IR 05000416/1999006
| ML20207A702 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 05/21/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20207A700 | List: |
| References | |
| 50-416-99-06, 50-416-99-6, NUDOCS 9905270197 | |
| Download: ML20207A702 (11) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.:
50-416 License No.:
NPF-29 Report No.:
50-416/99-06 Licensee:
Entergy Operations, Inc.
Facility:
Grand Gulf Nuclear Station Location:
Waterloo Road Port Gibson, Mississippi Dates:
April 19 to 23,1999 Inspectors:
Rebecca L. Nease, Senior Reactor inspector, Engineering and Maintenance Branch Russell Bywater, Reactor inspector, Engineering and Maintenance Branch Accompanying Egan Wang, Reactor Engineer Personnel:
Approved By:
Dr. Dale A. Powers, Chief Engineering and Maintenance Branch Division of Reactor Safety ATTACHMENT:
Supplemental Information l
9905270197 990521
gDR ADOCK 05000416 PDR
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EXECUTIVE SUMMARY Grand Gulf Nuclear Station NRC Inspection Report No. 50-416/99-06 in this announced, routine inspection, NRC inspectors reviewed the licensee's implementation of the NRC approved fire protection program.
Plant Support Overall, the licensee's fire protection program was properly controlled, implemented,
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and maintained in accordance with their approved fire protection program (Section F1).
The licensee's identification and correcton of the long-standing issue of the flow
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instruments for the diesel-driven fire pumps not providing accurate data was not timely.
The installed flow instruments had been providing inaccurate data since original plant start up, and the licensee had been using an alternative test methodology for obtaining pump flow for surveillance testing. Although several condition reports had been written documenting the failure of the installed flow instruments, only recently had the licensee determined the cause of the failure and planned to effect repairs (Section F2.2).
The training and qualification of fire brigade members and the licensee's performance of
fire drills met the requirements of the fire protection program. The response of the fire brigade to the observed fire drill was timely, good command and control were exercised by the brigade leader, and fire fighting activities were appropriate to the circumstances (Section F5).
An unresolved item was identified to further review the licensee's position that damage
to safe shutdown equipment as a result of fire-induced circuit failures is not required to be considered. This position is contrary to the NRC's interpretation of Generic Letter 86-10 (Section F8.1).
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-3-Report Details Summarv of Plant Status The plant operated at full powar during the inspection.
IV. PLANT SUPPORT F1 Control of Fire Protection Activities (64704)
The inspectors reviewed the licensee's fire protection program to verify that the licensee had properly implemented and maintained the fire protection program as required by the operating license. The inspectors reviewed fire protection procedures, administrative controls, fire reports, fire brigade qualifications, fire brigade staffing, and fire watch staffing to determine if they were in accordance with approved fire protection program.
The inspectors also conducted tours of the facility and observed a fire drill to verify licensee implementation of the fire protection program.
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I With a few minor exceptions discussed in other sections of this report, fire response equipment was well maintained, plant housekeeping for control of transient i
combustibles was satisfactory, and procedures were adequate for implementing the fire
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protection program. Fire brigade personnel were qualified, and performed acceptably during the observed fire drill. The inspectors concluded that, overall, the licensee's fire protection program was properly controlled, implemented, and maintained in accordance with the approved fire protection program.
F2 Status of Fire Protection Facilities and Equipment (64704)
F2.1 Fire Protection System Walkdown a.
Inspection Scope The inspectors performed a walkdown of accessible areas of the facility containing safe shutdown equipment and fire protection equipment, including fire suppression and i
detection equipment, fire rated assemblies, and fire brigade and operator emergency response equipment. In addition, the inspectors reviewed maintenance and surveillance
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records of selected fire protection equipment to verify that the equipment was maintained in an operable condition.
b.
Observations and Findinas The inspectors observed that, for the most part, fire protection equipment was in good working order. During the walkdown, inspectors observed a sealleak on fire protection
-4-Jockey Pump P54, which had already been identified and a work order written for its repair. In addition, the inspectors noted a few misplaced housekeeping items, such as a mop handle, a stack of absorbent towels, and a small plastic bag of trash, all of which licensee personnel removed immediately. Fire brigade equipment was well maintained and ready for use.
c.
