IR 05000424/1986064
| ML20214M900 | |
| Person / Time | |
|---|---|
| Site: | Vogtle |
| Issue date: | 08/15/1986 |
| From: | Conlon T, Miller W, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20214M892 | List: |
| References | |
| 50-424-86-64, 50-425-86-30, NUDOCS 8609110400 | |
| Download: ML20214M900 (15) | |
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dFf4 UNITED STATES
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9'o NUCLEAR REGULATORY COMMISSION
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REGION 11
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j 101 MARIETTA STREET,N.W.
's ATL ANTA. GEORGI A 30323
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Report Nos.: 50-424/86-64 and 50-425/86-30'
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Licensee: Georgia Power Company F. O. Box 4545 Atlanta, GA 30302 Docket Nos.: 50-424 and 50-425 License Nos.: CPPR-108 and CPPR-109 Facility Name: Vogtle 1 and 2 Inspection. Conducted: July 21-25, 1986 Inspect r:
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I[//![h W. H. Miller, Jr.
Mte Signed te. LL-suu G.'R. Wisem'an Date 31gned Approved by gf#p/ M
[' /f-b T. E. Conlon, Chief Date Signed Plant Systems Section Division of Reactor Safety SUMMARY Scope:
This routine, announced inspection was conducted in the areas of fire protection and prevention.
l Results:
No violations were identified, but one deviation was identified -
Inadequate Fire Protection Quality Assurance Program - paragraph 6.b.
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l 8609110400 860827 PDR ADOCK 05000424 G
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- R. Allen, Project Compliance
- C. E. Eelflower, Quality Assurance Site Manager /0perations
- D. C. Borowski, EQE Inspection, Supervisor
- P. L. Cail, Plant Training / Operations R. E. Conway, Senior, Vice President, Project Director M. S. Dean, Mechanical Engineer
- S. D. Driver, Plant Training Supervisor / Operations
- M. H. Googe, Project Construction Manager
- E. D. Groover, Quality Assurance Site Manager
- B. C. Harbin, Manager, Quality Control
- C. Hayes, Quality Assurance Manager
- C. W. Janecke, Quality Control Investigator
- G. A. McCarley, Project Compliance Coordinator
- C. C. Miller, Superintendent Plant Engineering & Services
- W. T. Nickerson, Asstistant to Project Director
- C. Quinn, Senior, Engineer
- K. Rosanski, Asstistant to Vice President, Project Engineering
- P. Rushton, Superintendent Nuclear Training
- R. Sprankle, Senior Engineer, Fire Protection
- H. Varnadog, Plant Engineering Supervisor Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security office members and office personnel.
Other Organizations J. B. Ellison, Cleveland - EF0 Supervisor M. Jordon, ICMS
- G. H. Jones, Utility Support Corporation M. Larson, Bechtel (Fire Protection / Safe Shutdown)
- J. Maddry, SCS, Fire Protective Engineer
- F. B. Marsh, Bechtel, Project Engineering Manager
- A. J. Strunk, Bechtel, Fire Protection
- B. Woodley, Bechtel, Fire Protection Coordinator D. Zilke, ICMS/QC Manager
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NRC Resident Inspectors H. Livermore
- J.
Rogge
- R. Schepens
- Attended exit interview
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2.
Exit Interview The inspection scope and findings were summarized on July 25, 1986, with those persons indic ted in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings listed below. No dissenting comments were received from the licensee.
Inspector Followup Item (424/86-64-01), Inadequate Quarterly Fire Drills by the Fire Brigade - paragraph 6.a.(1).
Inspector Followup Item (424/86-64-02), Incomplete Fire Brigade Equipment Inventory and Fire Brigade Response Assembly Area c
paragraph 6.a.(2).
Inspector Followup Item (424/86-64-03), Pre-fire Plans Fail to Properly Identify Adequate Fire Brigade Strategies - paragraph 6.a.(3).
Inspector Followup Item (424/86-64-04),
Automatic Sprinkler Systems Do Not Meet FSAR Design Commitments - paragraph 6.b.(1).
Deviation (424/86-64-05 and 425/86-30-01), QA Program for Fire Protection Systems Installation Does Not Meet NRC Branch Technical Position CMEB 9.5.1 - paragraph E.b(2), (3) and (4).
