IR 05000498/1988061

Insp Repts 50-498/88-61 & 50-499/88-61 on 881003-07.No Violations or Deviation Noted.Major Areas Inspected: Implementation of Fire Protection Program & Compliance W/ Requirements of 10CFR50,App R

ML20195E242
Person / Time
Site:	South Texas
Issue date:	10/26/1988
From:	Clay Johnson, Singh A, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20195E227	List: IR 05000498/1988061 ML20195E223
References
50-498-88-61, 50-499-88-61, GL-86-10, NUDOCS 8811070313
Download: ML20195E242 (11)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/88-61 Operating License: HPF-76 50-499/88-61 Construction Permit: CPPR-129 Dockets: 50-498 50-499 Licensee: Houston Lighting & Power Company (HL&P)

P.O. Box 1700 Houston, Texas 77001 Facility Name: South Texas Project (STP), Units 1 and 2 Inspection At: STP, Matagorda County, Texas Inspection Conducted: October 3-7, 1988 Inspectors: /o[.96/ff'

A. Singh, Reactor Inypector, Plant Systems Date'

Section, Division of Reactor Safety (Team Leader)

G lof26fff C. 'E. Johnson, Reacto'r Inspector, Plant Date'

Systems Section, Division of Reactor Safety

Accompanying Personnei: T. Storey, SAIC J. I. Tapia, Resident Inspector D. L. Garrison, Resident Inspector Approved: /0 76 Nf'

T. F. Stetka, Chief, Plt..t Systems Section

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Division of Reactor Safety l

8811070313 881031 PDR ADGCK 05000498 0 PNU k

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Inspection Summary Inspection Conducted October 3-7, 1988 (Report 50-498/66-611 Areas Ir.spected: No inspection of Unit 1 was conducte Results: Not applicable.

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inspection Conducted October 3-7, 1988 (Report 50-499/88-61)

Areas Inspected: Special, announced inspection of the implementation of the

. fire protection program and compliance with commitments to Appendix A to BTP Auxiliary Power Conversion Systems Branch (APCSB) 9.5-1 and requirements of 1 Appendix R to 10 CFR 50. A physical verification of commitments was performed for Unit 2 only.-

Results: Within the areas inspected, no violations or deviations were identified.

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.3 DETAILS l: - Persons Contacted HL&P l- *G. Vaughn, Vice President, Nuclear Operations i

• J. E. Geiger, General Manager, Nuclear Assurance

• S. L. Rosen, General Manager, Operations Support

• S. M. Dew, Manager, Operations Support

• L. Parkey, Plant Superintendent, Unit 2

• T. J. Jordon, Project Quality Assurance (QA) Manager J. Bailey, Manager, Engineering / Licensing

• J. W. Loesch, Plant Operations Manager

• L. Giles, Manager, Plant Operations, Unit 2

• A. W. Harrison, Supervising Engineer, Licensing

• F. Polishak, Staff Engineer, Project Compliance

• D. L. Dujka, Project Engineer

• S. S. Eldridge, Manager, Plant Operations Support

• J. A. Labuda, Fire Protection Coordinator

• S. Phillips, Project Compliance Engineer M. Duke Electrical Engineer G. Purdon, Principal Engineer G. D. Manasco, Lead Electrical Engineer T. Acuff, Reactor Plant Operator M. Berrens, Shift Supervisor J. Constantine, Nuclear Training J. Grant, Unit Supervisor S. Kasper, Primary Reactor Operator J. Moerbe. Secondary Reactor Operator A. Diaz, Reactor Plant Operator G. Smith, Independent Safcty Engineering Group D. Rocha, Mechanical Engineer Bechtel Engineering (Bechtel)

• L. W. Hurst, Project Manager

• R. W. Miller, Project QA Manager

• V. Khemka, Lead Engineer, Fire Protection

• A. Guidry, Mechanical Engineer

• K. Ng, Fire Protection Consultant C. Jackson, Mechanical Designer J. Sanchez, Mechanical Engineer

• R. Manek, Architectural Engineer

• A. Benton, Electrical Engineer R. Jadav, Electrical Engineer V. Sinha Electrical Engineer J. Daniels, Electrical Designer A. Banerjee, Civil Engineer

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• H. Abel, Quality Program Site Manager Cygna Energy Services (Cygna)

• C M. Turner, Fire Protection Consultant E. Simbles, Civil Engineer NRC

• T..F. Stetka, Chief Plant Systems Section

• T. Storey, Science Applications International Corporation (SAIC)/NRC Fire Protection Engineer .

