IR 05000454/1999007
| ML20207E567 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 05/28/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20207E550 | List: |
| References | |
| 50-454-99-07, 50-454-99-7, 50-455-99-07, 50-455-99-7, NUDOCS 9906070079 | |
| Download: ML20207E567 (10) | |
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U. S. NUCLEAR REGULATORY COMMISSION t
REGION til Docket Nos:
50-454;50-455 License Nos:
50-454/455-99007(DRS)
Licensee:
Commonwealth Edison Company Facility:
Byron Generating Station, Units 1 and 2 Location:
- 4450 N. German Church Road I
Byron,IL 61010 i
Dates:
May 17-20,1999 Inspector:
D. Chyu, Reactor Engineer Approved by:
Ronald Gardner, Chief, j
Electrical Engineering Branch j
Division of Reactor Safety
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i 9906070079 990528 PDR ADOCK 05000454 G
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EXECUTIVE SUMMARY Byron Generating Station Units 1 and 2 NRC Inspection Report 50-454/99007(DRS); 50-455/09007(DRS)
This inspection reviewed the fire protection program, an aspect of Plant Support. This was an announced inspection conducted by one regionalinspector. The following strengths and weaknesses were identifiad:
Minimal amounts of combustible material were noted in the plant and the material
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condition of most fire protection equipment appeared to be good. The fire brigade tumout gear appeared to be well controlled (Section F2).
The inspector concluded that the fire protection procedures reviewed provided adequate
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fire protection controls and were adequately implemented by station personnel. In addition, the licensee was pro-active in identifying problems with fire protection surveillance procedures (Section F3).
The inspector concluded the training for fire brigade members was acceptable. The
requirements for drill participation and medical examination were met (Section F5).
n The fire protection self-assessment was thorough and comprehensive. The self-
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assessment utilized lessons learned from other NRC conducted fire protection inspections at other sites. The licensee also used IPEEE data to select areas for plant walkdowns and used a recently published information notice to evaluate surveillance practices for testing deluge systems (Section F7).
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Report Details IV. Plant Support F2 Status of Fire Protection Facilities and Equipment a.
Insoection Scope -
The inspector toured areas of the turbine and auxiliary buildings to observe the adequacy and control of combustibles, dampers, fire doors, hose stations, detection equipment, extinguishers, sprinkler systems, emergency lights, and housekeeping. The inspector also reviewed the fire protection features as described in applicable safety evaluation reports (SERs) and verified the installation of these fire protection features in several risk sensitive areas.
b.
Observations and Findinas Minimal amounts of combustible material were noted in the plant. The general housekeeping was good. Based on the licensee's IPEEE submittal report, dated December 1996, the core damage frequency (CDF) resulting from fire scenarios was 3.1E-06 per reactor-year for Unit 1 and 3.0E-06 for Unit 2. The inspector reviewed and toured some the following risk-sensitive areas:
Unit 1 cable tunnel, Fire Zone 3.1-1 (18% of Unit 1 fire CDF)
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Unit 2 cable tunnel, Fire Zone 3.1-2 (12% of Unit 2 fire CDF)
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Unit 2 upper cable spreading room, Fire Zone 3.3B-2 (25% of Unit 2 fire CDF)
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Division 214Kv switchgear room, Fire Zone 5.2-2 (10% of Unit 2 fire CDF)
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Units 1 and 2 auxiliary building 346 feet elevation, Fire Zone 11.2-0 (17% of Unit
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1 fire CDF and 14% of Unit 2 fire CDF)
Units 1 and 2 auxiliary building 426 feet elevation, Fire Zone 11.6-0 (16% of Unit i
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1 fire CDF and 16% of Unit 2 fire CDF)
Laundry room, Fire Zone 11.6C-0 (10% of Unit 1 fire CDF)
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The inspector verified that fire protection features as stated in the SER and supplements were installed in various areas in the reactor and auxiliary buildings, in addition, the licensee had sufficient masks and breathing bottles onsite and had installed a manual backup CO extinguishing system in the lower cable spreading room fire zones as
committed in the SER and Supplement 5. In addition, the pre-fire plan was verified to include the use of this backup capability No hardware deficiencies were noted. The material condition of most fire protection equipment appeared to be good. The fire brigade dress-out areas contained proper turnout gear and appeared to be well controlled.