Inspector Followup Item (424/86-64-06) Licensee to Provide Design and Test Data for Fire Barrier Penetration Seals - paragraph
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6.b.(3).
Inspector Followup Item (424/86-64-07), Fire Detection System for the Main Control Room Complex Fails to Comply with SSER 1 Commitments - paragraph 6.b(4).
Inspector Followup Item (424/86-64-08), NRC Verification of Fire Protection Finalization Program Procedure Revision and Procedure Implementation - paragraph 7.
NOTE:
The above items are identified as Inspector Followup Items since l
these items are not required to be in place or operational until after licensing.
I The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.
3.
Licensee Action on Previous Enforcement Matters (Closed) Unresolved Item (424, 425/84-34-04), Apparent Substandard Fire Damper Installations.
The licensee has obtained design data from the
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manufacturer which approved mounting of fire dampers to dampen sleeves by l
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the use of 1" welds on 6" centers on one side of damper assembly for dampers smaller than 24" X 24".
Also, data has been obtained from Underwriters Laboratories, Inc. (UL), who evaluated and found the installation of fire dampers which meet the following configuration to be acceptable:
Provisions of expansion clearance of up to 21" between sleeve and wall or floor opening Use of steel spacers between duct sleeve and wall on not more than two
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sides of the sleeve Use of No. 10 gauge cover plates in lieu of mounting angles
Use of fiberfrax or kao-wool ceramic fiber insulation for clearance openings over 21 and less than 13 inches between duct and damper The licensee has incorporated this data into the design, installation and QC inspections requirements for fire dampers.
This item is closed.
However, since a number of duct / fire damper assemblies are installed within opening in floor / wall for fire barrier penetrations which have an opening greater than 13 inches, the inspectors requested that the licensee provide design / test data to substantiate that this configuration meets the required three hour fire resistant rating.
Refer to Inspector Followup Item (424/86-64-06).
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Unresolved Items Unresolved items were not identified during the inspection.
5.
Fire Protection Features For Receipt of New Fuel The inspectors toured Fire Zone 47, New Fuel Unloading Bay, and Zone 139, New Fuel Storage Area to verify that the licensee's fire protection commitments for these areas upon initial, fuel receipt, as identified in the licensee application for SNM, dated June 30, 1986, had been implemented.
Based upon this walkthrough, it appears that the licensee's fire protection features meet the license application except for the following:
Permanent plant fire hose and fire hose nozzles have not yet been
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installed on the fire hose stations in the above fire zones Fire detection systems within these areas are not operational
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Portable fire extinguishers have not yet been installed within the fire
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zones These items have been identified by the licensee, and are to be completed prior to receipt of fuel within the fuel handling and storage areas. These are to be verified during future routine NRC inspections.
Within the areas examined, no violations or deviations were identified.
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6.
Operational Fire Prevention / Protection Program (Module 64704)
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Plant Fire Brigade (1) The total Unit 1 station fire brigade is to be composed of approximately 115 personnel from the operations (76) and maintenance (39) staffs.
The "on-duty" fire brigade shift is to include five members in accordance with NUREG 0800, Standard Review Plan, 9.5.1, Fire Protection Programs for
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Nuclear Power Facilities.
The fire brigade team captain and two members are personnel from the reactor operations group.
The remaining two members are from the maintenance operations group.
At the time of the inspection, the reactor operations group had not yet developed the procedures to give guidance for the assignment of the on-shift fire team captain.
This item has been identified in the licensee's QA Audit for Operations Phase and is considered part of the previously identified Inspector Followup Item (424/86-55-04), which remains open.
FSAR Appendix 9B, Section C,3.d.(7)(b) states that fire drills will be performed with the fire brigade quarterly.
The licensee's training program includes scheduling of training the brigade through a review and walkthrough of pre-fire plans in various areas of the plant.
This appears to be an excellent method of acquainting the brigade member with various aspects of firefighting for specific plant areas.
However, the licensee intends to credit these sessions as a means of meeting the drill requirements of BTP 9.5.1.