Conclusions Fire protection equipment required for program implementation was generally well maintained and available for use. Plant housekeeping for control of transient combustibles was satisfactory.
F2.2 Diesel-Driven Fire Pumo Surveillance Testina a.
Scope The inspectors reviewed the records of the last completed diesel-driven fire pump surveillance tests. In addition, the inspectors reviewed Surveillance Procedure 06-OP-SP64-A-0005, " Diesel-Driven Fire Pump A Functional Test,"
Revision 101, and Surveillance Procedure 06-OP-SP64-A-0006, " Diesel-Driven Fire Pump B Functional Test," Revision 101, which were written to implement the technical requirements manual surveillance requirement. The inspectors also reviewed Equiprnent Performance instruction 04-S-03-P64-17, " Fire Flow and Pressure Test,"
Revision 0, which described an attemate means of testing the diesel-driven fire pumps.
b.
Observations and Findinas
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Technical Requirements Manual Surveillance Requirement 6.2.2.11.2 specified that.
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every 18 months each fire pump be verified capable of developing a flow rate of 1500 gpm at a system head of 275 feet (119.2 psig). These requirements were implemented by Procedures 06-OP-SP64-A-0005 and 06-OP-SP64-A-0005.
On October 1,1998, during the performance of Procedure 06-OP-SP64-A-0006, the Fire Pump B test resulted in a measured flow rate of 1500 gpm at 118 psig. On January 27,1999, using Procedure 06-OP-SP64-A-0005, the Fire Pump A test resulted in a measured flow rate of 1135 gpm at 124.8 psig, which did not meet the acceptance cnteria in Technical Requirements Manual Surveillance Requirement 6.2.2.11.2 for flow and pressure. After each of the tests, licensee personnel reperformed the surveillance tests using an alternative test method described in Equipment Performance Instruction 04-S-03-P64-17. This attemative test specified the use of a pitot probe in the test nozzle flow streams to determine flow. The results from the attemative tests met Technical Requirements Manual Surveillance Requirement 6.2.2.11.2 acceptance criteria for operability.
The licensee's representatives informed the inspectors that the fire pumps had never passed Technical Requirements Manual Surveillance Requirement 6.2.2.11.2 using Procedures 06-OP-SP64-A-0005 and 06-OP-SP64-A-0006, and that this had been a
-5-long-standing issue. The licensee's representatives further stated that the altemative test method described in Equipment Performance Instruction 04-S-03-P64-17 had been used in every case to demonstrate that the pumps were operable. Licensee representatives provided several condition reports that documented this issue and its resolution, in response to inspectors' questions regarding the attemative test methodology and the reasons for the discrepancies in the test results.
During resolution of this issue, licensee personnel identified two problems that affected the flow measurement. The first problem involved the use of a flow orifice installed in the test line to measure the test header flow rate. Licensee personnel determined that, due to the test header pipe configuration, air was trapped at the orifice plate during testing, which could not be vented, affecting the differential pressure across the plate and the resulting flow measurement. To correct this condition, licensee personnel initiated Engineering Request 97-0302 to install a new orifice plate that contained drain and vent holes to improve the reliability of the flow measurement. The inspectors noted that the licensee's engineering evaluation documented the appropriate drain and vent hole sizes, and determined that this modification was consistent with standard industry practice for flow measurement. The modification was scheduled for implementation in May 1999.
The second problem that the licensee's engineers identified was that the test nozzles used in the attemative test each had a 5-inch long, short, straight pipe installed on the nozzle. The short pipes had apparently been installed on the nozzles during plant construction. The addition of the short pipe on the nozzles prevented the licensee from placing the pitot probe at the vena contracta of the nozzle. The licensee's engineering calculations were based on data taken at the vena contracta; therefore, the resulting flow rates were incorrect. On February 19,1999, licensee personnel removed the short pipes from the test nozzles and reperformed the attemative test, Equipment Performance Instruction 04-S-03-P64-17, for diesel-driven Fire Pump B. The inspectors noted that test results indicated a flow rate that was approximately 10 percent higher than previously reported flow rates. Although previous tests using the pitot probe resulted in inaccurately measured flow rates, the results were conservative, therefore, the licensee did not identify any past operability concerns.
