IR 05000445/1989069
| ML19327B950 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/02/1989 |
| From: | Clay Johnson, Murphy M, Singh A, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19327B949 | List: |
| References | |
| 50-445-89-69, 50-446-89-69, NUDOCS 8911140252 | |
| Download: ML19327B950 (11) | |
Text
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i.. . . > U.S. NUCLEAR REGULATORY COMMISSION - %v" . ' ' > > s m7, a: . REGION IV- ' ~ ' t '
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' " .', > - c ' . JNRCInspectionRSport: 50-445/89-69-Construction Permits: CPPR-126 i . .s 1. # j 50-446/89-69 ' ' CPPR-127 .. ' < . J.
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- 50-446.
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. " . . , ,, Licensee: _ , ~' ' ' TU Electric.'
, ' - , , . Skyway, Tower . '400 North:. Olive. L.B. 81 ' Dallas, Texas.:75201 ' ' , ' ' . + .. . 'e .. -l ,H, JFacility:Name:,ComanchePeakSteamElectricStation(CPSES) , ,
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LInspection'At:L CPSES, Glen Rose, Somervell County, Texas t , Inspection Conducted: October 2-6. 1989 ' - i - . m ;i.
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, ., . - , . Inspectors: AL, a4 K M N d d In M ' , ' ' A. 31ngh, WQctor IMspector, Plant Systems Date . ~"'
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, LSect1on,' Division of Reactor Safety (Team-W " - Leader) . ! ' ( . . -,. Oi-d' //(/2 89.
r , ' YX, blij gWL ' . , ~ ' ' 7' ([. E.f Jo son,: Reactor Inspector, Plant Date Syst 'Section Division of, Reactor. Safety " -
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pg fjv% '// 2, ff % [ . , , . M # phy, Reactor Inspector, Test Programs: Date.
- S[ct16n, Division of Reactor Safety
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t 1JAccompanying 3, ' C Personnel: ' Thomas A; Storey, Science Applications International ,: ' , . Corporation (SAIC).
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. //!2 N . ' Approvedi C M '- _ (T. (F. 5%tka, Chief, Plant Systems Section Date J '"
-. , Divisich of Reactor Safety '* 4- ) .., - l - ' il '
, - , 8911140252 891102 ADOCK0500g5 ' PDR a , %. ' ' ' - . ' ' \\ l l
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, , 9% I'nspection Summary i- ' (t ! nspection Conducted October 2-6', 1989 (Report'50-445/89-69) ' I t , .,. . - i - Areas Inspected:.Special., announced inspection of the implementation of the Branch Technical Position'(BTP)pliance with the commitments to Appendix A of fire protection program and com a . l d ~ Auxiliary Power Conversion Systems
Branch (APCSB) 9.5-1 as approved through. Supplement 21 to the Safety Evaluation ' , Report (SER).
In addition,'a physical verification of the commitments was.
, ' performed.
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Results:. The. inspection verified.that the licensee.has maintained overall an , effective fire protection program.
Items requiring licensee's' action as ,.. m ~ ! approved and committeo through.Suppleaent 21 to the SER were found to be v.: - " completed and concerns resolved The' thoroughness and detail of the technical
. , evaluations to support the fire protection program-are considered to be a
strength. Also,' the fire brigade. training program was found to-be thorough and m* comprehensive and adds to.the strength ofcthe fire protection program.
'y' Inspection Conducted' October 2-6, 1989 (Report 50-446/89-69) . Areas Inspected:: No inspection of Unit 2 was conducted.
F Results: Not. applicable.
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-34 ( .,. Q? . ' ' ' , , R'~ . . < .. DETAILS - l , , - , e.1.
Persons' Contacted .,, I;, .. .
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L 'TU Electric , . , ,
- T, A. Hope. Senior: Nuclear Licensing Engineer
' +J. A. Seawright.: Corporate. Licensing !
