IR 05000423/1998081

Insp Rept 50-423/98-81 on 980302-31 & 0412.Violations Noted. Major Areas Inspected:Plant Support

ML20248A791
Person / Time
Site:	Millstone
Issue date:	05/22/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20248A743	List: IR 05000423/1998081 ML20248A738 ML20248A778
References
50-423-98-81, NUDOCS 9806010042
Download: ML20248A791 (26)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No: 50-423 )

License No: NPF-49 i

' Report No: 50-423/98-81 Licensee: Northeast Nuclear Energy Company Facility: Millstone Nuclear Power Station, Unit 3 Location: Waterford, CT Dates: March 2 - 31,1998 April 12,1998 Inspectors: Roy L. Fuhrmeister, Sr. Reactor Engineer, Region 1 (RI),

Electrical Engineering Branch (EEB), Division of Reactor-Safety (DRS)

Phillip M. Qualls, Fire Protection Engineer, Office of Nuclear Reactor Regulation, Plant Systems Branch, Fire Protection Section Keith A. Young, Reactor Engineer, Rl, DRS, EEB Approved by: William H. Ruland, Chief i Electrical Engineering Branch Division of Reactor Safety i

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TABLE OF CONTENTS PAGE EXEC UTIVE SU M MARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii IV. Plant Support .................................................1 F2 Status of Fire Protection Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . 1 F2.1 Modifications to Motor Operated Valves in Response to IN 92-18 . . . . . . 1 F2.2 Structural Steel Fireproofing ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 F2.3 Charging Pump / Reactor Plant Component Cooling Water Pump Area -

' Ventilation System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 F2.4 Fire Barrier Penetration Seals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 F3 Fire Protection Procedures and' Documentation . . . . . . . . . . . . . . . . . . , , . . . . 4 F3.1 Fire Protection Program Manual . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 F4 Fire Protection Staff Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . 5 F4.1 Quality of Fire Drills and Drill Critiques . . . . . . . . . . . . . . . . . . . . . . . . . 5 F7 Quality Assurance in Fire Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 F7.1 Fire Protection Program Audits ..............................5 F8 Miscellaneous Fire Protection issues ...............................6 F8.1 Multiple High Impedance Faults (MHIFs) during a Postulated Control Room Fire .................................................6 F8.2 (Closed) LER 50-423/97-051: Design Deficiency for 4.16 Kilovolt Feeder Fault Cla aring Times . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 F8.3 (Closed) LER 50-423/97 059: Spurious Operation of Auxiliary Feedwater Pump Turbine Exhaust Condensate Drain Line Isolation Valve During Certain Fire Scenarios May impact Safe' Shutdown Capability .............. 9

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F8.4 (Closed) Unresolved item 50-423/97-84-01, inadequate implementation of l Fire Protection Program Controls" . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 F8.5 (Closed) Significant issues List Item 42 . . . . . . . . . . . . . . . . . . . . . . . 14 Y. M ANAG EMENT MEETINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

.X1 ~ Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 1.

l PARTI AL LIST OF PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

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l L INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 ITEMS OPENED, CLOSED, AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 LIST OF ABBREVIATIONS USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 ii

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EXECUTIVE SUMMARY Millstone Nuclear Power Station inspection 50-423/98-81 This inspection included aspects of licensee plant support. The inspection consisted of an assessment of aspects of the fire protection program to support restart of Millstone Unit . The report covers a 4-week period of announced inspection by regional and NRR based

. inspector Plant Support Fire Protection

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• - Licensee modifications were adequate to protect the motor-operated valves that the l licenaee had determined needed protection from fire-induced spurious action due to ll bypassing the torque limit switches. (Section F2.1)

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-* The licensee. failed to provide an adequate fire barrier between the cable spreading room and control room due to inadequately protected structural steel. This is a violation of License Condition 2.H. (VIO 50-423/98-81-01) (Section F2.2) ;

• Licensee tests of emergency ventilation fans demonstrated that the fans provided i adequate cooling to the charging pump / reactor component cooling water pump area to achieve the fire protection program required safe shutdown. (Section F2.3)

• _ 'The heensee maintained the. effectiveness of the observed fire barrier penetration seals. (Section F2.4)

-- * The license 's Fire Protection Program Manual provided apprc.priate guidance for !

program implementation and responsibilities. (Section F3.1) l

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-* The licensee had made significant improvement in fire brigade drills. (Section F4.1)

• Audits of the fire protection program have been effective in identifying deficiencies for correction. (Section F7.1)

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• - . The licensee did not initially take appropriate corrective actions to resolve multiple ;

high impedance fault problems on the 120 VAC vital power panels. This is a l violation of License Condition 2.H. (VIO 50-423/98-81-02) (Section F8.1)

• - .The licensee identified a design deficiency for 4.16 kilovolt feeder fault' clearing l times (LER -50-423/97-051). The licensee reported and corrected this deficiency in I

- an acceptable manner. (NCV 50-423/98-81-04) (Section F8.2) 4 l

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• .The licensee identified the spurious operation of auxiliary feedwater pump turbine exhaust condensate drain line isolation valve during certain fire scenarios which may impact safe shutdown capability (LER 50-423/97-059). The licensee reported and corrected this deficiency in an acceptable manner. (NCV 50-423/98-81-05)

(Section F8.3)

• . The licensee took the following actions to disposition inadequate implementation of

