IR 05000416/1996004

Insp Rept 50-416/96-04 on 960123-26.No Violations Noted. Major Areas Inspected:Fp Program & NRC Followup Items

ML20149L509
Person / Time
Site:	Grand Gulf
Issue date:	02/22/1996
From:	Vandenburgh C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20149L508	List: IR 05000416/1996004 ML20149L504
References
50-416-96-04, 50-416-96-4, NUDOCS 9602260388
Download: ML20149L509 (10)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Inspection Report: 50-416/96-04 License: NPF-29 Licensee: Entergy Operations. In P.O. Box 756 Port Gibson Mississippi Facility Name: Grand Gulf Nuclear Station

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Inspection At: Port Gibson. Mississippi Inspection Conducted: January 23-26, 1996 Inspector: William J. Wagner, Senior Reactor Inspector. Engineering Branch Division of Reactor Safety -

Approved: . ffby/rhW # Lks

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iino c Sa Insoection Summary Areas Insoected: Routine, announced inspection of the licensee's fire protection program and NRC followup items. Inspection Procedures 64704 and 92904 were use Results:

Enqineerina e The inspector determined that adequate emergency lighting was not provided for all plant areas required for operation of safe shutdown equipment (Section 1.5).

Plant Sucoort

. The inspector determined that the licensee's approved fire protection program was technically adequate and satisfactorily implemented to provide defense-in-depth against plant fires (Section 1). )

Summary of Insoection Findinas:

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Violation 50-416/9405-01 was closed (Section 2).

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A Non-Cited Violation was identified (Section 1.5).

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-2-Attachments:

. Attachment 1 - Persons Contacted and Exit Meeting

. Attachment 2 - Procedures Reviewed l

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-3-E DETAILS 1 FIRE PROTECTION / PREVENTION PROGRAM (64704)

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i 1.1 Grand Gulf Nuclear Station Fire Protection Reouirements

The licensee has incorporated the fire protection program, including Technical Specifications, into Appendix 98 of the Updated Final Safety Analysis Report.

Revision 5. by letter dated December 1. 1990, in accordance with NRC Generic

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Letter 88-12. The NRC issued Amendment 82 to Operating License NPF-29 on i August 23, 1991. Amendment 82 consisted of the applicable changes to the

Technical Specifications and issuance of Operating License Condition 2.c (41),

a- which references the NRC-approved fire protection program and allows certain

! licensee changes to this program.

l 1.2 Review of Fire Protection Procedures I The inspector reviewed the licensee's approved fire protection program as

defined in the Updated Final Safety Analysis Report for the facility. The f inspector specifically reviewed the procedural guidance (Attachment 2) to .

assure that the fire protection program contained, at a minimum, the following .

1 items described belo !

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. 1.2.1 Combustible Material Control / Fire Hazards Reduction i

The inspector verified that the procedures for combustible controls for

, transient fire loads in safety-related and adjacent plant areas addressed

wood, bulk flammable and combustible liquids and gases storage, anti-i contamination clothing and shelving, plastics, and hydrogen lines.

j 1.2.2 Housekeeping I' The inspector verified that the housekeeping procedures addressed the j following items: frequency of licensee-conducted housekeeping inspections.

control of combustible waste products, storage of radioactive materials.

controls of hazardous chemicals, and control of smoking.

i 1.2.3 Ignition Source / Fire Risk Reduction Controls

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, The inspector verified that procedural controls addressed welding cutting and

grinding operations, and that these operations were authorized only by.an  ;

appropriate permit. The inspector also determined that the procedures l l provided controls for leak testing and other open flame operation I

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5 l 1.2.4 Fire Control Capabilities The inspector verified that the fire protection program provided provisions

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for fire fighting training and qualifications, fire emergency plans, and fire personnel designations. The inspector also verified that the fire control

! capabilities provided for the maintenance and surveillance on fire

{ suppression, detection and emergency communications equipment, .3 Fire Protection Oroanization i

i The inspector's review of the fire protection organization determined that the

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Manager. Plant Operations. had overall responsibility for the plant fire '

i protection program. The fire protection coordinator was responsible for  ;

j implementation of the operations department responsibilities for the fire

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protection program. The shift superintendent, who was also the shift fire chief, was responsible for ensuring that each shift was manned with the i

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necessary complement of qualified fire brigade members.

