1 Duquesne Power and Light Company (DPLC)

• T. Noonan, Superintendent, Operations and Maintenance

• G. Beatty, Licensing Engineer

• J. Oneil, Licensing Engineer

• L. Miller, Engineer, Nuclear Operations

• J. Harding, Engineer

• G. Wargo, Assistant Director, Quality Control J. Randolph, Procedure Engineer

• J. Maracek, Senior Licensing Engi'neer

• G. Svaranowic, Fire Protection Engineer

• R. Wittschen, Licensing Engineer

• J. Belfiore, Senior Quality Assurance Specialist

• L. Rabenau, Compliance Engineer

• J. Godleski, Senior Test Engineer

• M. Kilpatrick, Senior Quality Assurance Specialist

• J. McArdle, Engineer

• A. Lerczak, Procedures Supervisor

• P. Cadena, Supervising Engineer

• H. Hughes, Engineer

• H. Cox, Nuclear Operations Training 1.2 Nuclear Regulator Commission (NRC)

J. Beall, Senior Resident Inspector A. Asars, Resident Inspector

• L. Prividy, Resident Inspector

• Denotes those present at exit intervie .0 Inspection Purpose and Methodology The purpose of this inspection was to evaluate the licensee's. fire protection and prevention program (FPPP) readiness to load fuel and verify that the utility has developed adequate procedures that are consistent with the applicable proposed license conditions, regulatory requirements and commitments made in the Final Safety Analysis Report (FSAR). The evaluation of the program consisted of a documentation

. and procedure review, interviews with licensee personnel and field observation The documents reviewed, the scope of review and the inspection findings for each area reviewed are described in the following section . _ - _ _ _ - _ ,

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3.0 Fire Protection Work, Construction Activities The inspector reviewed construction activities relating to the procurement and installation of pen.etration seals and the installation of the main fire loop. The documents reviewed and the scope of review are described belo .1 Procurement and Installation Activities The inspector reviewed the following documents:

Procedures for the Installation and Testing of Penetration Seals:

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IP-1700.501, Installation of Promatec LDSE and/or Sylgard 170

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IP-1030.101, Fabrication Instructions for Promatec Flexible Boots

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IP-1030.102, Installation Procedure for Flexible Boot Seals

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QCP-0014, Penetration Inspection Acceptance Criteria and Documentation

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CTP-1045, Procedure for the Three Hour Qualification Test B&B Flexible Diaphragm

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Miscellaneous purchase orders for the Fire Loop Piping

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Piping Drawings Nos. 12241-RB-2A-12a and 12241-RB-28-3c, Yard Piping Underground Sheets 1 and 2

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Review of the fire pump installation

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Specification for yard sewers, fire and domestic water systems No. 2BVS-912 The scope of review was to verify that the licensee has developed procedures which will assure field activities pertaining to the installation or modification of fire seals and the Fire Main Loop and to assure these activities are being accomplished in accordance with the applicable codes, standards and licensee commitment With regard to penetration seals, the inspector verified that:

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Penetration seal tests have been performed by generally accepted techniques

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Seal installation conforms to tested configurations

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QC hold points exist at critical points for the installation of the seals

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With regard to the fire loop installation, the inspector verified that:

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Materials suc,h as pipes, pipe joints, mains, anchors, valves and clamps are as specified

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Fire pump (s) and associated controls and wiring conform to NFPA 20 standards

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The design and fabrication codes and standards (NFPA, AWA, ANSI, ASME) requirements have been identified or specified in procurement documents

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Critical dimensions are specified. (Size and location of water supplies, size and location of all piping and the depth to which it is to be buried, etc.)

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Fire hydrants comply with NFPA or AWA criteri ;

The only deficient condition identified is described belo Fire Loop Installation The inspector requested to review the installation details of the fire loop and, in particular, the pipe restraint detail The licensee could not find the installation details during the inspection because this work was done in 1974. This is an unresolved item pending verification of the acceptability of the pipe restraint i method used at pipe locations of direction change and under safety-

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related buildings. (50-412/87-11-01)

3.2 Receipt Inspection The inspector reviewed various material receipt reports and receipt i

inspection reports performed by the site Quality Control group to I ascertain that receipt inspection instructions specify inspection for damage, conformance to purchase specifications (including any special requirements), proper identification and verification that the proper supplier / vendor documentation is receive No unacceptable conditions were identifie .0 Fire Protection Program Review 4.1 Review of Administrative Controls The inspector reviewed the following licensee documents:

