IR 05000424/1993008
| ML20044E430 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/11/1993 |
| From: | Branch M, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20044E428 | List: |
| References | |
| 50-424-93-08, 50-424-93-8, 50-425-93-08, 50-425-93-8, NUDOCS 9305250005 | |
| Download: ML20044E430 (8) | |
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UNITED STATES
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J, NUCLEAR REGULATORY COMMisslON
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o REGION 11
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101 MARIETTA STREET N.W.
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f ATLANT A, GEORGI A 30323 l
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Report Nos.:- 50-424/93-08 and 50-425/93-08
i Licensee:
Georgia Power Company l
P. O. 1295 l
Birmingham, AL. 35201
Docket Nos.:
50-424 and 50-425 License Nos.: NPF-68 and NPF-81 Facility Name:
Vogtle Nuclear Station Units 1 and ?
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Inspection Conducted: April 19-23, 1993 Inspector:
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zu G. R. Wiseman Date Signed l
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M. W. Branch, Acting Chief D' ate Signed l
Test Programs Section
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Engineering Branch Division of Reactor Safety
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i SUMMARY
i Scope:
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This routine announced inspection was conducted to evaluate the plant's fire protection / prevention implementation program an'd to follow-up on previous inspection findings.
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Results:
Within the area examined no violations or deviations were identified.
Impr6vements were noted in the implementation of the fire protection program.
The staff was knowledgeable and had taken appropriate actions towards
resolving the violations and concerns identified during a May 1991, NRC i
inspection of the fire protection program. Overall, the fire protection-l program was considered good. The following strengths were identified.
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Strengths:
i Compliance with the plant fire prevention procedures regarding control of
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ignition sources and combustible materials during plant maintenance activities has resulted in a low number of fires during the past several years.
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9305250005 930517
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PDR ADGCK 05000424 i
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Weekly Fire Protection Status and Trending Reports to plant Department
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Managers have been an effective management tool for monitoring the i
implementation of the site fire protection program and in the identification i
of adverse impairment trends of plant fire protection features.
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I An Inspector Followup Item related to the conduct of fire brigade drills in
'I specific plant fire areas was identified (paragraph 2.d.).
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REPORT DETAILS
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1.
Persons Contacted l
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Licensee Employees t
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- D. Adams, Plant Modifications Supervisor
- J. Beasly, Assistant General Manager i
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- W. Burmeister, Manager, Engineering Support
- S. Chesnut, Manager, Technical Support
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- C. Christansen, Supervisor, (SAER)
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- G. Fredrick, Manager, Maintenance
- W. Gabbard, Nuclear Specialist
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- K. Holmes, Manager, Operations l
- W. Kitchens, Assistant General Manager
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- C. Meyer, Operations Superintendent
- G. McCarley, ISEG Supervisor l
- E. Pickett, Senior Engineer, Fire Protection
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- M. Sheibani, NSAC Supervisor i
- W. Shipman, General Manager i
- H. Williams, Nuclear Specialist, Fire Protection (
Other licensee employees contacted during this inspection included craftsmen, engineers, operators, mechanics, fire watches, security force
members, technicians, and administrative personnel.
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NRC Resident Inspector
- B. Bonser
- Attended exit interview l
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2.
Fire Protection / Prevention Program (64704)
l The inspector evaluated the adequacy and implementation of the licensee's Fire Protection Program described in the Final Safety Analysis Report i
(FSAR) Section 9.5.1 and Appendixes 9A and 9B.
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a.
Fire Protection Organization l
The Station General Manager has overall responsibility for the fire protection program. The responsibility for implementation of the fire
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protection program has been assigned to the Nuclear Specialist Fire i
Protection (NSFP) who is under the supervision of the Manager
Operations. A Fire Protection Technician (FPT) is assigned to each i
operating shift to provide on-shift fire protection technical
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assistance to the Shift Superintendent (SS). The FPT monitors the
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fire alarm control panels, establishes the compensatory actions on
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inoperable fire protection features, issues permits for control of l
ignition sources and transient combustibles, and conducts bi-weekly i
fire prevention plant inspections.
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The Nuclear Operations organization has an effective program for l
monitoring plant fire prevention and protection ineasures. Weekly fire protection status and trending reports are provided to plant
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department level management. These reports address the status of. fire protection Limiting Condition for Operation (LCO) actions, fire protection feature impairments, ongoing fire protection maintenance
activities, and fire watch activities for vital plant areas. The
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inspector's review of the 1992 and 1993 reports on fire protection
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activities indicated that maintenance for fire protection equipment
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was being performed in a timely manner, and the resulting backlog of
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open Maintenance Work Orders (MW0s) was not large. The inspector
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noted the reports had been utilized by the licensee in the t
identification of increasing impairments of plant fire doors in 1993.
l A Request for Engineering Assistance (REA), VG-3024, had been issued
in February 1993, to address, by June 1993, the appropriate
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operability requirements for specific FSAR fire doors. The inspector
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determined that these reports provided an effective management tool
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for monitoring the implementation of the site fire protection program
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and is considered a strength, i
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Fire Protection Program Implementation i
The inspector reviewed the onsite fire protection program implementing procedure, 92000-C, Revision 9, Fire Protection Program, dated
December 14, 1992, and compared it to the program description in the
FSAR. The review indicated that the fire protection program had been updated to include a description of the current fire protection
staffing organizations, their responsibilities and interfaces; fire l
brigade membership and training requirements and general personnel i
training. This effort was thorough and no discrepancies were noted.