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Fire Briaade Readiness'

i The inspector determined that the plant fire brigade was composed of six shifts (A through F) of dedicated fire brigade personnel from the operations t i staff. Each shift was composed of five fire brigade members. The fire brigade leader re)orted to the shift fire chief (shift superintendent) who was

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not a member of tie brigade.

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The inspector reviewed the physical examination records of the fire brigade !

members and determined that all fire brigade 3ersonnel were scheduled to have

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the required annual physical examinations by rebruary 20, 1996.

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! The inspector reviewed the training records of fire drills performed during 1995 and determined that the required drills were preplanned, critiqued. and

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performed for all six fire brigade shifts including unannounced and backshift i drills. The fire brigade drills were conducted at regular intervals not

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exceeding 3 months for each fire brigade shift during the past 2 years. The inspector verified that at least one unannounced drill was critiqued by -

independent cualified offsite personnel within the past 3 years. The critique was performec during the triennial fire protection audit conducted on January 6 through February 28, 1993, and assessed overall performance such as

response time, use of equipment, and knowledge.

1- The inspector reviewed the classroom training course outlines and verified that the following topics were covered by the initial program and were repeated over a 2-year period:

. Indoctrination of the plant fire fighting plan with specific identification of each individual's responsibilitie * Identification of the type and location of fire hazards and associated j types of fire that could occur in the plan .

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. ^The toxic and corrosive characteristics of expected products of combustio .

. Identification of the location of fire fighting equipment for each fire area and familiarization with the layout of the plant. including access and egress routes to each are . The proper use of available fire fighting equipment and the correct method of fighting each type of fire. The types of fires included fires involving energized electrical equipment, cables in cable trays, hydrogen fires, fires involving flammable and combustible liquids or hazardous process chemicals, fires resulting from modifications ,

(welding), and record file fire The inspector reviewed the training records of one fire brigade leader and two brigade members and verified that each member had the following training:

initial fire brigade training. classroom training every 3 months, participation in at least two drills per year, attended practice fire fighting sessions, and that the fire brigade leader had attended fire brigade leadership trainin .5 Plant Tour The inspector performed a walkdown inspection of the outside fire protection system to evaluate the operability and material conoition of the fire  :'

suppression water sup)1y system. The inspector verified that the system had two separate fire fig 1 ting water supplies as required by Section 9.5.1.2 of the updated final safety analysis report. One electrically-driven and two-

diesel-driven fire pumps, each capable of Jumping 1500 gallons per minute. . ,

take suction from either water storage tan (. The inspector determined that the two 300.000 gallon nominal capacity water storage tanks each contained an adequate volume of fire fighting water to supply at maximum demand for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. During this outside walkdown, the inspector selected five fire main )

supply valves and verified that were aligned and controlled by locks or- )

electrical supervision devices with audible signals to ensure the continuance i of the water supply to all portions of the fire suppression system. The j inspector inspected one fire hose house and determined that the hose house was ,

properly equippe :

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The inspector toured various areas of the diesel generator building, the  ;

i auxiliary building and the control building. The inspector performed this i tour to visually inspect the fire protection equipment and features provided  :

in these areas and to evaluate the adequacy of the licensee's fire prevention  !

program from a performance-based perspectiv The inspector observed the following:

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. The fire sprinkler systems and deluge systems were operable and well ,

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. The fire protection equipment, such as hoses, hose reels, detectors, and

fire extinguishers were in good material conditio . That housekeeping was well maintained.

i The inspector walkdown inspection included an evaluation of the ability of

! plant operators to implement instructions for shutting down the plant from

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outside the control room as required in Off-Normal-Event Procedure 05-1-02-I11. " Shutdown from the Remote Shutdown Panel." Revision 22.