• M. Hunnicutt, Site Project Engineer

• P.-C. Wagner, Reactor Inspector

• J. E. Bess, Senior Resident Inspector

• B. Evans, Resident Inspector

• Denotes those attending the exit intervie . Fire Protection / Prevention Program (640518) Introduction This inspection was conducted to verify the adequacy of the Unit 2 fire protection program against the NRC guidelines and requirements as specified in Appendix A to BTP APCSB 9.5-1 and Appendix R to 10 CFR 5 A special team inspection was conducted for Unit I during the period March 30 through April 3, 1987. All items identified during that inspection have been resolved. Since both Units 1 and 2 are essentially identical, the Safety Evaluation Report (SER) was written for both units. The fire protection program was found to be acceptable in the SER through Supplement 5. Therefore, this inspection for Unit 2 was intended to ensure that Unit 2 was equivalent with Unit 1 and if differences were identified, to review them for acceptabilit Fire Prevention / Administrative Control Procedures The NRC inspectors reviewed the following fire prevention / administrative procedures:

Procedure N Title Date OPGP03-ZF-0001 Fire Protection Program 01/20/88 Revision 4

OPGP03-ZF-0004 Control of Transient Fire Loads 04/22/86 i Revision 1 l

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OPGP03-ZF-0005 Use of Flamable 1.iquids and Gases 08/18/87 Revision 3 OPGP03-ZF-0006 Control of Ignition Sources 09/09/87 Revision 3 OPGP03-ZF-0007 Control of Solvents, Paints, and 01/18/88 Revision 2 Painting Processes OPGP03-ZF-0009 Smoking Control Program 05/16/87 Revision 3 l

This review verified that the applicant has technically adequate procedures to implement the fire protection program. Procedural guidance was provided to control combustible materials, transient fire loads, and use of flammable liquids, gases and ignition sources. Based on this review, the NRC inspectors concluded that these procedures meet the NRC guidelines of NUREG-0800, Section 9.5.1, Standard Review Plan - Fire Protection Program, Appendix A to BTP APCSB 9,5-1 and the applicant's comitments in a letter to the NRC dated June 26, 198 c. , Fire Protection Surveillance Procedures The NRC inspectors reviewed the following Fire Protection System Surveillance Procedures:

Procedure N Title Date OPGP03-ZF-0018 Fire Protection System Operability 10/28/87 Revision 4 Requirements OPGP03-ZF-0014 Fire Prevention Surveys 03/21/88 Revision 3

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IP-4.30 Quality Assurance Program for Fire 04/10/87 ;

Revision 1 Protection

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The above procedures were reviewed to determine if the various operability requirements and inspection instructions adequately !

implement the surveillance requirements of the STP's fire protection ;

program. In addition, these procecures were reviewed to determine if ;

the inspection and test instructions followed the general industry fire protection practices, NRC fire protection guidelines, and National Fire Protection Association (NFPA) Fire Codes. Based on this review, the NRC inspectors found the procedures acceptable, i

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Plant Tour and Inspection of Fire Protection Equipment

Inspection of Fire Brigade Manual Fighting Equipment The NRC inspectors perfortned an inspection of the fire brigade <

equipment, consisting of fire hoses, nozzles, tools, and miscellaneous equipment, stored at the fire brigade equipment response locetion in the Unit 1 Turbine F jildin A total of fi/e sets of turnout gear (coats, boots, helmets, '

gloves, etc.), five sets of sealed self-contained breathing apparatus and six spare air cylinders are stored in the fire ,

brigade equipment lockers located in the Unit 1 turbine '

building. Based on this inspection, the NRC inspectors verified that the designated fire brigade equipment appeared to be properly maintained and stored in ready conditio *

Permanent Plant Fire Protection Features

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A plant tour was made by the NRC inspector During the plant tour, the following safe shutdown related plant areas and their  :

related fire protection features were inspected including remote shutdown panels, cable chase trays, and diesel generator room Tha fire / smoke detection systems, manual fire fighting equipme't (i.e., portable extinguishers and hose stations, etc.), and t fire boundary walls, penetrations, ducts, floors, and ceiling, associated with the above plant areas were inspected and verified to be in a functional statu All of the cable spreading rooms are equipped with automatic sprinkler systems. An automatic sprinkle" system is installed in the control building, lhese systems were inspected and found  ;

to be in service. The plant tour also verified the applicant's

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implementation of the fire prevention administrative procedure The control of combustible flamable materials, liquids and gases, and the general housekeeping was found to be satisfactory e

