IR 05000483/1987018
| ML20236B638 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/15/1987 |
| From: | Gardner R, Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236B608 | List: |
| References | |
| 50-483-87-18, NUDOCS 8707290180 | |
| Download: ML20236B638 (11) | |
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U. S. NUCLEAR REGULATORY COMMISSION I
REGION III
l Report No. 50-483/87018(DRS)
Docket No. 50-483 License No. NPF-30 Licensee: The Union Electric Company I
Post Offica Box 149 St. Louis, M0 63166 Facility Name:
Callaway Plant, Unit 1 Inspection At:
Callaway Site, Callaway County, Missouri Inspection Conducted:
June 1-5, and June 29, 1987 btAh-
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h Inspector:
Joseph M. Ulie 7 /
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l Date Mk-
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Approved By:
Ronald N. Gardner, Chief 7//f d7 Plant Systems Section Date j
l Inspection Summag Inspection on June 1-5, and June 29, 1987 (Report No. 50-483/87018(DRS))
Areas Inspected:
Routine, unannounced inspection of licensee action on previous inspection findings, fire. protection organization, fire brigade
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drill, administrative controls, fire protection system inspection, maintenance j
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l and test program, fire barrier penetrations, Quality Assurance, review of l
selected Information Notices, and Raychem splices (30703, 64704, 92700,
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l 92701).
Results: Of the nine areas inspected, no violations were identified in I
eight areas; one violation (failure to cycle three critical fire suppression water system isolation valves - Paragraph 6) was identified in the remaining area.
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8707290180 870715 PDR ADOCK 05000483
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' DETAILS
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Person's Con'tacted
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- R. Allen, Safety Supervisor.
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- J. Blosser, Manager, Callawayl Plant
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L*D. Brueggeman, Quality Assurance Engineer
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'*D,-Capone,' Manager - Nuclear Engineering
D. Clause 1,.~ Assistant Safety Supervisor D. Cornwell', Nuclear Electrical. Mechanic L.':Crain, Safety Coordinator
- J. Davis, Superintendent, Compliance A. Durr, Nuclear Electrical Mechanic-S. Frank, Co-Op. Engineer.
- J. Gearhart, Superintendent',. Quality' Assurance
- L. - Kanuckel, Supervising Engineer - Quality Assurance Program Section
- J. Knaup, Compliance Engineer.
- J. Laux,: Superintendent, Technical _ Support q
- C. Naslund, Manager, Operations Support'
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- J. Peevy, Assistant Manager,. Technical Services
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- G. Randolph, General Manager, Nuclear Operations
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- W. Robinson, Superintendent, Instrumentation and Control
- R. Roselius, Superintendent, Health Physics
- 0. Seets, Quality Assurance Engineer,
'*T. Sharkey, Supervisor Compliance
- B. Stanfield, Quality Assurance Engineer J. Williams, Equipment Operator-C. Wohlers, Rad Chem Foreman
- G. Woods, Safety Coordinator i
The inspector also contacted other licensee personnel during the inspection visit.
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- Denotes persons attending'the exit interview of June 5,-1987.
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Action Taken on Previous Inspection Findings
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I a.
(Closed) Unresolved Item (483/85007-01(DRS)):
An NRC. inspector j
raised a general concern regarding closure surveillance testing of i
normally closed check valves..Of the 225 check valves addressed,
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thirteen (13) were fire protection system check valves.. Originally,
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the inspector requested the licensee to perform a review of the
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identified check valves for their required closure test requirements.
j This review was conducted and the inspector. closed the majority of
this item in Inspection Report 483/86020.
During this inspection, the inspector concentrated on the 13 fire protection check valves,
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According to the licensee's staff, a review of the National Fire Codes did not identify any specific code guidelines covering fire protection check valves.
However, the licensee's staff indicated that during performance of TS surveillance, the. fire protection-
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cueck ' valves are routinely exercised during those surveillance requiring water flow conditions.
As a result, this portion of the item is considered closed.
No violations or. deviations were identified during review of this unresolved item.
3.
Fire Protection Organization The inspector examined the qualifications of certain licensee fire protection staff including the Safety Supervisor, a Safety Coordinator, and personnel performing fire watch duties.
During this review the licensee provided the inspector with resumes and other qualification type information in regards to the Safety Supervisor and Safety Coordinator.
The Safety Supervisor is a degreed Fire Protection Engineer and Registered Professional Engineer who has attained a." Member" grade in the Society of Fire Protection Engineers.
The Safety Coordinator (Fire Brigade Instructc1 has undergraduate degrees in i
Education and Fire Science and has served actively as a Fire Service Officer.