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Conclusion Minimal amounts of combustible material were noted in the plant and the material condition of most fire protection equipment appeared to be good. The fire brigade turnout gear appeared to be well controlled.
F3 Fire Protection Procedures and Documentation a.
Inspection Scop _g The. inspector reviewed the following procedures:
BHP 4200-19, " Battery Operated Appendix R Emergency Light Units 18 Month
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Inspection," Revision 12.
OBOSR FP-Q1, " Unit Common Quarterly Deluge System Visual Inspection and
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Main Drain Test Surveillance," Revision 1.
1BHSR FP-3," Surveillance for Fire Protection Turbine Bearings Suppression
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Zone 1S-29," Revisioni.
Calculation No. ATD-0391," Evaluation to Establish Byron CV and SX Pump j
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Cubicle Cooler Electrical Cables are not required for safe shutdown of the reactor under 10 CFR 50, Appendix R," Revision 1.
BAP 1100-16, " Administrative Control for Required Fire / Flood Watch
Inspections," Revision 6.
BAP 1100-7, " Fire Prevention for Transient Combustibles," Revision 10.
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BAP 1100-9," Controls, Use, and Storage Flammable and Combustible Liquids
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and Aerosols," Revision 6.
BAP 1100-20, * Fire Prevention When Welding, Cutting and Grinding,"
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Revision 14.
BAP 1100-10. " Response Procedure for Fire," Revision 2.
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OBVSR 10.g.6-1, * Fire Barrier Penetration Visual Inspection 18 Month
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Surveillance," Revision 1.
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Observations and Findinas Emeraency Liaht Batterv Surveillance The inspector reviewed completed data sheets for 8-hour discharge tests of all emergency lights during the last cycle and identified that on four occasions the test duration for certain batteries was not fully 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. When questioned, the licensee was able to locate the PIFs generated for these incidents. The inspector considered that the surveillance procedure for emergency light battery tests received adequate review and problems were properly documented. In all cases, the operability of the battery was not affected.
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Surveillance Procedure for Deluae System National Fire Protection Association (NFPA) 15-1982 stated that flow tests of open head i
spray systems shall be made at least every five years or more frequently, as determined from experience. In addition, it stated that control valves and automatic detection equipment shall be tested at least annually by qualified personnel. However, in reviewing procedures OBOSR FP-Q1 and 1BHSR FP-3, the inspector did not identify that certain deluge control valves were tested. When questioned, the licensee indicated that this problem was identified when reviewing Information Notice (IN) 99-07, " Failed Fire Protection Deluge Valves and Potential Testing Deficiencies in Preaction Sprinkler Systems," and PIF B1999-01833 was initiated on May 13,1999. Currently, there was no testing of the deluge control valves for turbine bearings, turbine seal oil skid, and turbine oil storage tank areas. The inspector considered that the licensee responded properly to the information contained in IN 99-07 and documented the problem appropriately. The licensee is currently evaluating this issue to determine whether testing is required and a generic resolution for all Comed facilities.
i Operator Actions Durina Post-Fire Safe Shutdown Conditions The safe shutdown analysis (SSA) for Fire Zone 11.6-0 on Unit 2 stated that auxiliary building HVAC supply and exhaust fans B and D could be operated from the control room. The licensee stated that the fans were needed where the cubicle coolers for essential service water (SX) pumps and charging pumps were not credited for post-fire safe shutdown operations. The operators were required to start these fans within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> before the temperature limits were exceeded in accordance with Calculation No. ATD-0391, Rev 1. The inspector noted that the actions to start the fans were not prescribed -in emergency procedures and questioned the time needed to complete necessary operator actions. The licensee indicated that the actions to restore the fans were prescribed in annunciator procedures associated with the auxiliary building ventilation system; however, the ability to meet the time limit of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> could not be positively verified. The licensee committed to revise several fire protection related annunciator procedures for fire zones where auxiliary building ventilation was credited for pump cubicle cooling purposes. The procedures would require verification and start of the auxiliary building fans or the room coolers related to the pump cubicles within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The inspector considered the corrective action acceptable.