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in the areas inspecte . Fire Barriers Doors The applicant had performed a field comparison of the Unit 1 configuration against Unit 2 with respect to compliance with staff fire protection guidelines as approved in the SER. The applicant identified several doors in Unit 2 for which the required fire rating could not be verifie Prior to leaving the site, the applicant

formally included these doors on the Master Completion List (MCL) for tracking until resolution. If these doors cannot be verified, they will be rtplaced by the applicant. This action is considered

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7 Penetrations _

Penetration documentation including design details, Architect / Engineer (A/E) 'ield specifications, vendor installation procedures, and vendor pee + ration seal field installation sign-off sheets were 'eviewed. All documentation as well as sample installation reviewed in the field were found acceptable, Fire Dampers The installation of fire dampers was reviewed in the field. A concern was raised by the NRC inspectors regarding the ability of the plant's Ruskin dampers to close under air flow conditions. By letter dated September 17, 1987, the NRC inspectors concluded that adequate measures had been taken to ensure the dampers would close. These measures include installing stronger springs, adding flow restricters upstream of the dampers in some locations and manually shutting dow Heating, Ventilating, and Air Conditioning (HVAC) in the Electrical Auxiliary Building (EAB) if a fire occurs. The administrative procedures used to shut down the HVAC were reviewed and found acceptable. Engineering documentation which addressed this issue was reviewed and found to provide the necessary modifications to address the issu Generic Letter 86-10 Evaluations The NRC inspectors asked the applicant if any evaluations as described in NRC Generic Letter 86-10 had been performed for Unit 2 other than those previously reviewed for Unit 1. The applicant stated that no new evaluations had been performe . Training Fire Brigade r' ire brigade training records were reviewed for selected members to ensure that they had received adequate training and participated in drill Records were also reviewed to verify that members had received an annual physical. All documentation reviewed was found acceptable, Operator Reactor operator and auxiliary operator training records were reviewed to verify that they had received training in fire-related safe shutdown procedure Records reviewed were found acceptable,

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Acceptance Tests Fire detection and suppression system * which have been turned over to ,

the Nuclear Plant. Operations Department (NPOD) were reviewed to ensure F that initial tests required by the NFPA codes were satisfactorily i performed and documented. All tests reviewed were found acceptabl ,

During the inspection, the applicant identified their intention of i replacing the present smoke detectors in the Emergency Cooling Water ,

intake Structure (ECWIS) with thermal detectors. This action is necessary due to the frequent ino>erability of detection resulting .

from high humidity conditions. T1e areas in question were reviewed in the field and the ch.inging of detectors was found to be-acceptable. Unit I has a license condition which permitt, this type of change if found acceptable with a 10 CFR 50.59 safety evaluatio The evaluation was requestec by the NRC inspectors and found to provide acceptable justification that the change did not reduce the .

level of plant safet t 6. Post-Fire Safe Shutdown Procedures (Plant Abnormal Operating Procedures)

A drill was conducted to review Procedure 2POPO4-ZO-0001, "Control Room 4 Evacuation," Revision 0, dated May 26, 1988, for adequacy and operator i effectiveness in the event of a control room evacuation due to a fire, t Although the operators performed effectively, deficiencies were identified as listed oelow:

' Comunication Difficulties With the Sound-Powered Phones Several of the operators experienced difficulty communicating with the sound-powered phones. This is of particular concern since the ambient noise levels during the drill were less than what would be encountered during plant operation. Since the diesels were not actually started, sound levels at that shutdowa location would definitely be much greater. This is considered to be an open item pending inspector review of the applicant's actions to address this communication proble Open item (499/8861-01): Resolve in plant comunication problems with sound-powered phone Procedure Format Problems The control room evacuation procedure was noted to have several problems which affected the performance of operators. The addendum did not slways direct the operators to the location of the specific switches requiring the operators to remember their locations. Also, during the drill, an operator was directed by the shift supervisor at the shutdown panel to assist in the performance of a second

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operator's duties since that operator was involved with restoring diesel operations. While this is considered appropriate, the diesel operator, upon his return, was not immediately aware of what had been done in his absence. This problem was compounded by the poor communications due to the use of the sound-powered phones. It appears that the procedure needs a revision and the training needs to be reviewed to account for operators sharing tasks if this is a t aossibility during procedure implementation. This is considered to

)e an open item pending inspector review the applicant's action to address this proble Open item (50-499/8861-02): Review the control room evacuation procedure to determine if a revision is necessary to account for sharing of tasks by operator l