Each of these individuals demonstrated an ability to apply their j
fire protection knowledge during discussions with the inspector and I
responded appropriately during these discussions.
l In addition, during tours of safety-related areas of the plant, the inspector observed and interviewed four fire watch personnet performing hourly and continuous patrol duties in which one of the fire watch personnel was in place during grinding and welding activities.
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inspector determined, after discussions with each of these individuals,
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that they were adequately trained and knowledgeable.
The individuals were able to talk-through the required emergency actions which they would take upon spotting a fire.
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No violations or deviations were identified during review of this area.
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4.
Fire Brigade Drill
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During this inspection visit, the Regional based inspector witnessed a i
fire brigade drill (referred to as Mini-Scenario No. 6) during the emergency exercise on June 3, 1987.
Due to the already preplanned emergency exercise fire drill (as reviewed by the NRC Emergency Preparedness Section), the inspector, so as not to overly burden the
licensee's staff, witnessed this preplanned fire drill instead of requesting an additional fire drill be conducted.
The drill postulated a technician transporting, by vehicle, a Steam Generator (S/G) sample to the Emergency Operations Facility (E0F) losing control of the vehicle and
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resulting in the vehicle catching fire (live fire).
The inspector j
observed the fire brigade to determine the adequacy of'firefighting techniques; type, placement, and use of equipment; brigade composition;.
timeliness of brigade actions; assessment of the brigade leader's
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direction; and the fire brigade interface with the radiation protection personnel so as to determine overall fire brigade effectiveness during a fire emergency which may involve potential raciation hazards.
The inspector observed five members of the fire brigade assemble at the non-radiologically controlled area brigade station and followed the actions taken by those brigade members until extinguishment of the live fire was complete.
As a result, the inspector provided the following observations during the post-drill critique discussions:
a.
Positive Observations The fire brigade leader was thorough in making sure that the
appropriate firefighting equipment was brought from the brigade station to the' fire scene.
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Communications interface between radiation protection personnel j
and the fire brigade was good.
Enroute to the fire scene the brigade leader debriefed the
other brigade members on the known information concerning the emergency, The fire brigade approached the fire from the proper direction
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based on prevailing meteorological conditions.
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Areas Needing Improvement The actions taken during the donning of the fire brigade
protective clothing and gathering of the firefighting equipment at the brigade station could have been done in a more organized and timely manner.
The amount of time spent setting up for extinguishment of the
fire (from the time the fire brigade arrived on the fire scene to the time'that water was applied on the fire) could have been reduced by improved brigade leader direction and communication to the fire brigade members of their assigned duties.
Although communications between the radiation protection
personnel and the fire brigade was good, one fire brigade member still walked through the designated contamination area that was identified by the radiation protection individual.
The inspector made mention that other licensees' rope or tape off those areas designated as contaminated so as to make positive assurance that personnel are aware of the' prohibited area (s).
The three observations made regarding improvement being needed are considered an Open Item (483/87018-01) pending NRC witnessing of l
l additional unannounced fire drill (s) and the determination of their
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l adequacy.
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Ij Discussions held between the resident.and regional inspector l
regarding fire l brigade drills indicated.that previously witnessed'
l fire drills by the resident. inspection-staff had shown the fire j
' brigade ' actions at those drills to have'been done in a timely and q
orderly manner.
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' No violations.or deviations were identified during the witnessing of.
' this fire brigade drill.
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5.
Administrative Controls
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The inspector examined, in part, the licensee's fire protection
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administrative control procedures and implementation of these procedures j
while performing plant tours on June 1, 2, and 4, 1987. 'The procedures j
reviewed included:.(1). Administrative Procedure (APA) No. APA-ZZ-00370,
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General Plant Housekeeping, Revision 8, dated August 22,.1986; q
(2)
APA-ZZ-00741, Control and Transportation of Combustible Materials, j
Revision'4, dated November 26, 1985; and (3) APA-ZZ-00742, Control of
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- Ignition Sources, Revision 4, dated March 10, 1986.
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j The inspector's review of thes'e procedures determined they were generally
well written so as to minimize the amount of combustibles that a safety
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related area may be exposed to.
The implementation of these procedures
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will also afford protection.to safety-related equipment from fire damage resulting from work involving ignition sources.
In addition, these procedures prohibited the use of open flames and prohibited smoking'in the radiologically controlled area having certain areas designated for smoking purposes.
During a tour of the plant on June 1, 1987, the inspector, accompanied by the Safety Supervisor, observed that the
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implementation of these procedures was being satisfactorily maintained.