Based on review of the test results, condition reports, and discussions with the fire protection system engineers, the inspectors considered the licensee's efforts satisfactory to provide assurance that the fire pumps were capable of meeting the acceptance criteria in the technical requirements manual. However, the inspectors noted that this situation had existed since plant startup, and the licensee's previous attempts to identify the root cause(s) and correct the problems had been unsuccessful.
The inspectors reviewed the licensee's administrative process for satisfying part of the diesel-driven fire pump operability requirements through the use of an alternative test.
The process, which was informally referred to as the "Take Credit Program," was proceduralized in Administrative Procedure 01-S-06-12, "GGNS Surveillance Program,"
Revision 104. The engineering review supervisor and the responsible section superintendent were required to approve the use of such alternative tests for satisfying
-6-the technical requirement manual requirements using guidelines identified in the procedure, and must document this approval on a surveillance credit verification form.
The altemative tests for the fire pump surveillance testing described above were performed in accordance with Equipment Performance Instruction 04-S-03-P64-17, and were documented on the surveillance credit verification form, as required by Administrative Procedure 01-S-06-12. The inspectors did not identify any issues associated with the licensee's use of Equipment Performance Instruction 04-S-03-P64-17 for obtaining data necessary to verify the operability of the diesel-driven fire pumps. However, the inspectors did not review the programmatic aspects of the licensee's use of the take credit program, as described in Administrative Procedure 01-S-06-12.
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Conclusions The licensee's identification and correction of the long-standing issue of the flow instruments for the diesel-driven fire pumps not providing accurate data was not timely.
The installed flow instruments had been providing inaccurate data since original plant startup, and the licensee had been using an attemative test methodology for obtaining pump flow for surveillance testing. Although several condition reports had been written documenting the failure of the installed flow instruments, only recently had the licensee determined the cause of the failure and planned to effect repairs.
F3 Fire Protection Procedures and Documentation (64704)
The inspectors reviewed the licensee's approved fire protection program as documented in the Final Safety Analysis Report for the facility, to verify that the procedures adequately implemented the licensee's approved program. The inspectors found that the licensee procedures adequately implemented the approved fire protection program.
FS Fire Protection Staff Training and Qualification (64704)
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Inspection Scope The inspectors reviewed the readiness of the onsite fire brigade personnel to fight fires, inuuding fire brigade composition, qualifications (including physical), and training records. The inspectors also interviewed licensee staff responsible for fire protection training, observed the performance of the fire brigade during a fire drill, and attended j
the fire dnll critique.
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Observations and Findinas The inspectors did not find any discrepancies with the training and qualification requirements for fire brigade members or their physical examination requirements. Fire protection program training requirements were implemented by Procedure 10-S-03-7,
" Fire Protection Training Program," Revision 7. The inspectors reviewed the licensee's process for selecting fire brigade members for each shift. A control room shift
d-7-superintendent demonstrated to the inspectors how the training qualification of fire brigade members was verified by obtaining a complete listing (from the plant computer database) of qualified brigade members. From this listing, the inspectors verified that the training requirements for the fire brigade members selected for brigade staffing were met. The licensee's representatives stated that, in response to findings from quality assurance audits, training qualification of fire brigade members were not always revised in a timely manner. They were developing a new computer-based method for updating and controlling fire brigade training records.
Prior to the fire drill, inspectors noted that the fire drill controrar provided observers and monitors with fire brigade drill scenario and critique forms. The inspectors noted that the document did not include a detailed written description of the scenario, expected fire brigade actions, or acceptable performance criteda specific to the scenario. In addition, the drill controller did not assign the monitors to specific areas for observation, or provide them any guidance.
In observing the drill, inspectors noted that control room announcements of the fire drill were accomplished as required. The fire brigade reported to the site of the fire within an acceptable time period, with fire fighting equipment suitable for the type of simulated fire. Communication with the control room was appropriate for the circumstances. The inspectors observed that the fire brigade leader demonstrated good command and control during the drill, insisting on repeat-back communication with other fire brigade members. During the drill, the fire brigade provided acceptable responses to questions from the drill controller conceming specific fire fighting actions they were taking. The inspectors found that the fire scenario was sufficiently complex to demonstrate the required skills of the fire brigade. During the subsequent critique, inspectors observed j
open, critical discussion of the fire brigade's performance.