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Conclusion The inspector concluded that the fire protection procedures reviewed provided adequate fire protection controls and were adequately implemented by station personnel. In addition, the licensee was pro-active in identifying problems with fire protection surveillance procedures. One concern was identified where the time limit of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to start the auxiliary building supply and exhaust fans, as assumed in an engineering calculation, could not be positively demonstrated and verified for post-fire safe shutdown actions.
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Fire Protaction' Staff Training and Qualification a.
Insoection Scope
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The inspector interviewed the fire marshall and reviewed the outlines for fire brigade member training and fire drill critique sheets for the last four quarters, b-
' Observations and Findinas
. The fire brigade members mainly consisted of non-licensed operators. The initial training consisted of five-day classroom and hands-on exercises utilizing fire protection
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equipment. : The brigade leaders also receive additional classroom training on fire fighting strategies and tactics. ' Prior to 1998, the classroom and hands-on training was administered by the local fire department. After 1998, the classroom training was given onsite and the hands-on training was given at another Comed facility. In either case, the
. training outlines were the same as described in procedure BTP 300-12 " Fire Brigade Training," Revision 5. The contents of the initial training would be repeated in quarterly training sessions over a period of two years. The inspectors considered the contents of the training sessions to be acceptable.
. On a quarterly basis, the fire marshall informs the local fire department of announced fire drills to be conducted in that quarter, it was up to the discretion of the local fire
~ department whether to participate in these announced fire drills. However,' the local fire department had not formerly participated in a fire drill onsite in 1998. The licensee.
' frequently conducted plant tours for the local fire department personnel. In addition, the fire department conducted vertical rescue training at Byron station and had responded to
' the site on average 20 times per year for various non-fire emergencies. Due to recent changes in training schedules in the fire department, there was a plan being made to conduct a fire drill with the fire department in 1999. The inspector considered this to be acceptable.
The inspector reviewed the fire brigade drill records for the last four quarters and verified
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Each shift had performed the required unannounced and back shift drills.
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Only fire brigade members responding in turnout gear were credited as having participated in fire drills.
The inspector also reviewed the physical examination due dates for the brigade members. The timeliness requirements for the annual examination were met.
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Conclusion
- The inspector concluded that the training for fire brigade members was acceptable. The requirements for drill participation and medical examinations were met.
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F7 Quality Assurance in Fire Protection Activities The inspector reviewed Byron site quality verification (SQV) fire protection audit report QAA 06-96-01 and QAA 06-97-02, Comed nuclear generating group (NGG) fire protection program audit report Comed-98-01, and Byron station fire protection self-assessment report DG99-000498.
The fire protection self-assessment was performed from April 26 to May 7,1999. The
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audit scope contained 13 areas and the report contained several substantive findings.
The report utilized lessons learned from other NRC conducted fire protection inspections at other sites. The licensee also used IPEEE data to select areas for plant walkdown and useo a recently published information notice to evaluate surveillance practices for testing deluge systems. The inspector considered this self-assessment activity to be thorough and comprehensive.
F8 Miscellaneous Fire Protection Issues F8.1 - (Closed) Violation 50-454/455-98004-0_l: Failure to perform annual review of pre-fire plans. Due to a lack of attention to detail, the fire marshall did not sign and date the annual review sheet when reviewing the pre-fire plan. This Severity Level IV violation was issued prior to the implementation of the NRC's new policy for treatment of Severity Level IV violations contained in Appendix C of the Enforcement Policy. This violation would have been treated as a Non-Cited Violation under the new policy and therefore it is closed in this report. This violation is in the licensee's corrective action program as i
PlF B1998-01089.
F8.2 (Closed) Violation 50-454/455-98004-08: Some fire brigade members did not have the annual physical examinations whose results were used to assess their qualifications for unrestricted activity on the fire brigade. This Severity Level IV violation was issued prior to the implementation of the NRC's new policy for treatment of Severity Level IV violations contained in Appendix C of the Enforcement Policy. This violation would have been treated as a Non-Cited Violation under the new policy and therefore it is closed in this report. This violation is in the licensee's corrective action program as PlF B1998-01089.