However, the MSIV room was observed to contain'two partially filled j
anti-contamination plastic bag containers and wooden scaf folding.
No
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work activity was observed in progress at'the time of this tour.
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According to the Safety Supervisor, modification work had recently been
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performed.
Subsequently, the licensee.took prompt corrective action in removing the materials and the inspector confirmed these actions on June 2, 1987.
No violations or deviations were identified during review of this area.
6.
Fire Protection System Inspection, Maintenance and Test Program The inspector reviewed, in part, the licensee's fire protection system
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surveillance inspection, maintenance and test program as required by j
plant Technical' Specifications (TS).
The fire protection TS systems
reviewed included fire suppression water systems, a diesel fire pump, a halon gaseous system, fire hose stations, fire barrier penetrations, and i
fire detection instrumentation.
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This review consisted of an examination of completed surveillance packages and an in progress surveillance test.made during tours of plant areas, and i
by inspector discussions held with the Safety' Supervisor and other plant personnel.
The inspector determined the following:
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i A weekly surveillance check of the fire suppression water system was
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performed between May 20 and June 3, 1987 (TS 4.7.10.1.1.a) by-
verifying the water level in each of the fire water storage tanks.
i The inspector was provided surveillance test results demonstrating.
satisfactory surveillance completion.
A monthly surveillance check of the fire suppression water system i
was performed (TS 4.7.10) by verifying that fire protection valves in the flow path were in their correct position.
On June 3, 1987, I
the inspector, accompanied by licensee staff personnel, visually.
j checked six valves during a field inspection and determined that j
these valves were in their proper position.
I However, on April 4,1987, it was discovered by the licensee's l
staff that three critical fire suppression water system isolation l
valves were omitted from the surveillance procedure and had not been cycled as required by TS every twelve months since receipt of the Operating Licanse on June 11, 1984.
The licensee's corrective actions included cycling the valves on
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April 8, 1987, reviewing the surveillance procedure for completeness, I
and adding the omitted valves to the procedure.
The inspector
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determined the licensee's corrective actions regarding the three
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fire suppression system valves to be sufficient.
Due to two previous occurrences of missed fire protection surveillance, an Onsite Review Committee subcommittee had been established to re-review fire protection surveillance procedures.
NRC monitoring of the subcommittee's re-review is planned.
The lack of cycling the three critical Fire Suppression Water System isolation valves as required by TS 4.7.10.1.1.e, since receipt of the Operating License on June 11, 1984, is considered a Violation
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(483/87018-02).
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At the exit interview of June 5,1987, the licensee requested that further discussions regarding this violation continue prior to issuance of the inspection report.
On June 29, 1987, additional discussions between the licensee and Region III personnel were held to further discuss the validity and basis of this violation.
The most recent eighteen month surveillance check of fire pump
adequacy was conducted by review of the system functional test results including delivery of the required gallons per minute at the required pressure in accordance with NFC and NRC requirements.
The inspector was provided the completed surveillance package dated October 9,1986 documenting that these functional tests were performed satisfactorily (TS 4.7.10.1.1.f (1) and (2)).
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A monthly surveillance check of the diesel fire pump engines was
conducted by verifying the fuel oil day tank level and verifying that the engine started and operated for at least thirty minutes on recirculation flow.
On June 4,1987, the inspector witnessed the satisfactory performance of the initial stages of these required
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surveillance tests for the A diesel fire pump (TS 4.7.10.1.2.a (1)
and (2)).
The licensee also provided pertinent portions of the satisfactorily completed surveillance test results which had been
. approved on May 27, 1987.
The weekly surveillance checks of the diesel fire pump battery
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electrolyte levels and overall battery' voltage were performed. On approximately June 2,1987, the inspector witnessed the satisfactory
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performance of these required surveillance tests (TS 4.7.10.1.2.a (1)
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A semi-annual surveillance check of the halon system was performed l
by verifying that the halon storage tank weight was as required.
j The inspector was provided the satisfactorily completed surveillance
test package which had been approved on April 9,1987 (TS 4.7.10.3 (a)).
The once per three year surveillance check of.the fire hose stations (TS 4.7.10.4) to determine operability by partially opening'each j
hose station valve was discussed as related to the fire hose l
pressure reducing devices (PRD's).
During plant tours the inspector
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observed the installation of PRD's on each of the fire hose stations.
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The licensee was unable to provide documentation to demonstrate that i
l the as-installed setting of these PRD's was adequate. Section E.3(d)
of the $NUPPS response to the Auxiliary Power Conversion and Systems Branch 9.5-1, Appendix A Section, Revision 15, dated June, 1984 specifies that all hose stations are equipped with PRD's where
required by code.