The inspectors noted that the fire brigade members did not wear the self-contained
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breathing apparatus face pieces during the drill. The inspectors questioned whether the licensee was meeting the fire protection program requirements for the fire brigade to demonstrate the use of self-contained breathing apparatus. Licensee representatives stated that this requirement was met during the annual offsite training session through the use of emergency breathing apparatus under live fire fighting conditions. Furthermore, the wearing of self-contained breathing apparatus during the numerous fire drills required by their fire protection program created the burden of cleaning the self-contained breathing apparatus masks and recharging the breathing air tanks. This resulted in the unavailability of this equipment for an actual fire emergency
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and created the risk of inadvertent contact and operation of sensitive plant equipment that could result in a plant transient. The inspectors agreed that the use of self-contained breathing apparatus during the annual offsite training met the minimum requirements of the fire protection program.
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Conclusions The training and qualification of fire brigade members and the licensee's performance of fire drills met the requirements of the fire protection program. The respense of the
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8-fire brigade to the observed fire drill was timely, good command and control was exercised by the brigade leader, and fire fighting activities were appropriate to the circumstances.
F7 Quality Assurance in Fire Protection Activities (64704)
The inspectors reviewed the 1996,1997, and 1998 fire protection audits. In addition, the licensee's representatives discussed, with the inspectors, preliminary results from their draft triennial fire protection audit performed in February 1999.
The 1996 audit was a biennial / triennial audit, the 1997 audit was an annual audit, and the 1998 audit was a biennial audit. The inspectors found that the audit teams were appropriately staffed and met the requirements of the licensee's fire protection program. The inspectors noted that, although not required by their fire protection program, the licensee did not perform any discretionary quality assurance audits or surveillances of fire protection activities. The inspectors concluded that the licensee's quality assurance audit activities met the minimum requirements of the fire protection j
program.
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F8 Miscellaneous Fire Protection issues (64704)
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F8.1 Consideration of the Effects of Fire-induced Circuit Failures
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Inspection Scope The inspectors interviewed personnel and reviewed documentation regarding the licensee's evaluation of NRC Information Notice 92-18, " Potential for Loss of Remote Shutdown Capability During Control Room Fire," and the potential for fire-induced circuit failures to prevent the operation or cause maloperation of equipment necessary for post-fire safe shutdown.
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Observations and Findinas Condition Report CR-GGN-1999-0236 documented the licensee's position that, in evaluating the effect of a control room fire scenario, the mispositioning of any single valve or valves due to one credible spurious circuit actuation was required for analysis.
The licensee did not consider simultaneous multiple component repositioning (such as valves opening, valves closing, pumps starting, and pumps stopping) as credible unless the single spurious actuation could cause this to occur. Additionally, licensee personnel documented that consideration of mechanistic damage to motor-operated valves, as described in Information Notice 92-18, was outside the design and licensing bases of the facility. Licensee personnel based this conclusion on its interpretation of NRC Generic Letter 86-10, " Implementation of Fire Protection Requirements," that an acceptable post-fire safe shutdown analysis does not require the use of mechanistic damage assessments.
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~ The inspectors informed the licensee's representatives that their position on this issue was contrary to the NRC's position articulated in a letter dated March 11,1997, from Mr. Samuel Collins, Director, Office of Nuclear Reactor Regulation, to Mr. Ralph Beedle, Senior Vice President and Chief Nuclear Officer, Nuclear Energy Institute. The enclosure to Mr. Collins' letter provided an assessment of the Nuclear Energy Institute's concems regarding information Notice 92-18, and concluded that the safety issue addressed in Information Notice 92-18 was within the scope of the existing fire
. protection regulation and did not constitute a backfit.