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c. Poor Location of Diesel Keys The plan, at the time of the drill, was to locate the keys used to transfer the mode of the diesels from "Auto" to "Local" in the "B" diesel bay. It was noted during the drill that the preferred order of starting the diesels locally was "A," "C," and then "B." Based on this order, it would be more effective and less time consuming for the applicant to locate the keys in each diesel ba Prior to leaving the site, the applicant comitted to locate a diesel key in each diesel bay. This action is acceptable to the NRC ,

inspector d. Technical Adequacy of the Control Room Evacuation Procedure and Plant Equipment Labeling Discrepancies During this inspection, deficiencies were identified which appear to involve inadequate technical review of the control room evacuation I procedure Jnd multiple mislabeling of the components in the plan t For example, a case was identified where the procedure called for the operator to open a 13,800 volt breaker while the 4160 volt breaker i should have t'een opened per the Unit Supervisor. (It was not established prior to the exit what the proper sequence of breakers

should be.) This situation coupled with other procedure

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discrepancies demonstrated an inadequate technical review by the applicant. Similar deficiencies, regarding abnormal operating l

procedures, were noted during the period of March 30 through April 3, 1987, as documented in NRC Inspection Report 50-498/87-17 for Unit A Notice of Violation (NOV) was inued for inadequate abnormal operating procedures and is documented in NRC Inspection i Report 50-499/88-54. The inadequacies identified with the control room evacuation procedure are considered to be another example of this i'

violation. Therefore, the applicant should respond to this finding as a part of their response to the NOV identified in the NRC Inspection Report 50-499/88-54 ,

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10 Separation of Safe '. shutdown Cables and Componer.ts In order to optimize cable runs and reduce the amount of required cable wrap, the applicant rerouted many of 1.ie cables for Unit 2 as compared with the routing in Unit 1. As a result, certain cables in Unit 2 may be in areas other than those identified for the cables in Unit 1. This required the applicant to reanalyze the new configurations for impact to the sa'e shutdown analysi The applicant developed a computer generated list of all cables where there were differences in fire areas between Units 1 and 2. This list was then used to perform a review of the safe shutdown analysis originally performed for Unit 1 to ensure that appropriate separation per uppendix R,Section III.G was maintaine Approximately 50 percent of the required cable wrapping was installed at the time of this inspectie. The applicant will to verify that all necessary wrapping nas been installed prior to fuel loa Therefore, this item will be covered in a future inspectio . Fire Brigade A fire drill was conducted in the Unit 2 Fuel Handling Building to verify the adequacy of brigade training, equipment, comunications, and accessibility of the fire area. Although the drill wat considered adequate, the NRC inspectors noted that there was a problem with the location of the brigade turnout gear. The current arrangement is to locate all of the brigade gear in the Unit 1 Turbine Building. Upon receipt of a fire alarm, the brigade members, responding from Unit 1, bring the necessary gear to the scen The NRC inspectors noted that this arrangement could delay a response to a fire in Unit 2. During the inspection, the applicant comitted to placing appropriate brigade turnout gear in Unit 2. This arrangement is found to be acceptable. Also, during the drill, the telephone initially used to notify the Control Room of a fire condition did not function ;:roperly when the station emergency number was dialed. The applicant submitted a work order to repair the pho following the drill. The NRC inspectors found the applicant's acticns to be acceptabl . Emergency Lighting At the time of this inspection, emergency lighting required by Appendix D ;

was either not installed or aligned properly. Since the lighting will not be complete until hst prior to fuel load, this item will be verified in a future inspectio . Control Room During the inspection, the applicant identified that carpeting would be installed in the Unit 2 Control Room. Although this issue was reviewed and accepted by the NRR staff for Unit 1, the fire testing criteria for ,

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l Unit 2 carpeting is different than that referenced by the NRR staff in the Safety Evaluation Report (SER). However, since the Unit 2 carpeting was tested to a more current standard, ASTM E 648, it is considered to be acceptable. This establishes the carpeting as Class I and is therefore  :

found to be acceptable for installation in the Control Room of Unit . Reactor Coolant Pump (RCP) Oil Collection System The NRC inspectors reviewed the installation of the RCP oil collection -

system. The NRC inspectors verified that all the reactor coolant pumps I are provided with a seismic Category I oil collection system and designed to collect oil from potential leakage sites and sized for the pumps' total oil inventory. The design drawings and seismic analysis were reviewe ;

This review provided reasonable assurance that the system was seismically  ;

qualified and that each collection tank could hold al'. of the oil -

inventory from its associated pump and was therefore found to be i acceptabl . Exit Interview  ;

An exit interview was conducted on October 7, 1988, with those personnel  !

denoted in paragraph 1 of this report. At ti.is interview, the scope of l

the inspection and the findings were summarize The licensee did not l identify as proprietary any of the information provided to, or reviewed i j by, the NRC inspector l l  !

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