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FSAR Section 9.5.1, Fire Protection System (Amendment 14)

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General Work Practice Procedures, Section 13

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GWP-1, General Work Practices for Cutting, Welding, '

Grinding on Open Flame Work

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GWP-2, General Work Practices for Fire Prevention

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GWP-3, General Work Practices for Maintenance of Penetration Fire Barriers and Fire Doors

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Site Administrative Procedures Chapter 90, Fire Protection, Revision 4 (Draft)

The scope of review was to verify that the licensee had developed administrative controls which require that: a work authorization, construction permit or similar arrangement is provided for review and approval of modification, construc-tion and maintenance activities which could adversely affect the safety of the facility; the fire brigade organization and qualificatiens of brigade members are delineated; the fire reporting instructions for general plant personnel are developed; periodic audits are to be conducted on the entire fire protec-tion program; and the fire protection / prevention program is included in the licensee's QA Progra During the procedure review, the inspector noted that the licensee training for fire watches' assigned to patrol areas with degraded fire protection equipment is limited to instructions to notify the control room in the event of a fir The licensee committed to revise all applicable procedures so that fire watches established for this purpose receive the same training as the fire watches established for hot work. They will be provided hands-on trainin '

. The licensee also committed to post fire watch sign sheets in areas recairing a fire watch to assure that the required rounds are

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4.2 Review of Installation, Operability and Maintenance of Fire Protection Systems The inspector reviewed the installation of randomly selected fire protection systems, fire protection system flow diagrams, and made observations of the condition and operability of the fire protection equipment to determine whether: Fire protection equipment such as stand pipes and hose stations are operable and accessible in all areas important to safety; Adequate portable extinguishers are provided at designated places in each fire area; The condition of all fire suppression devices inspected is satisfactory; The system's valves are lined up in the proper position and are protected from tampering; The fire protection equipment is well maintained; and The fire barriers and related components such as fire doors, fire dampers, and penetration seals have been installed and

, maintained properly to prevent fire propagatio A; a result of this review, the inspector noted that the ability of the licensee to effectively use fire fighting equipment within the purple switchgear room is restricted due to the following factors:

(1) The hose station is a dry pipe system that requires manual actuation from the control room to get water to flow through this station. The control room must first ascertain that there is a fire in the room before turning on the water; (2) The hose station is located inside the room thus, subjecting the hose to possible fire damag The foregoing items are unresolved pending an evaluation of the licensee's fire fighting capability associated with this room. (50-412/87-11-02)

The inspector also observed that the Fire Protection system work was incomplete. For instance, some of the fire barrier penetrations had not been sealed and acceptance testing for miscellaneous systems had not been performe This work is to be completed by fuel load. If any systems are not completed by that time, the licensee committed to inform the NRC of their compensatory measure .

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4.3 Review of Fire Fighting Capabilities -

The inspector reviewed the licensee documents listed below, conducted interviews with personnel and inspected fire fighting gear to evaluate the on-site capability of the licensee to fight fires:

The documents reviewed were:

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FSAR Section 9. In Class Fire Brigade Training Lesson Plan LP-SQS-56. The scope of the review was to: verify that all personnel designated to take part in fire emergencies are trained in these actions and in the overall emargency plan; verify that the licensee has established a training program that ensures the capability to fight potential fires; verify that the licensee's training program consists of initial classroom instruction followed by periodic classroom instruc-tion, firefighting practice and fire drills; verify that the licensee had developed fire fighting strategies for fires in all safety-related areas and in areas in which a fire could present a hazard to safety-related equipment; verify that the fire fighters can fight plant fires with the equipment available; and verify that fire watches established for hot work or Technical Specification (TS) surveillances have received training which includes hands-on practic With regard to the above, the inspector made the following observa-tions concerning the adequacy of the fire brigade training, the adequacy and use of the fire fighters protective gear and the ability of licensee personnel to fight plant fires jointly with local fire department Adequacy of Initial Classroom and Hands-On Training for the Fire Brigade The inspector reviewed the fire brigade training to verify that it meets the objectives set forth in the Branch Technical Position (BTP)

9.5.1 which stipulates that the Fire Brigade Training Program shall ensure the capability to fight potential fire The inspection included a review of the lesson plan objectives, interviews with training personnel and a review of the Fire Protection consultant's