. W. F.. Grace, Safety Services Manager, Nuclear Operations
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- P. -D. Stewart Operations Fire' Protection Supervisor
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- R.'D. Walker, Nanager, Nuclear Licensing
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- Si Palmer, Stirulation Manager
' , L*W.:G. Guldemond, Manager, Site Licensing ' ,;K" .*W. O. Porter,: Operations Support Engineer - ,' .' '*P. B. Stevens Manager of Operations Support Engineering '
- M..~R.1Blevins, Manager of Nuclear Operations
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- B.-T..Lancaster, Manager, Plant Support
, .*D. E. Deviney, Deputy Director, Quality Assurance
- 0. W. Lowe, Mandger
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- D.' M. Heintz, Nuclear Training
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- C.-B. Hogg, Chief Engineer
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- S. W. Swann Training Supervisor-
' - '*H. D. Bruner, Senior Vice President . -,
- W. A. Cahill, Executive.Vice President
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- K. L. ~ Anger, Fire. Protection Engineer
' - '*C.-E. Beckett,' Fire Protection Engineer . . T. Wright, Senior Engineer
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- R. 0. Babb',' Fire' Protection Engineering Supervisor
- F.tMadden,' Manager, Mechanical Engineering TL Engel, Engineer
.J. Donohue, Manager, Operations > - P. Goodwin, Senior Engineer, Operations ,., o, D. M. McAfee,' Manager, Quality Assurance '- i IMPELL Corporation ' ,
- G.' Grabruck,' Quality. Assurance
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- H. Beel, Fire Protection Engineer
- R'. L. Dible, Fire Protection Engineer
.' H. R. Beck', Fire Protection Engineer p S. D. Einbinder, Fire Protection Engineer CASE ' r . E. Ottney, Program Manager l
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- 0. Thero, Consultant i-I
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- L}J. Callan, Oirector. Division of Reactor Safety, Region"IV-
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- T. F.tStetka, Chief. Plant Systems Section
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- J.. Wiebe Senior Project, Inspector
' ' 'W. D. Johnson, Senior Resident Inspector
- Denotes those attending the exit interview conducted on October 6, 1989.-
y g , !. The inspectors also interviewed other TU Electric personnel during the ' . inspection.
7, - , % , e , l 2'. . Fglowup on Previously Ic'entified Item (92701)- ~ " ' <, U 'E (Closed)50penItem(445/8722-001): This' item concerned the ~ lack of a (seismic analysis for the reactor coolant pump-(RCP) oil collect w system , to meet the requirements of: Appendix R to.10 CFR 50 Section 111.0. During ' ' .; o this. inspection, the licensee provided the seismic analysis for, review.. .The analysis was reviewed by the inspectors and demonstrated that the RCP.
,y oil collection system;is seismically qualified. Therefore,;this item is l P' n considered to be closed.
3.
Fire Protection / Prevention Program { '
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- Introduction i , s ' , . .
A site inspection of the Comanche Peak Steam Electric Station (CPSES) L ' , for' the: Unit 1 fire protection program was conducted during . s< " October 19-23, 1987. The inspection was documented in NRC Inspection Report'(IR) 50-445/87-22. During the 87-22 inspection, the inspectors ',
reviewed the CPSES fire protection program'against the criteria of , Appendix A to BTP APCSB 9.5-1 and Appendix R to.10 CFR 50.and identified ' b,. a number of open items. An ' additional site visit was inde' on May 2-6.. , 1988, to resolve the outstanding issues'. Asia result of the evaluations- , , , l~ conduct'ed during these inspections, the NRC concluded, in the ! ' Supplement 21 to Safety' Evaluation Report-(SSER 21), that the plant's '- a fire protection program provided a. level of protection equivalent to-l- that specified in SSER 21. However, at the time of the previous , f visits, many of the' features identified in the licensee's fire ,, L protection program were not yet installed. Specifically, cable
L wrapping to meet the separation criteria of Section III.G of Appendix R eg and 8-hour battery powered emergency lights installed in accordance ' - p'a;. with Section.III.J of Appendix R had not been installed. In addition.