. fire protection program controls; (1) The licenses took appropriate actions to verify operability of post-fire safe shutdown equipment. (2) Appropriate measures have been taken to ensure effective evaluations of temporary modification impact on the firo protection program. (3) The licensee had adequately implemented the licensing commitment to proceduralize that manual actions identified in the fire hazards analysis as being necessary to achieve safe shutdown after a fire. (4) Corrective actions taken by the licensee to disposition fire protection issues documented in j condition report M3-97-3373 were acceptable. These issues violated BTP 9.5-1, l Section 4(e), Section 6, the license condition, and Section 4(h). (NCV 50-423/98-

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81-03) (Section F8.4)

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Reoort Details IV. Plant Suncort Background The purpose of this inspection was to assess the readiness of the Millstone Nuclear Power Station Fire Protection Program to support the startup and operation of Unit 3. The inspection reviewed actions taken by Northeast Nuclear Energy l Company (NNECu) to resolve issues identified in NRC Integrated Inspection Report 96-08 and covered by Significant issues List (SIL) ltem 42, and issues identified in NRC Combined inspection Report 50-336&423/97-84 In addition, the inspecticn covered NNECo actions taken in response to NRC Information Notice 92-18, Potential for Loss of Remote Shutdown Capability During a Control Room Fire," and program deficiencies identified in recent Licensee Event Reports (LERs)

and Event Notifications (ens).

i F2 Status of Fire Protection Facilities and Eouiprnent  ;

F Modifications to Motor Operated Valves in Resoonse to IN 92-18 Inspection Scope The inspectors reviewed the hcensee actions taken in response to information Notice (lN) 92-18, Potential for Loss of Remote Shutdown Capability During a Control Room Fire. The inspectors reviewed licensee Design Change Requests (DCRs) M3-97-038 and M3-97-047 to determine the adequacy of these plant modifications. DCRs M3-97-038 and M3-97-047 documented the implementation of the plant modifications to comply with the approved fire protection program using the information given in IN 92-1 Observations and Findinos The inspectors noted that the licensee modified 38 valves to protect the valves from fire induced hot shorts causing a valve to operate without the torque and limit switch protecting the valv The inspectors noted that the licensee modifications were adequate to ensure that torque and limit switch protection would not be bypassed for a fire-induced spurious )

actuatio I Conclusions The inspectors concluded that licensee modifications were adequate to protect the motor-operated valves that the licensee had determined needed protection from fire-induced spurious actuation due to bypassing the torque and limit switche l l

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F2.2 Structural Steel Fireoroofina a .' Insoection Scoos

'To evaluate conditions observed in the plant during a walkdown, the inspectors; reviewed the protection of structural steel members supporting required fire barriers from an exposure fir . Observations and Findinas During the inspection, the inspectors observed several structural steel members,.

supporting required fire barriers, that did not have intact fire protective coating The inspectors noted many modifications apparently requiring coating removal and

steel unistrut supports' welded onto the steel support column.' *.pparently, after the unistrut was welded to the steel on the beam, the fireproof coating had not been -

replaced to cover the unistrut. This practice appeared to the inspectors to allow the steel support to be unprotected from a postulated exposure fire. The inspectors noted this in the Instrument Rack Room and the Cable Spreading Room. The inspectors noted that column A4-54 had 6 unprotected single horizontal unistrut attachments, column D2-54 had 11 unprotected single horizontal unistrut attachments and 2 double-wide unprotected horizontal unistrut attachments, column D2-53 had 8 unprotected single horizontal unistrut attachments and 2 double-wide unprotected horizontal unistrut attachments, and column A4-52 had 12 unprotected single horizontal unistrut attachments and 6 double-wide unprotected horizontal unistrut attachments. All the noted attachments were made to the flange of the column and uncoated, essentially leaving the column flange unprotected from the exposure fire. These columns are in the cable spreading room and are structurally required to be protected from the effects of an exposure fir The inspectors noted that column A4-52 was located in the area of the cable spreading room that appeared to have the greatest concentration of in-situ combustible material The inspectors reviewed licensee specification no. SP-CE-248, Specification for fireproof coatings at Millstone Unit No. 3, Revision 1, dated September 24,199 This specification documents the steel support members that are required to be protected to meet the fire barrier criteria in the approved fire protection plan and provides installation instructions for the fire proof coating. . The inspectors verified . I that columns A4-54, D2-54, D2-53, and A4-52 are required to be protected by the i licensee's specificatio The specification required that "in areas where clips, hangers, supports, and sleeves -

are in place prior to fireproofing, they shall be incorporated into the fireproofing where they are adjacent to areas designated on the fireproof coating schedule."

The specification then addresses the distance from the flange that steel should be protected when attached to the column and extending away from the beam. The specification then stated that fireproofing of single or double wide unistrut was not required in the control building. The licensee did not provide a basis for concluding that unistrut welded across a steel column flange, effectively leaving the flange l exposed to a postulated fire at that point, was not in the specification to protect the l column from an exposure fir )

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l The Millstone Unit 3 operating license requires that the licensee implement the  ;

L approved fire protection program. The approved fire protection program, as i I

documented in the Fire Protection Evaluation Report (FPER) Section 5, Fire Hazards l Analysis (FHA), shows the cable spreading room ceiling to be a 3-hour rated fire ,

l l barrier. The failure to protect the fire barrier support steel from the effects of an i exposure fire in the cable spreading room is a violation of the Millstone 3 fire protection requirements. (VIO 50-423/98-81-01)

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'The inspectors concluded that the licensee failed to provide an adequate fire barrier between the cable spreading room and the control room due to inadequately l protected structural stee l l

F2.3 Charaina Pumo/ Reactor Plant Comoonent Coolina Water Pumo Area Ventilation l System