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The purpose was to ensure that the specific operator actions would not be

constrained because of the inadequate emergency lighting or improperly i labelled equipment. The inspector noted the emergency lights in the vicinity

. of Panels 1H22-P299. 1H22-P295, and 1H22-P296 were inadequate for the operator to perform the required safe-shutdown activities. The inspector determined

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that the inadequate emergency lighting was due to improper aiming of the bulbs. The inspector observed a licensee representative re-aiming the bulbs

to provide adequate lighting during the walkdown inspectio '

During this walkdown, for operator actions from the remote shutdown panel, the inspector also noted that Panel 1C71-P002 had no emergency lighting to perform

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the function of opening the circuit breakers as described in Section 3.3 of Procedure 05-1-02-II-1. The inspector determined that the operator actions at Panel 1C71-P002 were not required for safe shutdown and that Section 3.3 was incorporated into Procedure 05-1-02-11-1 as an enhancement. The licensee representative informed the inspector that they would evaluate the necessity to revise Section 3.3 and whether emergency lighting should be required for '

Panel 1C71-P00 The inspector walkdown included inspection of fire' barriers located in two important fire compartment areas considered in the fire probabalistic risk assessment methodology addressed in licensee Engineering Report GGNS-94-005 Revision The two compartments. CC202 and CC215. were located in the Switchgear Room on the 111 foot 0 inch elevation of the control building. The probablistic risk assessment targets of interest in these compartments were cables associated with Division 1 and Division 2 safe-shutdown equipment. The Division 2 cables in CC202, and the Division 1 cables in CC215, were assumed in the probablistic risk assessment to have been wrapped with at least a nominal 1-hour wrap. The inspector observed that the Division 2 cables in CC202 were wrapped with Thermo-Lag, and that the Division 1 cables in CC215 were wrapped with 1-hour rated Kaowool fire barrier wrap. The licensee representative informed the inspector that the action plan for the Grand Gulf ,

Nuclear Station Thermo-Lag resolution includes upgrading the Thermo-Lag to provide a 1-hour rating where required; in the mean time, ap compensatory measure (five watches) were being implemente propriate The ins 3ector determined that this upgrade applies to the Thermo-Lag wrap for the Jivision 2 cables.in Compartment CC20 ;

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L 1.6 Ouality Assurance Audit

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The inspector reviewed Audit Report OPA-09.01-95. " Annual Fire Protection Audit." conducted January 24 through February 24. 1995. The licensee

conducted this audit to assess the implementation and effectiveness of the

fire protection program. The scope of the audit included a review of

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documentation, plant walkdowns and aerformance based observations to assess i and evaluate the effectiveness of tie fire protection program. The audit

. included a fire protection engineer from Houston Lighting and Power Company's South Texas Project as a technical specialist. The audit identified program deficiencies regarding training records. missing surveillance package data

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sheets, fire watch training, and the use of chemical control permits. The

licensee corrected these deficiencies and issued quality deficiency reports for further evaluation. The licensee audit found the fire protection programs l and support programs were properly implemented, with the exceptions of the j above deficiencie FOLLOWUP PLANT SUPPORT (92904)

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(Closed) Violation 416/9405-01: Failure to Uodate Fire Protection Proaram and Documents Backaround

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This violation involved two examples of failure to follow and implement design >

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change process controls for plant modifications and failure to follow and l implement fire protection procedures necessary to maintain the provisions of

the approved fire protection progra In the first example, the inspector identified that operations section reviews i

of 3rocedures, programs or material requirements affected by Design Change

, Pac cages 85-0050 and 88-0050 failed to identify that certain features of the

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fire protection program, operations section.'were affected by the design changes.

The second example identified by the inspector was the failure of the operations section to annually review and update the status of the fire i preplans as required in Procedure 02-S-01-18. " Control of Fire Preplans."

Revision 4. dated November 8. 199 Insoector Followuo

The inspector reviewed the licensee's response to this violation, which was documented in Letter GNR0-94/00049 to the NRC. dated March 28, 199 The licensee stated that it would take the following corrective actions to prevent

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recurrence:

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i l . Fire protection personnel would be added to the review cycle of all j modifications that went to operations for impact review.