E other features such as fire doors and fire barrier penetration seals
. . M were only partially complete.
l: L' This inspection was conducted to ensure that those features not yet ' '- installed or completed in the previous visits will be completed in , l accordance with the previously reviewed licensee fire protection I program prior to fuel load.
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gr - -- , , . " > ^r = , ," F.quy ,, , , , . , R g.y ' ,- ' -5- . , i ' >- y; . - - s .t h [' ('. !!n addition, since the issuance of SSER 21, the licensee has
. ' ' submitted Revisions 2 and 3 to the Fire Protection Report and- " ' E +c Amendments 75 and'76'to the Final Safety Analysis Report (FSAR).
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- i f This inspection also reviewed the changes made to these documents to ensure that they did not adversely affect the level of plant safety
' ',, - or impact previous conclusions made by the NRC.. L., , - . b.1 Fire Prevention / Administrative Control Procedures , This area of Ne inspection covered review of the administrative procedures, Fire Protection Manual Procedures Fire Pre-Plans, and '
' <. Training. A list of the procedures reviewed is included in the , ' ' ' Attachment..The licensee was found to have adequate procedures.
either issued'or in draft form that comprehensively covered all - ' . , aspects of the fire prevention / protection program.
The " licensee's fire protection program for the pre-fuel load period is described in Procedure STA-722.s" Interim Fire Fict?ction Program."
This procedure covers.all aspects of a construction program and provides the requirements to support.the special nuclear materials ' ~ license for'new fuel stored in the fuel building. A draft revision . to STA-722'has been distributed for review that will implement the ' post fuel' load fire prevention / protection program. The inspectors ~ ' reviewed a sample'of the completed surveillance procedures presently' conducted under the interim program.. No problems were' identified.. Fire brigade training was found to be a strong point with good lesson plans;and a comprehensive classroom, practical' factors..and offsite - f fire academy program. The training department is responsible for . conducting the classroom training, developing, scheduling and
l !- . ' conducting fire drills; and, maintaining the training records. Fire ! ' brigade training.and drills are on a one year qualification cycle.
'[ ,- l .3o The shift supervisor is responsible for identifying the fire brigade . . ithin a given shift and receives notification of personnel qualifi- ' w . cation status on a quarterly basis from the training department.
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% Personnel qualification tracking is handled through a computer f system. One item of concern was identified by the inspectors during
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the review of Procedure TR-104, " Fire Protection Training." This ' procedure was not considered sufficiently explicit in describing what ! retesting or retraining was required of an individual who failed to , obtain the established passing level of the classroom training k ' '" examinations. The inspectors discussed this issue with licensee ' l: representatives',' and a ' revision to the procedure clearly establishing remedial action was issued. Therefore, this concern was resolved.
'The licensee has established specific training for individuals who are classified as fire watch personnel. The trained personnel may be , assigned as dedicated fire watches on each shift, while assigned as a ' !~ fire watch, no other duties.
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.o - , , at y-6- , h 'Y , ., " ' ,4 j v , Lesson plans for licensed operator training in the p'rocedure for safe ' ' ' , ,,.o shutdown of.the' plant when the control room must be abandoned f' following a fire:were reviewed by the inspectors. This was O considered a strong' point in training because it effectively covered ' .a4 refe shutdown requirements, made effective use of the simulator, p," ' - aba gluded plant walkdowns.,This training has been completed for.
p "all' presently licensed operators.
' o reviewed the' licensee's fire pre-pl.an manual. All The inspectors have been reviewed and'are in place'throughout the , fire pre-plans , n . ,F plant. The pre-plans are presently being reviewed for updating and L ' '_ revising. The licensee plans to modify the format so that-each - pre-plan will be a single sheet. This enhancement program is planned.
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- nto be complete by fuel load,
~ ' c + , >Surveillar,ce' testing,in the Technical Specifications.
is contained in the fire protection manual and.
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will not be included The inspectors b < . reviewed the administrative program and a sampling of individual ~ ' ' procedures. ' Scheduling and tracking will be monitored:by computer t , program.