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c.
Fire Reports L
The inspector reviewed the station fire incident reports required for
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procedure 00601-C, Fire Investigation Report Procedure, for 1991,
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1992, and 1993.
These reports indicated that there were six incidents of fire in safety-related plant areas during 1991-1992, which required
fire brigade response.
Of these, two were minor fire events involving
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cutting or welding activities associated with the Unit 1 outage and
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the remainder were fires involving electrical transformer failures.
l Thus far in 1993, there have been no reported plant fires. The low i
number of fires during the past several years indicates good overall
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compliance with the plant fire prevention procedures regarding control
of ignition sources and combustible materials during plant maintenance i
activities. This is considered a program strength.
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d.
Fire Drills i
Due to Unit 2 being in an outage and the high priority work in i
progress, a fire brigade drill was not conducted during this l
inspection. To evaluate fire brigade performance, the drill critique
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data and drill scenarios for drills conducted in 1991, 1992 and 1993
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i were reviewed by the inspector.
Based on this review, the overall
brigade response times and personnel participation for these drills J
were considered satisfactory.
Following each drill an exercise l
critique was conducted to discuss the drill, participant's
performance, and recommendations for improvements.
l The inspector did note however, that for the time period reviewed, no
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l fire brigade drills had been conducted in those plant fire areas where
'l deviations from NRC fire protection requirements had been approved.
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These areas were evaluated by the NRC in the Safety Evaluation Report I
(NUREG-ll37), Supplement 4, dated December 1986, Appendix Q, section
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2.6. The evaluation discussed seven fire areas in Unit I which do not
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have full area suppression in conformance with Section C.5.b(2)(b) of
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the Branch Technical Position, BTP CMEB 9.5.1.
The evaluation concluded that based on the existing fire protection features, the e
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absence of an automatic suppression system throughout each area was an
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acceptable deviation from the NRC requirements. The existing features l
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described included low combustible loading, separation of redundant
safe shutdown components, and an early warning fire detection system
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that would detect a fire early in its incipient stage and alarm the i
control room, where the fire brigade would be dispatched to extinguish the fire manually. The inspector discussed the exclusion of these
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areas from the fire drill scope with the licensee. The licensee indicated that enhancement of the fire drill program to include fire
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brigade drill exercises in these fire areas would be evaluated. This
is identified as Inspector Followup Item 424/93-08-01, Conduct of Fire Drill Exercises in Fire Areas Where Deviations from NRC Fire Protection Requirements Were Approved.
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Fire Watches i
The inspector observed the performance of several fire watches
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provided to compensate for inoperable fire barrier's as a result of
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NRC Bulletin 92-01 addressing Thermo-Lag 330 material issues. The
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fire watches were attentive to their fire watch responsibilities and l
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knowledgeable of their duties and the locations of communication
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equipment to rapidly report a fire situation should it have occurred.
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The inspector also reviewed a closed circuit television and camera i
system used to monitor affected Thermo-Lag installations in the locked
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high radiation Residual Heat Removal (RHR) Heat Exchanger Rooms for l
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each unit. The inspector questioned the limited monitored area of
j coverage for the upper grated platform elevation provided by this j
j system. Walkdown of the area indicated that the camera position was j
acceptable due to the room configuration and large obstructions in the
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upper elevations of the room. The licensee also plans to supplement i
the camera monitors with an on-shift FPT turnover item to review shift i
activities to be conducted in the lower areas of the rooms to identify
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any potential fire sources. This indicated that the licensee was l
sensitive to ongoing plant conditions in the affected areas and was
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considered acceptable.
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3.
Fire Protection Quality Assurance Audits The inspector reviewed the following recent quality assurance annual and triennial fire protection program audits required by FSAR section 9.5.1.1.4:
l Audit No. OP20-93/04, QA Audit of Fire Protection
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Programmatic Controls, dated March 16, 1993
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Audit No. OP20-92/27, Triennial / Annual Fire Protection and Inspection Audit, dated July 31, 1992 In general, the fire protection QA audits were thorough and identified several problems related to fire protection surveillance for fire barrier penetration seals, fire doors, and fire suppression and detection systems. The licensee had initiated corrective actions to resolve the findings identified by these audits, however, these have not yet been fully implemented.