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Backaround I During NRC combined inspection 97-84, a review of program audits determined that I some post fire safe shutdown equipment had apparently never been tested. One  !

part of this issue concerned the lack of a test of the required area emergency l ventilation cooling for the charging pump and the reactor plant component cooling water pump (CH/RPCCW) area to maintain pump operation in the event that a fire causes a loss of normal ventilation. The licensee had constructed a door with two fans installed to place in the frame of one of the doors to provide ventilation to the area in an emergency. This arrangement had never been tested installed in the room door to ensure adequate ventilation flow existe Insoection Scope The inspectors reviewed the results of a test conducted February.3,1998,to determine the flow rate the emergency ventilation fans produced, and Technical Evaluation M3-EV-98-OO3Owhich evaluated the acceptability of the fan Observations and Findinas The inspectors found that on February 3,1998, the licensee installed and tested the 2 fans. The licensee determined that actual ventilation flow was 9,656 standard i cubic feet per minute (sefm). The required ventilation was stated as 10,600 scf The licensee concluded that the actual test was acceptable because the results j were within the plus or minus 10% specified in UFSAR Section 9.4 and by typical  !

industry standards, such as ANSI /ASME-N510. In addition, the inspector noted that the 10,630 scfm was based on both A and B train pumps operating. Since the B train is not protected from the effects of a control room fire, they are not required for safe shutdown. The actual heat loading in the room could be about 50% of that used in the licensee's calculatio _ - _ _ - - _ _ _ _ _ _ - - _ _ _ _ - _ - _ _ - _ _ _ _ _ _ _ _ .- -_-__ _ ____ _____-_ ___ . - - _ - _ _ -_ _ _ _ _ _ .

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. Conclusions The inspectors concluded that'the licansee's test demonstrated that the fans provide adequate cooling to the area to achieve the fire protection program required safe shutdown.

l F2.4 Fire Barrier Penetration Seals l Insoection Scope The inspectors visually inspected numerous fire barrier penetration seats during plant tours. In addition, the inspectors reviewed the design of one selected fire seal to verify that the configuration was supported by fire test dat Observations and Findinas -

During plant tours the inspectors noted no missing seals or seals with more than superficial damage. Observed fire barrier per3etrations seals were well maintaine The inspectors reviewed the design drawings for seal EWG-08 of drawing 25212-24277 sheet CWOO5D. The drawing accurately reflected penetrating items through the sealin the unit. The drawings also adequately reflected that this fire barrier seal design had passed an actual fire tes Conclusions

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- The inspectors concluded that the licensee had maintained the effectiveness of the observed fire barrier penetration seal {

F3 Fire Protectim Procedures and Documentation F Fire Protection Proaram Manual -i Inspection Scooe The inspectors reviewed Revision 1 to the Fire Protection Program Manual to evaluate programmatic controls and assignment of program responsibilitie Observations and Findinas

. Revision 1 to the Fire Protection Manual was issued December 12,1997, with an effective date of December 30,199 The inspectors found the contents of the manualincluded program description, assignment of responsibilities, description of interfaces with other programs, and details of program elements. The inspectors also found that programmatic controls and assignment of responsibilities reflects the current operating and support organizations at the statio _ - _ _ - - _ _ _ _ _ _ _ _ - _ - _ _ _ - - _ - _ - _ _ _ - - -_ .

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5 Conclusions Based on the description of program elements and assignment c,f prograrn responsibilities in the fire protection program manual revision, the inspectors

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concluded the manual provides appropriate guidance for program implementation I and responsibilitie l F4 Fire Protection Staff Knowledge and Performance

'F4.1 . Quality of Fire Drills and Drill Critiaues Inspection Scope This issue, part of SIL 42, concerned the quality of fire drill critique to be marginal and that poor support was provided by security and chemistry during the drill.; The .

j inspectors reviewed 10 selected fire drill critiques conducted subsequent to the  ;

50-423/96-08 inspectio Observations and Findinas LThe inspectors noted that drill critiques appeared to be detailed and self-critica The critiques also involved all parties involved in the drill The inspectors noted that chemistry and security participation in the drills were satisfactory. Licensee personnel informed the inspector, that in drills prior to the 1996 inspection, the participation of security and chemistry was simulate Licensee personnel also stated that, subsequent to the inspection, the participation was active and not simulated. The inspectors review of the completed drill reports

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supported that statement, Conclusions i

The inspectors concluded that the licensee had made significant improvement in

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F Fire Protection Proaram Audits 1 i Scone of Inspection i

The inspectors reviewed audit report MP-97-A09-01," Fire r$rotection Program,"

which documented the results of the audit which was in progress at the time of the 50-423/97-84 inspection.

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6~ Observations and Findinas-The audit was conducted September 8 - 26,1997, by the Audits and Evaluations -

(A&E) group. They found that while improvements were being made,- additional-progress was still needed before the fire protection program could be considered fully effectiv .The inspectors reviewed Audit Report MP-97-A09-1 and found that it was' effective in identifying deficiencies for correction by the licensee. The inspectors also found

that the licensee had taken acceptable corrective actions from previous audit an self-assessment finding Conclusions The inspectors concluded that the audits of the Fire Protection Program have been .

l . effective in identifying deficiencies for correction. The response to audit findings i discussed separately in Section F8.4.4 of this repor F8 Miscellaneous Fire Protection issues

F Multiole Hiah Imoedance Faults (MHIFs) durina a Postulated Control Room Fire Insoection Scope