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observations that are contained in the Unit I triennial Technical Specification audit report. It was noted that the Unit 2 training program for the fire brigade is patterned after the Unit I training program. The Unit 1 audit indicated that the fire brigade relies on outside assistance from the local fire department; the licensee is addressing the audit findings for unit Based on the licensee's audit findings, the inspector expressed the concern that the Unit 2 brigade may not be adequately trained or have the capability to fight potential fires without outside assistanc The inspector reviewed the training given to the firefighters and, in particular, the initial classroom instructions and hands-on practice on actual fires. It was determined that each member of the licen-see's fire brigade attends annually a one-day training course that includes 4h hours of classroom instruction and 3h hours of practic Each fire brigade member has an opportunity to handle a charged hose line at least once and extinguish a practice fire. This hose handling experience lasts less than 10 minutes. When each fire brigade member completes this one-day course, they are considered to be a qualified fire brigade membe Given the above, the inspector expressed the concern that the training given to the brigade may not be adequate. The licensee stated that the brigade training is adequate. They are confident that with this training the brigade can fight any postulated fires on site. The licensee also stated that they can demonstrate this capability via a dril The adequacy of the licensee's fire brigade training program is an unresolved item pending detailed review of the fire brigade training and witnessing a fire dril (50-412/87-11-03)

Availability of Fire Fighter Gear The inspector noted that the licensee plans to maintain two fire brigade equipment lockers with fire fighter gear. Because of the locker location, the fire fighters may spend excessive time and energy responding to a fire by first going to the equipment locke The licensee stated that they plan to provide the fire brigade with a van type vehicle fully equipped with fire fighter gear to serve as a mobile equipment locker. When a fire alarm is received in the control room, this van will be dispatched to the nearest access point to a fir .4 Review of Equipment Maintenance, Inspection and Tests The inspector reviewed the following documents to determine whether the licensee had developed adequate procedures which establish maintenance, inspection, and testing requirements for the plant fire protection equipment:

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Fire Protection System Monthly Inspection Test, OST 2.3 Fire Protection System Hose Station Test, OST 2.3 Fire Protection System Drain Test, OST 2.3 Fire Protection System Hydrant Test, OST 2.3 Fire Protection System Inspection Test, OST 2.3 Fire Protection System Annual Test OST 2.3 CO2 Fire Protection System Inspection Test, OST 2.3 CO2 Fire Protection System Test, OST 2.33.10

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Fire Protection System Detection Instrumentation Test, OST 2.33.13

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Smoke Detection Instrumentation Test, OST 2.33.16

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Halon System Test, OST 2.33.20 No unacceptable conditions were identifie .5 Periodic Inspection and Quality Assurance (QA) Audits The licensee has a QA program for Fire Protection that is in accord-ance with the guidance contained in Generic Letter 82-21. To verify the adequacy of this program, the inspector reviewed audits performed for Unit 1 since the Unit 1 and Unit 2 Fire Protection Programs are identical and are implemented by the same individual The inspector observed that the licensee uses their insurer to be the outside consultant required by the technical specification for the triennial audit. The inspector, in reviewing the guidance con-tained in Generic Letter 82-21, determined that this is at:eptable provided, that pertinent findings contained in the insurance report are properly addresse The inspector observed tnat several observations made by this consultant were not addressed in the final Unit 1 QA report. For instance, recommendations concerning the performance of fire drills, the installation of detection systems and the need for additional sprinkler systems were not addressed or resolved by the QA departmen It is acceptable for the licensee to use their insurer to be the outside consultant for the triennial technical specification's audits; however, all pertinent suggestions, recommendations and findings contained in the consultant's report must be reviewed, and formally resolve .6 Facility Tour The inspector examined the fire protection water systems. This included fire pumps, fire water piping and distribution systems, post indicator valves, hydrants and the contents of hose house The inspector toured accessible vital and non-vital plant areas and examined fire detection and alarm systers, automatic and manual fixed suppression systems, interior hose stations, fire barrier penetration seals, and fire doors. The inspector observed general plant housekeeping condition and randomly checked tags of portable

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extinguishers for evidence of periodic inspections. No deteri-oration of equipment was noted. The inspection tags attached to extinguishers indicated that monthly inspections were performe The inspector did not-identify any unacceptable conditions other than those identified in other sections of this repor .0 Unresolved Items Unresolved items are matters about which more information is required to ascertain whether they are acceptable items, violations or deviation Unresolved items disclosed during the inspection are discussed fr. Sections 3.1, 4.2, and .0 Exit Interview The inspector met with the licensee representatives (see Section 1.0 for attendees) at the conclusion of the inspection on February 6,1987. 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 inspecto .