In Condition Report CR-GGN-1999-0236, the licensee performed an evaluation to determine the incidence frequency expected for an event that would result in sufficient damage to create an impairment to safe shutdown consistent with that described in Information Notice 92-18. The results of this evaluation were that the probability of such an event sequence was approximately 9.26 E-7 per reactor year. This value was considered by the licensee to be a low probability occurrence.
The inspectors noted that several design features and administrative controls provided defense-in-depth for the prevention, limitation, and mitigation of a control room fire.
These included the control of combustibles; design of the control room complex with respect to panel arrangement, separate cable spreading rooms, cable routing, fire breaks, fire detection and suppression in cable raceways, and fire detection in panels; and the continuous presence of operations personnel and availability of manual fire suppression equipment. Based on these design features and administrative controls,
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Conclusions An unresolved item was identified to further review the licensee's position that damage to safe shutdown equipment as a result of fire-induced circuit failures is not required to be considered.-
V. Manaaement Meetinos X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on April 22,1999. The licensee representatives acknowledged the findings presented.
The inspectors asked the representatives of the licensee's management whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie.
ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee C. Abbott, Supervisor, Quality Programs T. Samett, Acting Manger, Electrical / Instrumentation and Control, Design Engineering H. Bishop, Technical Soecialist, Nuclear Safety and Regulatory Affairs C. Brooks, Senior Licensing Specialist, Nuclear Safety and Regulatory Affairs W. Brown, Fire Trainer, Engineering Programs M. Cumbest, Fire Protection Engineer, Engineering Programs R. Daley, Senior Engineer, Design Engineering L. Daughtery, Technical Coordinator, Nuclear Safety and Regulatory Affairs B. Hicks, Fie Protection Coordinator, Engineering Programs T. Howse, System Engineer D. Janecek, Director, Training C. Lambert, Director, Design Engineering M. Renfroe, Manager, Engineering Programs
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J. Roberts, Director, Quality Programs R. Sorrels, System Engineer W. White, Supervisor, Engineering Programs, Design Engineering
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NRC j
J. Dixon-Herrity, Senior Resident inspector INSPECTION PROCEDURES USED l
64704 Fire Protection Program ITEMS OPENED, CLOSED, AND DISCUSSED i
Opened 50-416/99006-01 URI Consideration of the effects of fire-induced circuit failures on equipment required for safe shutdown
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-2-LIST OF DOCUMENTS REVIEWED Tvoe/ Number Title Revision /Date
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Condition Report Information Notice 92-18 Evaluation February 23,1999 CR-GGN-1999-0236 Condition Report Evaluation of Potential Fire-Induced July 10,1997 CR-GGN-1997-0779 Spurious SRV Openings Condition Report All Three Fire Pumps Routinely Fail the April 15,1997 CR-GGN-1997-0391 Pressure / Flow Requirements Condition Report Annual Flow Test of Diesel Driven Fire February 2,1999 CR-GGN-1999-0196 Pump C003B Conducted on 10/2/98 was incorrectly Evaluated Condition Report Equipment Performance Instruction for February 23,1999 CR GGN-1999-0234 Fire Pump Testing Contained Error and Test Nozzles Found to Have Extra Short Pipe Installed Document Review Loss of Remote Shutdown Capability April 2,1992 Summary Sheet During Control Room Fire IEN 92-018 Memorandum from Circuit Level Failure Modes and Effects February 21,1992 M. Meisner to Analyses for Fire Hazards C. Hutchinson and D. Pace Engineering Assistance Hot Shorts issue - Hi/Lo interface November 11,1998 Request 98-039 Administrative Procedure GGNS Surveillance Program Revision 104 01-S-06-12 Off-Normal Event Shutdown from the Remote Shutdown Revision 24 Procedure 05-1-02-11-1 Panel Procedure Diesel Driven Fire Pump A Functional Revision 101 06-OP SP64 A-0005 Test Procedure Diesel Driven Fire Pump B Functional Revision 101 06-OP-SP64 A-0006 Test Equipment Performance.
Fire Flow and Pressure Test Revision 0 instruction 04-S-03-P64-17
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Engineering Request Add Drain and Vent Holes to Fire Revision 0 97-0302 Protection System (P64) Test Manifold in Flow Orifice, SP64N010
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