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The inspectors reviewed the licensee's corrective actions taken for the resolution of the deficiency identified in their fire protection program and documented in event notification number (EN) 33484. As documented in the event notification, the licensee determined that during a postulated control room fire, instrumentation

required to achieve and maintain the plant in a stable hot shutdown condition may not have been available at the alternate shutdown statio This issue was identified by NNECo as a result of field verification of a procedure revision being conducted to resolve an audit finding discussed in Section F3.1 of NRC Combined Inspection Report 50-336&423/97-84, in which implementation of a licensing commitment, regarding procedure content, was found to have been inadequate. Observations and Findinas The inspectors reviewed the resolution of the documented fire protection issue described in event notification number 33484, January 2,1998. MHIFs could cause the 150 ampere fuse supplying 120 VAC power to distribution panels 3VBA*PNL-VB1 and -VB3 (east switchgear room) and -VB2 and -VB4 (west switchgear room)

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to open. This would cause loss of electric power to the nuclear instrumentation at the alternate shutdown station. If the 150 ampere fuse were to open, a fuse

- replacement would be required to restore electric power to the panels. A fuse replacement would be considered a repair and is not allowed to reach and maintain hot shutdown conditions. On January 31,1998, the licensee retracted this event notification based on their conclusion that MHIFs would not cause the 150 ampere

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The inspectors reviewed several documents / drawings associated with the resolution of this issue to evaluate whether they provided sufficient corrective actions, analysis, root cause investigation, an operability determination, and a safety evaluation to determine the basis for dispositioning this chang The inspectors reviewed calculation change notice (CCN) - 4, "120 VAC System Short Circuit Study," Revision 1, and found that the licensee assumed that no more than 40% of the totalload circuits (19) would be involved in MHIFs at any given time and that MHIFs at the 120 VAC level could not persist past several cycles since restrike voltages would not be obtained. The inspectors determined that this 40% assumption was based on engineering judgement and was not supported by any test data or reports. The calculation showed that the 150 ampere fuse would not open. The inspectors verified that this was due to combined MHIFs and full load current equaling 145 amperes which is below the 150 ampere rating of the l fuse. The inspectors performed their own calculations and determined that if all circuits were considered for MHIFs, full load current would equal 216 ampere This condition would cause the 150 ampere fuse to open, thus necessitating a repair to achieve hot shutdow The inspector requested documented justification for the 40% assumption, since the issue of MHIFs is addressed in GL 86-10, which stated that the short must be assumed to exist until it is cleared by a protective action (paragraph 5.3.2).

Furthermore, GL 86-10 states, in paragraph 5.3.8, that licensees must " consider all associated circuits" which means that the 40% assumption is inappropriate. - The licensee stated that they were complying with the guidance provided in that they

" considered" all circuits but that they did not feel it was a credible failure mode to assume more than 40% failed circuits and that this assumption was very conservativ The inspectors considered the failure to include all circuits within the power panel as faulted to be a violation of Section 4.7.8 of the Fire Protection Program Manual, which states that " Measures are established to ensure that conditions adverse to fire protection such as failures, modifications, ... and nonconformances are promptly identified, reported and corrected." (VIO 50-423/98-81-02)

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l assumption, the licensee performed a reassessment of MHIFs and has determined l that three circuits in 3VBA*PNL-VB1 will require reenergization. They have implem3nted a design change, M3-98019, to install a 100 ampere circuit breaker in

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parallel with the 150 ampere main power supply fuse. The licensee also instituted controls to ensure the breaker is maintained in the open position. The inspectors

! reviewed the design change package and found no violations of requirements. In

- the event of a postulated control room fire, the circuit breaker can be operated without performing a repair to reach and maintain hot shutdown conditions.

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The failure of the original procedure to adequately reflect the installed equipment configuration (fuses rather than circuit breakers) is one example of procedure inadequacies described in Section 8.4.3 of this report, which is the subject of a non-cited violatio Conclusions Based on the above review, the inspectors concluded that the licensee did not initially perform acceptable corrective actions to resolve the MHIF condition, which is a violation of the corrective action requirements of the Fire Protection Program )

Manual. The inspectors considered CCN-4 inadequate based on the licensees assumption that 40% of the total connected circuits were considered to be faulte The licensee took appropriate corrective actions to reassess and disposition this a issu F8.2 (Closed) LER 50-423/97-051: Design Deficiency for 4.16 Kilovolt Feeder Fault Clearing Times. This LER was reviewed at the licensee's site during this inspectio On October 6,1997, the licensee identified that the overcurrent protection design for 4.16kV feeder circuits (class 1E and non-class 1E) would not clear a short circuit in sufficient time to provide adequate cable protection for short circuit condition A short circuit could be an initiating condition or a subsequent condition due to a fire. The licensee identified a total of seventy-one 4.16kV system feeder circuits (on buses 34A,348,34C, and 34D) that were impacted by this condition. The root cause of this condition was attributed to an inadequate design control process during original design implementation. The licensee initiated corrective actions to replace GE model number 12HFA154B22F electrically resettable lockout relays with a faster model, GE model number 12HFA154825Feiectrically resettable lockout relays to all affected circuits, thus reducing clearing times to the six cycles or less required by calculation SWEC 178E, "SkV and 8kV Power Cable Temperature Under Fault Conditions," Revision The inspectors reviewed several documents associated with the closure of this j issue and found that they provided sufficient corrective actions, analysis, an operability determination, and an appropriate safety evaluation to determine the basis for this change. The inspectors performed a verification walkdown of the east I and west switchgear rooms to verify the installation of the GE model number l 12HFA154825Flockout relays. Forty five lockout relays were verified to be installe The inspectors concluded that, prior to the relay replacements recently performed, the facility did not conform to the approved design documented in the Fire Protection Evaluation Report. This old design issue, which was identified, reported, and corrected, is not being cited for enforcement action in accordance with Section Vll.B.2 of the General Statement of Policy and Procedures for NRC Enforcement Actions, NUREG-1600 (Enforcement Policy). (NCV 50-423/98-81-04)