The inspectors were concerned because these sessions were not performance oriented or critiqued by the fire protection staff, therefore they may not qualify as fire team drills to satisfy the quarterly drills requirement for the on-duty shift.
This concern is identified as Inspector Followup Item (424/86-64-01),
Inadequate Quarterly Fire Drills by the Fire Brigade, and will be reviewed during a subsequent NRC inspection.
(2)
Fire Brigade Equipment The inspectors performed an inspection of the fire brigade equipment consisting of turnout gear (coats, boots, pants, helmets, etc.), self-contained breathing apparatus, spare air '
cylinders, portable generator with lights and cards, and portable smoke ejectors with ducts.
It was noted that the fire brigade communication radios were not included in the equipment inventory.
This radio equipment was being procured
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and was not available at the time of the inspection.
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fire brigade permanent fire fighting equipment was stored in the warehouse receipt area and not within the plant.
At the time of the inspection, the permanent plant fire brigade response assembly / locker area had not been established.
Request for Engineering Assistance, REA No.1-86-0207 is under evaluation by Vogtle engineering to provide a review of a proposed area in Room 117 of the Equipment Building - Level 1 Elevation 220'
for use as the fire brigade locker and assembly area.
The area appears accessible from the main control room and would provide an adequate open area for brigade dressout and good access to other safety-related plant areas in event of fire.
This area, however, has not
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been authorized for this use by plant engineering and management.
The fire brigade is required to be capable of responding to a fire condition in the Fuel Handling Building upon fuel receipt and by fuel load for other areas.
Based on the above, these items are identified as Inspector Followup Item (424/86-64-02), Incomplete Fire Brigade Equipment Inventory and Fire Brigade Response Assembly Area, and will be reviewed during a subsequent NRC inspection.
(3) Fire Brigade Firefighting Pre-Fire Plans The inspectors reviewed the following pre-fire plans to determine if the plans developed proper fire-fighting strategies and addressed the guidelines established by Standard Review Plan (SRP) 9.5.1.
Procedure No.
Revision No.
Title 92701-C
Zone 1 Auxiliary Building (Level D)
92702-C
Zone 2 Switchgear Rooms Auxiliary Building 92714-C
Zone 14 Auxiliary Building (Level C)
92719-C
Zone 19 Auxiliary Building CVCS Centrifugal Charging Pump Rooms 92727-C
Zone 27 Fuel Handling Building (Level B)
92730-C
Zone 30 Auxiliary Building (Level B)
92747-C
Zone 47 Auxiliary Building (Level 1)
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92805-C
Zone 105 Control Building (Level 1)
92839-C
Zone 139 Fuel Handling Building (Levels A 183)
92862-C
Zone 162 Diesel Generator Building 92863-C
Zone-163 Diesel Generator Building 92865-C
Zone 165 Diesel Generator Tanks and Pumphouse These plans and strategies appear to meet the guidelines of SRP 9.5.1, Fire Protection Program, Position C.2.0 except that they do not, in general, adequately address protection of exposures such as heat sensitive plant equipment or other
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special considerations, specific plant operational duties of the brigade and backup plans for use of manual smoke removal equipment to move the smoke to a safe location using the brigade's portable exhaust fans and ducts in the event the plant's ventilation systems isolates as a result of a fire.
This is identified as Inspector Followup Item (424/86-64-03),
Pre-Fire Plans Fail to Properly Identify Adequate Fire Brigade Strategies, and will be reviewed during a subsequent NRC inspection.
(4) Fire Brigade Training Of the personnel presently assigned to the fire brigade; only approximately 40 of the 76 operational personnel and 21 of the 39 maintenance personnel have completed all of the required training or-have satisfactorily passed the fire brigade physical examination.
The licensee is reviewing the
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records to identify what additional training is required and which employees require a physical.
All personnel are to be properly trained and qualified prior to fuel load.
However, the licensee is to begin maintaining sufficient qualified personnel on each shift upon receipt of fuel.
The fire brigade training program will be reviewed during future NRC inspections.
(5) Fire Rrigade Drills During this inspection, the inspectors witnessed a fire brigade drill.
The fire scenario was a fuel oil fire in the Unit 1, Train B, Zone 162, Diesel Generator Building.