Performance will be handled. by various departments with the.
, -results reviewed;and approved by engineering. The fire protection ' , ' group will have overall tracking and scheduling responsibility.
, ,, , - - , , C In SSER 21, the NRC identified a concern relative to the possibility.
~that two adjacent manholes.containing redundant shutdown cables could be subjected to a flammable. liquids fire since'the manholes are in
' close proximity to the diesel; fuel unloading area.
During this inspection.-the licensee presented procedures which cover the . - - - unloading of: diesel fuel. The licensee had modified the procedures i to ensure that both manhole covers are in place prior to diesel fuel
" unloading..The procedure was reviewed and found_to adequately a . address the. concern raised,in SSER 21. This issue is considered resolved.
Jc.. Plant Tour and Inspection of Fire protection Equipment ~ i
' " (l) Inspection of Manual Fire Fighting Equipment
The inspectors. reviewed manual hose station installations and ^- l portable extinguishers,at various locations throughout the - ' C' ' plant. sThe inspectors'also reviewed the equipment located in '- ' several hose houses. in the yard area. All of the installations . and equipment were-found to be acceptable and consistent with !
. - ' what was identified in the Fire Protection Report.
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' , O (2) Inspection of Installed Fire Protectkon Features K , ,
. The inspectors performed an inspection of the penetration seals,
! , emergency-lighting, Thermo-lag, radiant energy shields, and fire H doors. The inspection was conducted to ensure that these items l; were in the configurations as identified by the licensee in the l,. ?
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. , _ p' < , '.- [ [. ' Fire Protection Report and as approved by the NRC through - Amendment 21 to the SER. Although the type.and method of J , , ' ' % installation for each of these items were found to be acceptable, none of these items had bee.a completely;. installed at La -
the time of the inspection. Thellevels of installation as of , October 5.'1989. were as follows:
>' , , . ., r Lg' ', ' Thenno-l ag - 40 percent installed I / Radiant Energy Shield.
88' percent installed i p ,
Fire Doors 85 percent installed t Emergency Lighting 65 percent installed t ' bC Penetration. Seals 92 percent installed . , m v.
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The inspectors walked down a number of installations associated ' . with each onejof these items. The review included physically , verifying'the operability of fire doors:and emergency: lights.- c , Sample penetration-seals chosen randomly in the field were ! , -. traced back to'the qualifying fire tests. Thermo-lag and v.
' radiant energy, shield installations were checked for compliance
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' ,with' design' criteria and that the-proper cables or components a ,-
, jF were being addressed. 'Since a significan.t amount of Thermo-lag
still' required installation, the inspectorc witnessed several- ' > , , ' / ongoingsinstallation activities to' verify qualification of the '
, , ainstallers and adequacy of the quality assurance procedures'. y n3'
l- . For_those. installations of each of the separate items identified - - ~1 above, the inspectors-concluded that the installed items.were in t Lp-l a - conformance with the approved designs and as called for in the . J! ' ' 11censee's-Fire Protection Report. The inspectors also concluded . , . that appropriate controls and management oversight were in place ' to ensure the correct and proper' installation ofJthose items'not ' yet. installed. ' Schedules'1or completion of each one of these > , items prior:to fuel load was discussed with licensee management.
l ;. The'11censee committed to' complete the installation of these , items prior'to fuel load.
' (3)~~Other Plant Features' l
In SSER 21,'the NRC had approved an analysis by the licensee-I , which justified partial suppression in a ' number of plant f.1re
areas.
During this inspection, the licensee identified that the analysis was' modified for several areastto include the addition ' ' of 1-hour fire rated barriers. This analysis was reviewed by the inspectors and'was found to be an enhancement of the
previously approved analysis and therefore'was found acceptable.