Paragraph 2-1.3.3 of the National Fire Codes,
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Pamphlet 14 - 1978 indicates that a pressure regulating device is
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arranged to regulate pressure at the hose valve outlet to a pressure i
not exceeding 100 psi.
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According to the licensee, no pre-operational test was performed to determine the appropriate setting of the PRD's, however, the Safety Supervisor indicated that the fire brigade was trained to properly handle standpipe hose pressures found in the plant.
Previous Regional discussions with NRR have identified the acceptability of certain criteria in lieu of strict conformance with the code as follows:
To have the fire brigade training program require that a minimum of two personnel man the fire hose with only those personnel trained on fire hose allowed to use it,
i-Fire brigade members need to be trained in the use of fire hose stations up to the maximum pressures found on these station standpipes.
Post caution or advisory type signs on any standpipe (s) having
outlet pressures greater than 100 psi.
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This is considered an Unresolved Item (483/87018-03) pending further evaluation by the licensee and review of that evaluation by the NRC in determining fire brigade and/or equipment readiness to properly control fire hose station pressures in excess of that discussed in the code.
A semi-annual surveillance check of the fire detection instruments-
tion through the performance of an operational trip actuating device test was reviewed.
The inspector was provided the satisfactorily l
completed surveillance package which had been approved as acceptable
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on May 6, 1986 demonstrating that the flame detectors located in the east diesel generator room were tested in accordance with TS 4.3.3.7.1 (1) and (2).
7.
Fire Barrier Penetrations The inspector examined, in part, the fire barrier penetration procedures and implementation of those procedures by visually inspecting the designated fire barriers during plant tours on June 1, 2, and 4, 1987.
l The following procedures were reviewed:
Fire Barrier Integrity, No. APA-ZZ-0744, Revision 1,
dated December 12, 1984.
Fire Barrier Penetration Seal Visual Inspection, No. MSM-ZZ-FZ001,
Revision 4, dated April 17, 1986.
Fire Barrier Inspection, No. MSM-ZZ-FWOO1, Revision 1,
dated June 23, 1986.
Fire Damper Visual Inspection, No, MSM-ZZ-FG001, Revision 3,
dated February 14, 1986.
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These procedures covered fire barrier walls, floors, fire protective wrap, fire dampers, penetration fire seals, fire doors, and fire resistive material applied to the steel beams.
The inspector determined that these procedures and the implementation of these procedures met TS requirements.
The inspector identified to the licensee a previously submitted 10 CFR 50.55(e) Report from another Region III plant which pertained to a fire damper blade being held in an open position by a "J" hook (also commonly referred to as an "S" hook).
This prohibited proper closure of the fire damper.
The licensee was informed by the inspector of the need to visually verify proper positioning of the installed "S" hooks.
This is considered an Open Item (483/87018-04a) pending a review of licensee action.
A copy of the 10 CFR 50.55(e) Report was provided to the licensee by the inspector.
In addition, fire damper operability acceptance tests were performed at the time of installation and more recently from additional fire damper reviews; however, operability tests are not planned to be performed l
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during the life of the plant as described by current surveillance procedures.
As discussed with the licensee, past NRC experience has shown that surveillance programs without periodic operability tests have not assured operability.
Consequently, at the exit interview on June 5, 1987, the inspector requested tha licensee to consider performing " drop tests" on fire dampers separating redundant systems, components, etc., on a periodic test schedule for a sample population of fire dampers (TS for penetration seals requires ten percent sample every eighteen months).
At the exit interview on June 5,1987, the General Manager, Nuclear Operations made mention of reservations he had in agreeing to such a request based on those licensee efforts already performed in the fire damper area along with other present licensee obligatio.1s.
This is considered an Open Item (483/87018-04b) pending NRC review of the licensee's evaluation of the
need to perform fire damper drop tests.
i No violations or deviations were identified during review of the fire barrier penetration area.
8.
Quality Assurance The inspector requested the licensee to provide those audits performed to satisfy TS Sections 6.5.2.9.e and f for the years 1985, 1986, and 1987.
The licensee provided Quality Assurance Audit Reports Numbered AD5A8504B, dated May 18, 1985, AD5A8604B, dated May 15, 1986, and AP87-005, dated May 22, 1987, respectively.
A review, in part, of each audit report indicated that the licensee performed the scheduled audits as required and verified certain programmatic and implementation aspects of the in place fire protection program including the following:
Compliance with TS, License Conditions, Safety Evaluation Reports,
and FSAR Appendix R commitments.
Inspection, Testing, and Maintenance of Fire Protection Systems and
Equipment.