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F8.3 JClosed) LER 50-423/97-059: Spurious Operation of Auxiliary Feedwater Pump Turbine Exhaust Condensate Drain Line Isolation Valve During Certain Fire Scenarios May impact Safe Shutdown Capability. The inspector reviewed the written report, submitted December 22,1997, and additional documents relating to the corrective actions for the deficiency. This matter was inspected onsite, including a walkdown to verify field conditions of the equipmen The deficiency was first identified by NNECo on September 10,1997, during design work to upgrade the pilot solenoid valve used to drain condensate from the turbine--

driven auxiliary feedwater pump exhaust piping. The BTP 9.5-1 Compliance Report identified the valve as not required for safe shutdown since misoperation of the valve would nut compromise the ability to achieve post-fire safe shutdown. In i

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actuality, the valve must close and remain closed on turbine initiation to limit steam leakage in to the turbine pump room, which could damage the turb;ne's electronic controls. This issue was created by a design change during initial construction which removed the valve outlet line from a closed drain header to' resolve excess pipe stress issues. The valve outlet piping was routed directly to the floor, where the condensate would run to a nearby floor drai Correction of the problem involved routing the drain valve outlet piping into the closed drain header, which vents outside the building. The drain header is routed to a floor drain through a loop seal which prevents steam leakage into the room. The tie-in to the drain header is made with flexible metal bellows hose, to prevent excessive pipe stress level The inspector concluded that prior to the recent tie-in of the exhaust drain line to the drain header, the facility was not in conformance to the approved design as documented in the Fire Protection Evaluation Report. This old design issue, which was identified, reported, and corrected, is not being cited for enforcement action in accordance with Section Vll.B.2 of the Enforcement Policy. (NCV 50-423/98-81- I 05) l F8.4 (Closed) Unresolved item 50-423/97-84-01."Inadeauste implementation of Fire I

Protection Proaram Controla" F8.4.1 Surveillance Testina of Post-Fire Safe Shutdown Eauioment

- Insoection Scooe The inspectors reviewed records of component level tests conducted during initial plant startup testing, and recent surveillance tests performed on post-fire safe .i shutdown equipmen l

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10 Observations and Findinas During a program audit conducted in December 1996 by NNECo Audits and Evaluations Group (A&E), the auditors identified potentially inadequate testing of some components required for post-fire safe shutdown. Several of those components were located in the Alternate Shutdown Panel (ASP) and Fire Transfer Switch Panel (FTSP).

Subsequent to the 50-423/97-84 inspection, NNECo was able to locate construction testing records which showed that the circuits through the FTSP had been tested as part of component level testing during the initial startup program, with three exception The results of the surveillance tests performed in February and March 1998 determined that all equipment functioned properly, except the "A" train charging pump cooling pump. Subsequent troubleshooting found the cause of the test failure to be a failed isolator card in panel 3CES*PNLOG20. The isolator was replaced and the pump was successfully teste This violation of requirements stated in Branch Technical Position 9.5-1, section 4(e), " Test and Test Control," to test post-fire safe shutdown equipment is not being cited, in accordance with Section Vll.B.2 of the General Statement of Policy and Procedures for NRC Enforcement Actions (Enforcement Policy) since it was identified by the licensee during the course of a program audit, was related to activities in the past which led to the extended shutdown of the Millstone reactors, was not willful, and would not have been categorized at Severity Level (NCV 50-423/98-81-03) Conclusions The inspectors determined, based on reviews of test results, and automated work orders, that appropriate actions were taken to verify the operability of post-fire safe shutdown equipment. The licensee performed inadequate testing of some components required for post-fire safe shutdown. The licensee performed surveillance tests to ensure all post-fire safe shutdown equipment was properly tested. This licensee identified and corrected violation was not cite (NCV 50-423/98-8103)

F8.4.2 Temporary Modification Process Evaluation of Effects on Post-Fire Safe Shutdown Insoection Scoce The inspector reviewed Procedure WC-10, Temporary Modification, Revision 1, through Change 4, to determine whether adequate programmatic controls were incorporated to ensure the evaluation of the effect of temporary modifications on the fire protection progra _ _ _ _ _

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11 Observations and Findinas An audit of the fire protection program conducted in December 1996 by the A&E group found that temporary modifications to the facility were not adequately evaluated for their effect on the fire protection program. A number of instances were cited where the evaluation did not identify welding, grinding, and temporary cable installation as impacting fire protection requirement Revision.1 to Procedure WC-10 was in draft form at the time of the 50-423/97-84 inspection and was therefore not reviewed at that time. Revision 1 was issued with an effective date of October 27,1997. Revision 1 to WC-10 requires evaluators of temporary modifications to perform a Design Engineering Screening in accordance with Chapter 3 of the Design Change Manual (Chapter 4 for quality systems).