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• All fire preplans would be reviewed and appropriate changes mad In addition, the document control organization would issue a notice for the annual revie . The incident described-in this violation would be routed to appropriate-personnel in accordance with the required reading program, The ins)ector reviewed Quality Deficiency Report 050-94, which was initiated on Marc 1 3, 1994, to document, implement, and track the corrective actions addressed in the first two' items above. The quality assurance organization closed this item on July 7,1995, by documenting on the quality deficiency report summary sheet that the following corrective actions were verified to have-been completed: (1) all design change packages were routed to the fire protection coordinator. (2) all design change packages since 1986 and related documents that impacted the fire hazards analysis have been reviewed and the appropriate change made to the fire preplans, and (3) the licensee's Commitment Tracking System A16828 would be used to remind them of the need to perform the annual review of fire preplans. The inspector reviewed these actions taken in Quality Deficiency Report 050-94 and verified that the corrective actions were complete The inspector also reviewed the reading reports that'were given to the training and the operations departments. The subject of these required reading sessions was on the licensee's response to this violation for failure to review and u)date fire protection elements and documents. The inspector verified that tie required reading was provided to appropriate personnel in the training and operations department The inspector determined that the licensee had implemented appropriate corrective actions to assure that the design changa process controls for plant .

modifications includes fire protection program reviews, and that fire preplans i were updated to reflect any design changes affecting the plant fire hazard analysis, The inspector determined that these actions should prevent recurrence of the problems addressed in this violatio I l

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ATTACHMENT 1 1 PERSONS CONTACTED 1.1 Licensee Personnel T. Barfield. Supervisor Electrical System D. Bost. Director, Design Engineering C. Brooks, Senior Licensing Specialist

- Brown. Fire Program Traine W. Cade, Operations Assistant M. Cumbest.-Senior Lead Technical Specialist J. Czaika, Nuclear Specialist L. Daughtery Technical Coordinator ,

W. Deck. Security Supervisor *

M. Dietrich, Manager, Nuclear Training J. Dimmette. Manager. Operations C. Dugger. Manager, Operational Maintenance & Work Control C. Hayes. Director, Quality Programs ,

C. Hollifield Licensing Engineer -

R. Hutchinson Vice President, Nuclear Operations S. Kirby. Fire Protection System Engineer C. McCas, Quality Auditor M. McDoniell. Superintendent. Operations M. Meisner. Director. Nuclear Safety & Regulatory Affairs W. Mosby Technical Specialist Quality Programs ,

J. Owens, Licensing Specialist D. Pace. General Manager Plant Operations S. Saunders, Manager, Electrical / Instrumentation & Controls

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1.2 NRC Personnel L J.- Donohew, Project Manager for Grand Gulf Nuclear Station J. Tedrow. Senior: Resident Inspector The personnel above attended the exit meeting, In addition to the personnel listed above, the inspector contacted other personnel during this inspection perio EXIT MEETING An exit meeting was conducted on January 26, 199 During this meeting, the inspector reviewed the scope and findings of the report. The licensee did not express a position on the inspection findings documented in this report. The licensee did not identify as proprietary any information provided to, or reviewed by. the inspecto .- .

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ATTACHMENT 2

PROCEDURES REVIEWED 01-S-07-9, " Housekeeping " Revision 19 01-S-08-1, " Respiratory Protection Program " Revision 19 01-S-10-01, " Fire Protection Plan," Revision 100 10-S-03-3, " Fire Prevention: Control of Ignition Sources," Revision 8 i

10-S-03-4, " Fire Prevention: Control of Combustible Material " Revision 8. l 10-S-03-7, " Fire Protection Training Program " Revision 5 10-S-03-8, "Firewatch Program " Revision 4 05-1-02-II-1. " Shutdown from the Remote Shutdown Panel," Revision 22 Nuclear Plant Engineering Procedure 317. " Fire Protection Review of-Design / Design Changes," Revision 11 UFSAR Section 7.4.1.5, " Alternate Shutdown System" UFSAR, Section 9.5.1, " Fire Protection System" UFSAR Appendix 9A " Fire Hazards Analysis Report" UFSAR, Appendix 98 " Fire Protection Program" UFSAR, Appendix 9C, " Analysis of Safe Shutdown"

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