The 1992 Triennial Audit was performed by an audit team that consisted of four auditors from Southern Company Services (SCS), Southern Nuclear Operating Company (SNC), and a technical consultant Fire Protection Specialist from Bechtel. The inspector questioned the use of the licensee's corporate engineering office and the contract A&E firm for Vogtle Station as related to the independence of the auditing agents as defined in NRC Generic Letter 82-21 guidance. The guidance explains that the independent auditors are those who do not have direct responsibility for the program being audited and the three-year audit must be performed by an outside independent (non-utility personnel) fire protection consultant.
The licensee explained their position in an interoffice letter dated December 11, 1992, provided to resolve a similar NRC concern at Hatch Station in NRC Inspection 91-30. The letter interprets the licensee's position that neither SCS or Bechtel engineers are licensees, owners, or employees of the current licensee utilities, thus, are acceptable organizations to perform the triennial audits.
Following the inspection, the inspector reviewed this area with responsible NRR and Regional personnel who agreed that the source of auditors used for the triennial fire protection audits at Vogtle Station would be considered independent and are acceptable.
4.
Observation of Plant Areas A general plant walkdown inspection was performed by the inspector to verify: acceptable housekeeping; compliance with the plant's fire prevention procedures such as " Hot Work" permits and transient combustibles; operability of the fire detection and suppression systems; emergency lighting; and, installation and operability of fire barriers, fire stop and penetration seals (fire doors, dampers, electrical penetration seals, etc.).
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Within the areas observed, the inspectors determined that the general housekeeping was satisfactory, considering that one unit was in an l
outage and maintenance and repair activities have been ongoing. The
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majority of the wood used during outage activities was treated.to make
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it fire retardant.
Fire retardant plastic sheeting and film materials were also being used.
Lubricants and oils were properly. stored in
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approved safety containers. Appropriate controls for cutting and
j welding operations were being enforced. No major discrepancies were
noted with the fire pumps, outside fire hose houses, fire main valves i
or headers. Controls were being maintained for transient combustibles
and areas containing potential lubrication of. and diesel fuel leaks, such as the~ diesel generator rooms, were being controlled.
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5.
S Follow-up on Previous Inspection Findings (92701 and 92702)
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(Close) Violation 424,425/91-10-01:
Failure to Implement the
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Approved Fire Protection Program: This violation involved three examples of failures to meet the conditions of the
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operating license. These examples included: 1) the failure to install a fire barrier penetration seal, 2) use of uncalibrated
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gauges for testing the fire pumps, and 3) the failure to i
maintain the backup power supply to automatic sprinkler
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systems.
The licensee responded to this violation on July 12, l
1991.
Each example is discussed below.
j (1) The licensee sealed fire barrier penetration 2-11-0244A between fire areas 2-CB-LA-T and 2-CB-LA-I.
The inspector
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reviewed MWO No. 29101799 and As Built Notice (ABN) No.
j 04091 which sealed the penetration and revised plant i
drawing AX1D94A20, revision 7, to indicate the penetration
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with a three-hour seal designation. The inspector visually inspected the penetration on April 22, 1993, and
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verified the seal was in-place on both sides of the penetration.
(2) The licensee developed procedural guidance specifying calibrated instrumentation for fire pump tests. The
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J inspector reviewed Procedures 14951-C, revision 3, and i
14952-C, revision 1, and verified that they were revised i
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to require calibrated test gauges and flow devices to be
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used for fire pump tests.
The inspector also verified
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that equipment maintenance checklists were updated in June
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1991, to include the fire pump tests instrumentation into the regular scheduled calibration database of the
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preventative maintenance program.
(3) The licensee's response indicated that whenever a degraded fire detection system battery is suspected, the panel will be declared inoperable and compensatory actions will be
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taken. The inspector verified that Procedure 92040-C, j
revision 4, sections 4.9.1 and 4.9.3 were revised to
define LCO conditions and compensatory actions required
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6 upon the receipt of fire detections systems alarm panel trouble condition annunciations.
The actions described above were acceptable and this item is closed.
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(Close)
Inspector Follow-up Item 425/91-10-02: Unit 2 Halon System not Included in Operability Requirements of FSAR Section
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9.5.1: Licensing Document Change Request FS91-028, was reviewed and approved by the Plant Review Board (PRB) on August 23, 1991, (Meeting No. 91-70). This change implemented a revision to the FSAR Table 9.5.1-10, sheets 6 and 7 to add Unit 2 Halon Systems for the remote shutdown panel rooms to the operability requirements. The inspector verified that the change was implemented in Revision 3 to the FSAR dated December l
1992.
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The actions described above were acceptable and this item is closed.
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6.
Exit Interview The inspection scope and findings were summarized on April 23, 1993, with those persons indicated in paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection results.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
Item Number Description and Reference (0 pen) 424/93-08-01 Inspector Followup Item:
Conduct of Fire Drill Exercises in Fire Areas Where Deviations from NRC Fire Protection Requirements Were Approved-paragraph 2.d (Closed) 424, 425/91-10-01 Failure to Implement the Approved r:re Protection Program (Closed) 425/91-10-02 Unit 2 Halon System not included in Operability Requirements of FSAR Section 9.5.1
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