Qualification and Training of the Fire Brigade and other plant
personnel.
Implementation of Administrative Fire Protection Procedures.
- Implementation of Fire Protection Quality Assurance
Requirements.
The inspector concluded that the licensee was satisfying the TS requirements and commented that the audit reports were sufficiently detailed and well documented.
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I No violations or deviations were identified during review of the quality assurance area.
9.
Review of Selected Information Notices The inspec'ir requested licensee evaluations of Information Notices (IN)
Numbered 6
.4, " Actuation of Fire Suppression Systems Causing Inoperability of Safety-Related Ventilation Equipment," dated March 23,
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1987; IN 83-68, " Respirator User Warning:
Defective Self-Contained l
Breathing Apparatus Air Cylinders," dated October 11, 1983; and IN 83-41,
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" Actuation of Fire Suppression Systems Causing Inoperability of Safety-Related Equipment," dated June 22, 1983.
The licensee provided the inspector with ther,e three evaluations dated April 25, 1987 for IN 87-14, December 27, 1983 for IN 83-68 and August 9, 1983 for IN 83-41.
The inspector after onsite and in-office reviews of these IN evaluations and subsequent discussions with licensee personnel determined adequate licensee review had occurred and no further actica is planned or deemed necessary.
I No violations or deviations were identified during review of this area.
10.
Raychem Splices Discussions were held between the licensee's staff and the inspector to discuss the fire protection characteristics and installation applications of the Raychem in-line splices being used at the Callaway plant.
These in-line splices are known to have been installed at other nuclear plants.
These discussions were held with the licensee staff as a result of questions generated during an NRC training session regarding Raychem
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splices and so as to gather information to determine the need for further
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NRC action if any.
The licensee's staff provided the inspector with an "In-Line Splice Application Guide," not dated, and a " Flammability Testing of Heat Shrinkable Field Splicing System for Class IE Electric Cables Type WCSF-N," Report No. EDR-5009, dated March 7, 1980.
The In-Line Splice Application Guide describes the splice (Raychem WCSF) as a heat shrinkable, flame retarded flexible polyolefin tubing being supplied in either coated or uncoated form.
When coated, the suffix "N" is added to the part designator to indicate that the entire inner surface of the tubing is covered with an adhesive which is designed to form an environmental seal under normal, off-normal and Design Basis Event (DBE)
conditions.
It was the fire characteristics of this adhesive on the inner surface of the tubing which was the primary topic of discussion.
According to the Flammability Test Report, the heat shrinkable WCSF-N components are flame test qualified as a field splicing for Class IE electric cables in accordance with IEEE Standard 383-1974.
The licensee's staff indicated that the installation application of the tubing splices were performed in accordance with the guidelines and application ranges described by the appropriate Raychem installation instructions.
As mentioned by the licensee, these Raychem splices are
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able to withstand the intended environmental conditions. These Environmental Qualification considerations were incorporated as part of Hazards Analysis (FHA)g to the Safety Supervisor, as described in the Fire this review. Accordin
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, additional conservatism is incorporated into the j
FHA in that the cable insulation including the IEEE qualified type cable
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is considered for analysis purposes to be combustible. :The licensee's i
FHA was approved by the NRC showing the as-stated description, thereby, adding to the conservatism built into the' FHA. The inspector concluded that the licensee had adequately addressed the inspector's questions and no further action is planned or deemed necessary.
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No violations or deviations were identified during review of this area.
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11. Open Item Open items are matters which have been discussed with the licensee, which
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will be reviewed further by the inspector, or which involve some action I
on the part of the NRC or licensee or both. Open items disclosed during
the inspection are discussed in Paragraphs 4 and 7 of this' report.
12. Unresolved Item Unresolved items are matters about which more information is required in order to ascertain whether it is an acceptable item, a violation, a failure to meet a licensee commitment, or a deviation. An unresolved item l
disclosed during the inspection is discussed in Paragraph 6 of the report.
13. Exit Interview
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l The inspectcr met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on June 5,1987, and s'mnarized the scope and findings of the inspection. The inspector also discussed the likely informational content of the inspection report with regard to documents reviewed by the inspectors during the inspection. The licensee did not identify any of the documents as proprietary.
Further, on June 29, 1987, additional discussions were held between the licensee and the Region III Office to further clarify information concerning this site visit.
During the exit interview, the inspector made mention of certain positive areas of the licensee's Fire Protection Program observed by the inspector during the inspectio? visit. These areas included the qualifications of the fire protection personnel within the Safety Department, the cleanliness of the plant, and the Quality Assurance Staff's audit reports in the fire protection area.
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