V. Manaaement Meetinos X1 Exit Meeting Summary The inspector presented the inspection results to the members of licensee management at the conclusion of the inspection on May 20,1999. The licensee acknowledged the findings
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The inspectors asked the licensee whether any material examined during the inspection should be considered proprietary. No proprietary information was identified.
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l PARTIAL LIST OF PERSONS CONTACTED Licensee
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B. Adams Regulatory Assurance Manager S. Chingo Fire Protection, Comed R. Colglazier NRC Coordinator j
B. Levis Site Vice President D. Popkins Operations Specialist D. Roberts Fire Protection, Comed D. Robinson Design Engineering R. Scheidecker Fire Marshall NRC B. Kemker Resident inspector T. Tongue Project Engineer INSPECTION PROCEDURES USED IP 64704 Fire protection IP 92701 Followup
ITEMS OPENED, CLOSED, AND DISCUSSED J
Closed 50-454/455-98004-07 VIO Failure to perform annual review of pre-fire plans.
50-454/455-98004-08 VIO Some fire brigade members did not have an annual physical examination
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d LIST OF ACRONYMS USED i
- BAP.
Byron Administrative Procedure j
' CDF Core Damage Frequency
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CFR Code of Federal Regulation Comed Commonwealth Edison DRS Division of Reactor Safety HVAC Heating, Ventilation, and Air Conditioning IN information Notice IPEEE Individual Plant Examination-Extemal Event NFPA National Fire Protection Association NGG-Nuclear Generating Group PIF Problem Identification Form QA'
Quality Assurance SER Safety Evaluation Report SQV Site Quality Verification SX Essential Service Water VIO Violation i
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LIST OF DOCUMENTS REVIEWED BHP 4200-19, " Battery Operated Appendix R Emergency Light Units 18 Month
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inspection," Revision 12, dated September 26,1994.
BHP 4200-13," Installation of Appendix R Emergency Cable," Revision 8, dated
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March 27,1993.
BTP 300-12. " Fire Brigade Training," Revision 5, dated May 15,1998.
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OBOSR FP-Oi," Unit Common Quarterly Deluge System Visual Inspection and Main
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Drain Test Surveillance," Revision 1, dated August 14,1998.
1BHSR FP-3, " Surveillance for Fire Protection Turbine Bearings Suppression Zone
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1S-29," Revision 1, dated December 9,1998.
Calculation No. ATD-0391. " Evaluation to establish Byron CV and SX pump cubicle
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cooler, electrical cables are not required for safe shutdown of the reactor under 10 CFR 50, Appendix R," Revision 1, dated May 18,1995.
BAP 1100-16, " Administrative Control for Required Fire / Flood Watch inspections,"
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Revision 6, dated January 7,1999.
BAP 1100-7, " Fire Prevention for Transient Combustibles," Revision 10, dated
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February 9,1999.
BAP 1100-9, " Controls, Use, and Storage Flammable and Combustible Liquids and
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Aerosols," Revision 6, dated February 9,1999.
BAP 1100-20, " Fire Prevention When Welding, Cutting and Grinding," Revision 14, dated
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November 2,1998.
BAP 1100-10. " Response Procedure for Fire," Revision 2, dated November 2,1998.
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BAR 1PM09J-D17, " Automatic Suppression," Revision 1, dated March 31,1997.
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OBVSR 10.g.6-1, " Fire Barrier Penetration Visual inspection 18 Month Surveillance,"
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Revision 1, daied October 16,1998.
OBMSR FP-4A, Portable Fire Extinguishing Annual Maintenance / Inspection," Revision 1,
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dated November 11,1998.
Byron Station IPEEE Submittal Report dated December 1996.
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Site Quality Verification Audit of Fire Protection QAA 06-96-01, dated February 8,1996
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Byron Site Quality Verification Audit of Fire Protection QAA 06-97-02, dated January 31,
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1997.
Comed Fire Protection Program Audit Report Comed-98-01, dated March 3,1998.
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Audit Checklist and Record Sheet for Audit CE-98-01, dated January 5,1998.
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Byron Station Fire Protection Self-Assessment, DG99-000498, dated May 10,1999.
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