. These reviews will identify the need for detailed reviews by fire protection personnel. In addition, procedures NGP 5.12, " Performance of Fire Protection-reviews," and NGP 5.24, " Maintenance of Appendix R/BTP 9.5-1 Program," have been revised to provide guidance for evaluating the impact of proposed ,

modifications on the post-fire shutdown methods described in the BTP 9.5-1 Compliance Repor This violation of the requirement stated in Branch Technical Position' O.5-1, j section b, " Fire Hazards Analysis," to evaluate the effect of facility modifications on

- the fire protection program is not being cited, in accordance with Section Vll.B.2 of -

the Enforcement Policy, since it was identified by the licensee during the course of ' 1

- a program audit, was related to activities in the past which led to the extended shutdown of the Millstone reactors, was not willful, and would not have been categorized at Severity Level 1. (NCV 50-423/98-81-03) 1 l I

' Conclusions Based on the procedure revisions, and process enhancements implemented, the inspectors determined that appropriate measures appeared to have been taken to ensure effective evaluations of temporary modification impact on the fire protection .

. program. The licensee failed to evaluate the effect of facility modifications on the l fire protection program. , Subsequently, the licensee revised procedure WC-10 to '

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identified and corrected violation was not cited. (NCV 50-423/98-81-03)

i F8.4.3 Unit 3 Emeroency Operatina Procedures for Post Fire Safe Shutdown  ; Scone of Insoection

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The inspectors reviewed the post-fire safe shutdown procedures for various fire areas in the facility to verify that manual actions identified in the BTP 9.5-1 -;

Compliance Report were appropriately incorporated, in addition, the inspector performed a field walkdown of EOP 3509.9, Rev. O, " Control Building El. 4'6" East SWGR Area Fire," to evaluate the feasibility of manual actions listed, and the emergency lighting provided for performing the manual action '

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. ' Observations and Findinas .

During an audit of the fire protection program conducted by the A&E group in December 1996, the auditors found that a licensing commitment to proceduralize manual actions needed to reach safe shutdown, as identified in the BTP 9.5-1 Compliance Report, had not been adequately carried out.

< During inspection 50-423/97-84,the NNECo fire protection staff informed the

. inspectors that the emergency operating procedures for post-fire safe shutdown, 1

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EOP3509 series, were under revision. Since the procedures were in draft form at the time, they were not reviewed in that inspectio !

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Emergency Operating Procedure (EOP) 3509, Fire Emergency, provides instructions 1 for the operators to respond to fires in the plant. It includes information regarding tripping of ventilation fans to ensure the ability of fire dampers to close, tables providing information regarding the habitability of plant areas in the event one of the fixed carbon dioxide (CO2 ) fire suppression systems were to actuate, and tables listing electrical loads which require power to permit achieving safe shutdown post-fire. Revision 15 of EOP 3509 was issued during this inspection perio In addition to EOP 3509, there are now separate procedures for each fire area in the plant where manual actions will be required to achieve safe shutdown condition j These procedures are designated as EOP 3509.1 through 3509.32. These  ;

procedures provide specific instructions for manual actions needed to achieve stable shutdown conditions after a fire in that area, including actions to disable equipment if it operates improperly due to fire damag During the walkdown of EOP 3509.9, Revision 0, the inspectors found that acceptable procedural steps were in place for the manual actions listed in the procedure. The inspectors also found that emergency lighting provided acceptable illumination and lighting patterns for performing the required manual manipulations of safe shutdown equipment. This was verified by hav,ing licensee personnel

depress test buttons'on the emergency lights during the walk down of the procedure. No problems were observed.

l- .The failure to implement licensing commitments as stated in the license condition, which implement the fire protection program as stated in the safety evaluation report is a violation of NRC requirements. However, the violation is not being cited, in accordance with Section Vll.B.2 of the Enforcement Policy, since it was identified by the licensee during the course of a program audit, was related to activities in the pest which led to the extended shutdown of the Millstone reactors, was not willful, and would not have been categorized at Severity Level (NCV 50-423/98-8103)

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l Conclusions The inspectors determined, based on a review of the EOP 3509 series of

~ procedures, that NNECo has adequately implemented the licensing commitment to proceduralize the manual actions identified in the FHA as being necessary to achieve safe shutdown after a fire.' (NCV 50-423/98-81-03) The inspectors also determined that EOP 3509.9, Revision 0, provided acceptable procedural steps to perform the listed manual actions and emergency lighting provided acceptable illumination and lighting patterns for these manual action F8.4.4 Response to issues identified in Audits and Self-Assessments Insoection Scooe The inspector reviewed several corrective actions implemented by NNECo to resolve findings of the December 1996 audit of the fire protection program which are documented in Condition Report M3 97-337 Observations and Findinas During an audit conducted in December 1996, the NNECo A&E group identified that corrective actions for several previous audit findings had not been timely, nor -

effective in preventing recurrence of the deficienc The Programs and Engineering Standards Group performed a root cause evaluation for the inadequate responses to audit findings, and determined that the cause included numerous occurrences of inattention to detail, unawareness, personnel errors and inappropriate assumption A wide range of corrective actions were developed, including revision of the Unit 3 Corrective Action Department procedure for controlling Action item Tracking System entries, revisions of the Fire Protection Program Manual regarding FHA

. updates, creation of a log of surveillance performed on fire dampers to ensure all dampers are inspected, revision of maintenance and surveillance procedures-regarding the replacement component cooling pump motor staged for post-fire installation, revisions to the work planning process, and changes to managerial responsibilities in the corrective action program. Those actions identified as -

necessary for restart have been completed, and the long term actions are being tracked to ensure completio ' The failure to implement adequate and affective corrective actions as stated in Branch Technical Position 9.5-1, section 4(h), " Corrective Action," is not being cited, in accordance with Section Vll.B.2 of the Enforcement Policy, since it was