3, An evaluation of control room carpeting had been previously , reviewed and accepted by the NRC. During this inspection, the licensee identified that additional carpeting of the same type , 'of fire resistance was being added in areas adjacent to tne
,
control room. The inspectors reviewed this modified evaluation and determined that the. additional installation of carpeting
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'During the inspection, th'e licensee identified that a. series of: < fire dampers, which had.bsen located in a. fire rated ] . ,f , , floor / ceiling assembly, were being replaced with a concrete ,j ' hatch.s The licens1e presented an analysis which <jemonstrated' n > ,k that the hatch, when installed, would provide an equivalent fire ' ',, iresistance rating of 3 hours. The analysis was reviewed and
t , ' . found to be acceptable, j h ' . . In SSER 21, the staff identified a concern about the fire rating ' '. m of stairwell walls.. The concern related to the lack of ~~ ' documentation by the-licensee for' gypsum wall assemblies which s comprised pat-of;the stairwell fire boundaries..In SSER 21, ' < , ,e e uthe NRC. stated that the licensee would either provide , , -documentation on:the adequacy of the walls or correct the i L - . deficiency..During thissinspection, the licensee stated that ' E . they were not able to. substantiate the construction of the.
t f'g - , l gypsum walls.and that all of the walls in, question were removed j ' 'tM and replaced with approved and documented gypsum wall ' w ' = construction. The documentation for these walls was reviewed
Jand a' field walkdown was conducted.. The inspectors concluded- - , 'G T.
that the new walls will provide the fire resistance as ? ' ' l' documented in,the Fire Protection Report and are therefore ' " ,y, acceptable., - s , m, . ..
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'The inspectors reviewed the recently. completed fire water pump d , ^s u _+, house.- The pump house was iristalled to replace the original
, ' s pumps which drew water frem the impoundment. The impoundment ". "i + '4
, . water was-found tn'cause significant pipe ~ corrosion _ problems and f ~ . i ! therefore wasLreplaced with a treated water source.~ The
. ' ' ' , inspectors reviewed the~ pump house design for code compliance & and performed a field walkdown. No discrepancies were
, , N, .? identified with the design.or installation. However, the ' licensee's design called for isolation. valves and an associated ~ % valve. lineup which would only allow for the fire pumps to take ' C s, , - - suction'from a single fire water storage tank at a' time. While . .c this approach is considered to be a conservative attempt to meet ' ^ ' tne 11teral statement in NRC guidelines which says'that no ' ' ' single failure in the fire water system should cause loss of, ' system capability, it did appear to present a potential operator ' - , problem.' The-problem relates to the fact.that with the valve " < i lineup as' identified by the licensee, and also given that the system is newly installed, if a failure were to occur, which necessitated realigning valves to allow for pumps to take , suction from the retundant tank, a significant delay might 3-result. The realigning process required four separate valves to be manipulated. This concern was discussed with the plants fire protection and operations personnel. The licensee agreed that increased operator knowledge of the system was necessary for .
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, $' ' ' 'y potential valve manipulations. A representative from operations j - ,c , presented a procedure which had recently been modified to
' y w address the very concern of fire water tank' valving. Based'on s f
this modification and the obvious awareness by plant personnel'
- < ", ~ of the potential problems this issue is considered resolved.
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Fire Drill t , , , . S The inspectors witnessed a fire brigade drill to. verify the adequacy of brigade training and equipment. The drill also involved response - , A.
by' the outside fire department.< The inspectors acknowledged that the .l fire brigade was well qualified (including fire' fighting techniques and ~ , communications and coordination with other plant personnel such as ' i those in the radiation protection and operations areas. There was
also good coordination between the'outside fire department and the ' " fire brigade.
, , " e.
The inspectors reviewed Revisions 2'and:3 to the Fire Protection , , Report and Amendments 75 and 76 to the FSAR.. The majority of changes ' in both documents were to correct typographical errors or to provide-clarification to existing evaluations or descriptions.
Recent plant + >
. changes such as the new fire water pump house were incorporated.
, Other plant modifications included the addition of a new start-up transformer and an auxiliary boiler house. The removal:of an ,
. interconnection between the fire water. system and the~ circulating , water system was alsoLidentified. The use of limited amounts'of non- _ , ,.