Two
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plant equipment operators were dispatched to the diesel generator building to verify the fire alarm.
Four fire brigade members and one of the Shift Supervisor responded to the pending fire emergency. The brigade arrived at the diesel generator in full protective clothing and breathing apparatus.
The brigade approached Train B room at the north door and attempted to enter, however, the door was locked and they had no keys.
The team captain and the brigade then entered the building through the unlocked south door.
The brigade assembled inside the area where the initial sizeup of the fire emergency was made by the fire brigade team captain.
Based on this sizeup the brigade established two 11 inch water fire attack hose lines on the fire.
These fire attack hose lines were placed in service approximately 15 minutes from the time of initial alarm notification.
Based on the observation of this drill,- the inspectors identified the following weaknesses related to brigade operations:
Entry keys to the building were not provided to the
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initial response personnel, security personnel, or the fire brigade team captain in order to gain rapid entry to the fire affected area.
Brigade used improper entry techniques upon their
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approach into the fire room.
Self-contained breathing apparatus (SCBA) units were not
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utilized upon entry into the fire area.
Fire brigade radio communication system appeared to be
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unsatisfactory in that the fire brigade team captain's radio was inoperative at the fire scene.
Also, it appeared that radio communications between the control room and diesel generator building was not possible.
l Brigade failed to protect fire exposures to the diesel
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generator such as the fuel oil storage tanks.
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Brigade failed to perform initial search and rescue
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operations upon entry into the fire room.
The above weaknesses in the fire brigade's operation is attributed to personnel inexperience in actual hands-on
firefighting.
This condition was identified to the
operations fire protection and training staff.
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intends to conduct frequent fire brigade drills for each on-duty
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shift to attain an increased level of experience and proficiency in basic fire fighting techniques prior to fuel receipt and
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storage.
The fire brigade drill performance will be reviewed
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during future NRC inspections, i
b.
Fire Protection Systems The following permanent plant fire protection systems and features were reviewed during this inspection:
(1) Automatic Sprinkler Systems FSAR Appendix 98, Section C.6.c.(3) states that NFPA-13, Standard for the Installation of Sprinkler Systems and NFPA-15, Standard
for Water Spray Fixed Systems will be used as a guide for instal-i lation of the automatic sprinkler systems at Vogtle, but the final
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design and installation will conform to sound engineering judgement.
- FSAR Appendix 9A identifies the plant areas in which the sprinkler protection is to be provided.
The sprinkler systems installed in the following plant. areas were reviewed by the inspector:
l Fire Area / Zone Location Drawing No.
Date of QC
Inspection
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1-AB-LC-E/19 Train B 1X4AX03-5119-4 2-13-86
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charging i
pump room 3-31-86 i
1-FB-LC-A/15 Pipe Pene-
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1-FB-LC-A/132 Pipe Pene-1X4A03-5258-4 3-12-86 tration Room
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NOTE: * System retested I
The systems for zones 15 and 132 do not meet the FSAR Appendix 9A.1.107 commitments and installation commitments of FSAR Appendix 9B, Section C.6.c.(3) due to the following discrepancies:
l Systems do not provide total zone coverage as stated by FSAR
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l Appendix 9A.1.107
l Protection for stairway and openings in Zone 15 does not meet
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NFPA-13, Section 4-4.8.2.3 due to lack of draft curtains and deficient sprinkler spacing.
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Protection is not provided beneath grated floors as required by NFPA-13, Section 4-4.11 Also, the control valve to the sprinkler system water flow pressure switch is not of the type that can be sealed or locked in the correct alignment as required by NFPA-13, Section 3-16.4.5.
Operations has issued Operation Deficiency Report T-1-86-2598 to correct this installation deficiency.
These deficiencies were identified to the licensee as Inspector
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Followup Item (424/86-64-04) Automatic Sprinkler System Do Not Meet FSAR Design Commitments.
(2) Structural Steel Fireproofing The inspectors reviewed the structural steel fireproofing for the following plant areas:
Drawing No.
Location AXZD09F011 Fuel handling building-263' Elevation AXZD08F133 Auxiliary Building-288'-2" Elevation AXZD07F001 Diesel Generator Building-255' Elevation The structural steel for several columns and beams within these areas were not properly coated.