. identified by the licensee during the course of a program audit, was related to activities in the past which led to the extended shutdown of the Millstone reactors, was not willful, was corrected without enforcement action being taken, and would not have been categorized at Severity Level I. (NCV 50-423/98-81-03)

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c. Conclusions The inspectors concluded that the corrective actions taken by the licensee to disposition fire protection issues documented in condition report M3-97-3373 were acceptable. The licensee failed to implement adequate and effective corrective actions from previous' audit findings. The licensee had instituted several corrective actions to ensure audit findings are entered into their correctivo action process and appropriate ly tracked. This licensee identified and corrected violation was not cite (NCV 50-423/48-81-03)

F8.5 (Closed) Significant issues List item 42 As a result of deficiencies identified during NRC Integrated Inspection 50-245&336&423/96-08, a fire protection startup item was added to the Significant issues List (SIL) for Unit 3 restart. The issues relating to fire protection in SIL ltem 42 were:

1) inadequacies in critiques conducted following fire drills 2) poor support by chemistry and security during fire drilb 3) inconsistent engineering support, a lack of program oversight by engineering, and a lack of guidance for prioritizing and correcting identified deficiencies 4) lack of guidance and direction for program responsibilities and implementation 5) review by a Joint Utilities Management Assessment team found the quality assurance program to be ineffective due to a lack of management support and an inadequate corrective action progra Issues 1 and 2 are discussed in Section F4.1 of this report, and were found acceptabl Issue 3 is discussed in Sections F2.1, F2.3, F2.4, F7.1, F8.2, F8.3, and F8.4 of this report, and were found acceptabl Issue 4 is discussed in Section F3.1 of this report, and was found acceptabl Issue 5 is discussed in Section 8.4.4 of this report, and was found acceptable.

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V. MANAGEMENT MEETINGS X1 Exit Meeting Sumrnary The results of the inspection were discussed with members of your staff in a meeting conducted onsite March 6,1998, and in a conference call conducted March 30,1998. At that time, the findings were not contested. The inspectors noted that no proprietary information was provided to them during this inspectio The licensee provided brit.*.'og information on the fire protection program for Millstone Unit 3 to the inspectors after it.e entrance meeting was completed. This information is provided as an enclosure to +.ua inspection report.

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PARTIAL LIST OF PERSONS CONTACTED Northeast Utilities M. Bowling MP2 Recovery Officer M. Brothers ' Vice president, Operations

- D. - Hicks Director, Millstone Unit 3 S. Scace Director, Engineering Programs H. Miller Director, Unit Services B. Willkens Manager, Programs and Engineering Standards E. Groove Manager, Audits and Evaluations

.P. Atkinson Supervisor, Unit 3 Technical Support R. : Hart Fire Protection Program Manager, Millstone Unit 2 T. Cleary

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Senior Engineer, Regulatory Compliance H. McKenne Site Fire Protection Engineer J. Nickerson Site Fire Marshall

. Nuclear Reaulatorv Commission K. S. West Chief, Fire Protection Section, Plant Systems Branch, NRR W. ' Ruland Chief, Electrical Engineering Branch, DRS, Region 1 A. . Corne Senior Resident inspector, Millstone 3 B. Korona Resident inspector, Millstone 3 INSPECTION PROCEDURES USED IP 64150: Triennial Postfire Safe Shutdown Capability Reverification-l ITEMS OPENED, CLOSED, AND DISCUSSED

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50-423/98-81-01 VIO failure to protect the fire barrier support steal from the effects of an exposure fire in the cable room 50-243/98-81-02- VIO failure to include all circuits within the power panol as faulted when analyzing multiple high impedance fault Closed 50-423/97-84-01 URI inadequate implementation of fire protection program controls

50-423/98-81-03 NCV inadequate implementation of fire protection program controls 50 423/98-81-04 NCV ciasign deficiency for 4.16 kilovolt feeder fault clearing times

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50-423/98-81-05- NCV spurious operation of auxiliary feedwater pump turbine exhaust condensate drain line isolation valve during certain fire scenarios may impact safe shutdown capabilit /97-051 LER design deficiency for 4.16 kilovolt feeder fault clearing times 50-423/98-81-05 LER spurious operation of auxiliary feedwater pump turbine exhaust condensate drain line isolation valve during certain fire scenarios cay impact safe shutdown capabilit _ _ _ - _ - _ _ _ _ _ _ _ -

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LIST OF ABBREVIATIONS USED A&E Audits and Evaluations ANSI American National Standards Institute ASME American Society of Mechanical Engineers ASP Alternative Shutdown Panel BLDG Building BTP Branch Technical Position CCN Calculation Change Notice CFR Code of Federal Regulations CH/RPCCW Charging Pump / Reactor Plant Component Cooling Water DCR Design Change Request EL Elevation EN Event Notification EOP Emergency Operating Procedure ESF Engineered Safeguards Feature FHA Fire Hazards Analysis FPER Fire Protection Evaluation Report FTSP Fire Transfer Switch Panel GL Generic Letter IN information Notice kV Kilovolt LER Licensee Event Report MHIF Multiple High Impedance Faults NCV Non-Cited Violation NGP Nuclear Group Procedure NNECo Northeast Nuclear Energy Company NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation PDR Public Docket Room scfm standard cubic feet per minute SIL Significant issues List SWGR Switchgear UFSAR Updated Final Safety Analysis Report VAC Volts Alternating Current VIAC Vital Alternating Current VIO Violation

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ENCMSlRE MILLSTONE UNIT 3

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FIRE PROTECTION PROGRAM INTERNAL AND EXTERNAL ASSESSMENTS i

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• Engineering Self-Assessment PES-97-006, " Engineering Self Assessment of the Fire Protection / Appendix R Program, Millstone Nuclear Power Station Unit No. 3," dated April 12,1997 (CR M3-97-1056)