, 3- .IEEE-383-cable was included. The emergency diesel day tank room o suppression systems, which were converted from Open Head Water Spray n System to Closed Head Preaction System to address seismic concerns, , was also reflected in Amendment 76.
- s Each one of the modifications was reviewed with the licensee and- ~i evaluated;to ensure that they did not adversely affect' plant safety , or modify previous NRC' evaluations. The thoroughness and detailed
" ' , technical evaluations and analysis to support the fire protection ' ' program are considered to be a strength. The inspectors concluded
, that the changes made in Revisions 2 and 3'to the Fire Protection ,, .. H-Report and Amendments 75 and 76 to the FSAR were' acceptable.
' . _ ' No violations or deviations were identified in the review of the fire U protection program.
s . . s.
I '; 43. Exit ^ Interview ' I r lAn exit interview was conducted on October 6, 1989, with those personnel ' . W. denoted in paragraph 1 of(this report. At this interview, the scope of
' the inspection and findings were summarized. The applicant did not i _ , identify as proprietary /any of the information provided to, or reviewed by '
h the inspectors.
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, l' $ ATTACHMENT ' ' - ' t . f ' , I %, - , , , $O [ Procedure No.- Title Date s e vt: p.; STA-727: _ 4 ' ' Fire-Brigade- . July 12, 1988 ' " ' y Revision.0- . + , ., , STA-728 .'Sturage & Handling of' Flammable / July 12, 1988 w, c
Combustible Materials & Compressed Gases ei Revision ~0' ' i ,
^ , l. t !. < -STA-729~ Control of Transient Combustible's, July 12, 1988
1- ' Revision.0~ Ignition Sources, and Fire Watches' y y . , - . u,' FIR-101- . Fire Protection' Program: October.16, 1987- ' u + 7e cRevision 9' - ' ' , .., . - . Fire Protection Training , March.1 '1989 TRA-104- . . ' '
Revision 7 . ^ ' '. _ .- . . .. m,y.
'STA-722: Interim Fire Protection .0ctober 16,'1987, u 7] Revision 1-Progtam: e y; ' o , . FIR-108 . Fire Protection Organization December. 22,1988 ' l- , Revision 0 g . . , " L
- FIR-201 Preparation, Control, Review, and Us.e August 7, 1989'
' 1 Revision 6 of Fire Preplan Instructions '4 % 'FI'R-202 Fire Protection Inspections December 19, 1988 ,~ " Revision 0 FIR-301 ' Portable. Fire Extinguisher Inspection, March 25, 1987 - L . Revision 1-Maintenance, Recharging, and Hydrostatic ' Testing-
- FIR-302..
Fire Door Surveillance October 13, 1987 j > ..; ;;, LT ' Revision 1 ! ' '
l ; FIR-303 Halon Fire Suppression System March 15, 1988 l ,
- Revision 2
' Inspection i
, , ."' f ' FIR-304 Support' Buildings Fire Alarm Testing September 24, 1984 ')
Revision 0 i ' q v g' b $h' t .' . - i ' '
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Inspection'of. Sprinkler Systems' , ' September 25,-1989 l -
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- STA-722,
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iRevision 2' ' Fire Protection Program Draft j , , ,
, f( fr - Fire Protection Systems /E'uipment Draft; .: ~' STA 723 q -
1 - ' Revision O' ' Requirements- ' ~/, f.y. ' > - r . y' "STA-738,
> , , , ' 'Ei "L1 - Rev.ision 0 ~ l Fire Protection Systems / Impairment Draft " ' , , t
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, '( y ','m Revision 0 ' July:12, 1988 T c
- STA-724.
s Fire Reporting & Response , ' ' , x y ' ' ' ' " FIR-308: , Fire Brigade Equipment May 9, 1989 , ' Revision'0' , [(.'<, FIR-309 '..
' Hose Station and Hydrant Hose House October'4, 1989
- Inspection
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