These discrepancies had been identified by the licensee's fire protection walkdown verification program, appropriate deficiency reports are to be issued and the
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deficiencies are to be corrected.
However, in reviewing these
features the inspector was unable to locate records which indicated that the recent fire proofing operations were being conducted under a quality assurance (QA) inspection verification program.
FSAR Section 9.5.1.1.4 states that the fire protection systems are to be installed under a QA program which has been
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integrated into the overall plant QA program as described by FSAR Section 17.1 for design and construction and FSAR Section 17.2 for operations.
FSAR Appendix 9B Section C.4 states that the Vogtle
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fire protection QA program will be part of the overall plant QA
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program.
The failure to include the structural steel fire
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proofing installation under the plant QA program is a failure to meet a commitment made to the NRC and is identified as Deviation (424/86-64-05 and 425/86-30-01), QA Program for Fire Protection l
Systems Does Not Meet NRC Branch Technical Position CMEB 9.5.1.
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(3)
Fire Barrier Penetrations A review was made of the following fire barrier penetration seals and dampers:
Tyge Number OC Inspection Records Fire Damper 1-1562-426 yes Fire Damper 1-1562-440 yes Fire Damper 1-1562-445 yes Fire Damper 1-1562-446 yes Fire Damper 1-1531-506 yes Fire Damper 1-1531-509 yes Mechanical / Pipe 134-2-1-09-079-A yes Mechanical / Pipe 134-2-1-09-080-A In process Mechanical / Pipe 081-2-1-09-B-10 In process Mechanical / Pipe 081-2-1-09-017-B-13 In process Electrical 1-213-1-11-005-2 In process Electrical 1-213-1-11-287-2 In process Electrical 1-213-1-11-288-2 In process Electrical 1-213-1-11-291-2 In process Electrical 1-213-1-11-292-2 In process Seismic Gap 1-01-1-20 No Seismic Gap 1-09-A-10-Curb No Seismic Gap Fuel Handling Bldg No Level A between Room 9 and 10 Seismic Gap Fuel Handling Bldg.
No Level 1 Room 20 Ficor
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Each of the above completed penetrations was inspected and the damper installation and/or penetration seal appeared to meet the construction documents.
However, records were not available to verify that the penetration seals met the design requirements for a three-hour fire resistant rating.
The inspector requested that the licensee provide the necessary design and test data to verify that the penetrations would provide the required three-hour protection.
This is identified as Inspector Followup Item (424/86-64-06), Licensee to Provide Design and Test Data for Fire Barrier Penetration Seals, and will be reviewed during a subsequent NRC inspection.
The inspector noted that the silicone foam for the electrical and mechanical penetration seals were being installed under a QC program, but the silicone foam for the seismic gap penetration seal was not being installed under a QC program as required by FSAR commitments.
This discrepancy was identified as another example of Deviation (424/86-64-05 and 425/86-30-01).
(4) Fire Detection System A review was made of the fire detection systems and their associated QC inspection records for the below listed fire detection systems:
Detection Zone NoJ Location 105 Control Building Main Control Room 161 Diesel Generator 162 Building 163 164
Fuel Handling / Auxiliary 139 Building - New Fuel Unloading Bay and Storage Areas A walkdown of these systems was conducted and it appeared that the installation of detectors was, in general, nearing completion.
However, the installation of the ionization detectors in each section of the main control board within the main control room as committed by the licensee in a letter to NRC/NRR, dated
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May 6,1985, and discussed in Section 9.5.1.6 o'/ the Vogtle Supplemental Safety Evaluation Report 1 (SSER), dated October 1985 was not complete.
These detectors have been procured by Bechtel, but the design drawings have yet to be issued for their installation.
The licensee's fire protection task force action item list is tracking completion of the design and identifies this item as Number 117. Completion of this design and installation will be reviewed during a subsequent NRC inspection.
In addition, the Vogtle SSER 1,
Section 9.5.1.6, Control Room Complex, states that an area - wide ceiling level ionization detection system is installed in the constantly manned control room.
Contrary to this commitment, the ionization detectors for the main control room are installed in the space
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above the main control room suspended ceiling. This item has been identified by the licensee through Operations Deficiency Report T-1-86-2619.