• QAS Audit No. A30339, " Appendix R (CMEB BTP 9.5-1) Fire Protection, Millstone Unit 3, dated March 6,1996 (CR M3-96-0196)

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• Nuclear Oversight Audit Package A24057/A25119, " Triennial Fire Protection Program Millstone and Connecticut Yankee," dated March 10,1997 (CR M3-97-0176)

• Nuclear Oversight Audit Package MP-97-A09-01, " Fire Protection Program,"

dated November 17,1997 (CR M3-97-3370, M3-97-3371, M3-97-3372, M3-97-3373)

• USNRC Combined inspection 50-245/96-08; 50-336/96-08; 50-423/96-08 and Notice of Violation, dated December 3,1996

• USNRC Combined inspection 50-336/97-84; 50-423/97-84, dated February 9,1998 (CR M3-98-0994)

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Page 1 of 5 B.J. W I

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MILLSTONE UNIT 3 ,

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FIRE PROTECTION PROGRAM RESULTS OF INTERNAL & EXTERNAL ASSESSMENTS

• ORGANIZATIONAL ISSUES

- Lines of communication undefined between organizations

- Lack of single point of control for Fire Protection / Appendix R issues

- Engineering support not consistently implemented

- Lack of prioritization of work load

- Lack of Performance Indicators

- Lack of Management Oversight

• Configuration Management of Licensing / Design Bases vs Physical Plant

- Lack of Program Manual and Implementing instructions

- Weaknesses in Design Control Program (including Temporary Modifications) for program reviews

- Program not included in NGP 2.32, " Engineering Programs"

- Lack of Program bdicators in PMMS

- Lack of updated Compliance Report, Fire Hazard Analysis, and FSAR

• Corrective Actions

- Lack of prioritization of corrective actions

- Lack of effective corrective actions

• Equipment Testing / Surveillance Procedures

- Lack of documentation to support testing of Fire Transfer Switch Panel and CCP Pump Area Fan

- Lack of surveillance procedures to support the TRM

- Implementation of Safe Shutdown requirements into EOPs not effective

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Page 2 of 5 B.J. Willkens 3f2198

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. MILLSTONE UNIT 3 FIRE PROTECTION PROGRAM MAJOR CONDITION REPORTS CR M3-96-0196 (dated 06/20/96)- Level D

. QAS Audit No. A30339 e 2 Actions remain tied to Mode 4 for completion of Safe Shutdown Procedures CR M3-97-0176 (dated 01/17/97)- Level B

. Oversight Audit A24057/A25119 2 Actions remain tied to Mode 4 for completion of surveillance procedures in support of the BTP Compliance Report CR M3-97-1056 (dated 04/12/97) - Level 2

. CMP Self-Assessment PES-97-006

. Restart items are complete CR M3-97-3226 (dated 09/23/97) - Level 2

. Preliminary results from NRC Inspection 50-423/97-94 (SIL Zone 42.1)

. 3 Actions remain tied to Mode 4 for the completion of surveillance procedures, Safe Shutdown procedures, and equipment testing CR M3-97-3373 (dated 10/03/97) - Level 1  !

. Oversight Audit MP-97-A09-01

. Restart items are complete CR M3-97-3413 (dated 10/06/97) - Level 1 5

. Discrepancies Between Plant Design and Required Fault Cleari j Times of 4.16KV Systems

. Restart items are complete 4R M3-97-4684 (dated 12/17/97) - Level 1

. Self Identified Multiple High impedance Faults

. 1 Actions remains tied to Mode 4 for completion of EOP 3509 in support of the BTP Compliance Report

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CR M3-98-0994 (dated 02/20/98) - Level 1

. NRC Inspection 50-423/97-84

. Currently Performing Root Cause Evaluation l

Page 3 of 5 B.J. Wilikens 3f2)98

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MILLSTONE UNIT 3

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FIRE PROTECTION PROGRAM COMPLETED ITEMS

• Establishment of Fire Protection / Appendix R Engineering Group (Minimum through MP2 restart)

e Assignment of Key issue Manager (Barbara Willkens) and Executive Sponsor (Marty Bowling)

• Assignment of NU Fire Protection Coordinator (Hugh McKenney)  !

• Independent Assessment of Program under CMP PI-21 ,

e issuance of Fire Protection Program Manual (Rev 0, dated 7/30/97),

and Rev.1 (dated 12/30/97).

e issuance of BTP 9.5-1 Compliance Report, (Rev. 2, dated 2/12/98)

e isstance of TRM Section to address operability of Appendix R Safe Shutdown equipment e issuance of surveillance procedures required to verify operability requirements from the TRM e Development of Annunciator Window for Fire Protection

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i e Fire Protection included in Nuclear Oversight Recovery Verification Plan (NORVP)

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MILLSTONE UNIT 3 l' FIRE PROTECTION PROGRAM REMAINING ACTIONS

Required for Restart:

• EOPs scheduled for PORC 3/3/98

. Surveillance Procedures approved 3/3/98

• Performance of surveillance tied to train swap estimated completion date week of 3/2/98 (Testing of Auxiliary Shutdown Panel and Fire Transfer {

Switch Panel)

• Completion of SIL Zone 4 Post-Restart:

• Completion of Deferred items from Condition Reports

• Enhancements to FPPM l

• Completion of items from Self-Assessments

• Performance of Assessment for Effectiveness of Corrective Actions

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