Because the present installation has not yet been fully completed and not operational or turned over to Nuclear Operations, this discrepancy is not considered a deviation.
However, these discrepancies are identified as Inspector F:llowup Item,(424/86-64-07), Fire Detection System for the Main Control Room Complex Fails to Comply with SSER 1 Commitments.
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In addition, a review was made of the installation inspection records related to the cable installations for the following local detection panels associated with the above detection systems:
Detection Panel Output signal Date Date Installation i
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Cable No.
Installed Verified i
E*1NCPFP55 ANCPFM023XY 3/10/86 3/11/86 i
E*INCPFP54 ANCPM07305 1/30/86 2/1/86 E*INCPFP15 ANCPM017XF 12/14/85 12/16/85 ANCPFM017XA 12/14/85 12/16/85 E*INCPFP50 ANCPFM038XC 12/13/85 12/15/85 ANCPFM038XH 12/13/85 12/15/85 Also, a review was made of the termination inspection records associated with the fire detection circuits for the cables listed below:
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Cable No.
Date Termination Made Date Verified ANCPFM038XH1 1/3/86 1/6/86 ANCPFM038XH2 1/13/86 1/14/86 ANCPFM038XC2 1/13/86 1/14/86 ANCPFM023XY1 4/4/86 5/21/86 ANCPM7305SA1 5/2/86 5/9/86 ANCPFM017XK1 12/31/85 1/6/86 ANCPFM017XF1 12/31/85 1/6/86 Based upon the reviews noted above, it appears that the output signal circuits for the fire detection panels reviewed had been verified by the quality engineering group for installation and termination.
The inspectors, however, noted that the input signal cable circuits from the fire detection loops were not included in the same verification program as listed for the output circuits.
The incpectors also noted that the personnel making the verifications on the output detection circuit; were not from the QA/QC organization but from the quality engineering group.
This appears to deviate from the licensee's commitment to include the fire protection program in the site QA/QC program.
This is considered another example of Deviation Item (424/86-64-05 and 425/86-30-01).
(5) Oil Collection System Each reactor coolant pump is provided with an oil collection system arranged to collect oil from any postulated leak and drain this oil into a drain tank.
A separate tank of 300 gallons capacity is provided for each pump's lubrication system.
Due to hot functional tests being performed during this inspection, the inspectors did not inspect the collection system.
However, based on a drawing review, it appears that the systems are designed to withstand the safe shutdown earthquake which meets the NRC guidelines.
The following isometric drawings and associated QC inspection records were reviewed and it was verified that the system was being installed under a QA/QC program.
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Drawing Nos.
IF4-1201-220-01 IJ4-1201-210-01 IJ4-1201-216-01 IJ4-1201-220-01
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A visual inspection of the oil collection system will be made during a subsequent NRC inspection.
Except as noted above, within the areas examined, no additional violations or deviations were identified.
7.
Licensee's Fire Protection Finalization Program The licensee's procedure, Finalization Program FP-3 (Revision 3), for performing verification that the Vogtle fire protection features are adequate as reviewed.
The inspectors suggested that a number of revisions be made to the procedure. These included the following:
Provide verification that the FSAR and fire hazards analysis conform to
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the as-built plant conditions Provide acceptance criteria for the fire detector systems based on the
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spacing and location requirements of NFPA 72E, Fire Detection System Provide verification that the fire door hardware, configuration and
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installation clearances meet the requirements of NFDA-80, Fire Doors.
Also, doors should be inspected and verified to function with the area HVAC systems in operation Provide verification that the eight hour emergency lighting units will
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provide sufficient illumination Provide verification that the structural steel fireproofing is the
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correct thickness Also, only six of the 18 inspection procedure attachments were available for review at the start of this inspection.
The licensee stated that all of verification procedures would be issued and verification program completed by late October 1986.
The above suggested revisions and incomplete procedure are identified as Inspector Followup Item (424/86-64-08), NRC Verification of Fire Protection Finalization Program Procedure Revision and Procedure Implementation, and will be reviewed during a future NRC inspection.
Within the areas examined, no violations or deviations were identified.
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