IR 05000498/1993037
| ML20058C077 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/19/1993 |
| From: | Constable G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20058C029 | List: |
| References | |
| 50-498-93-37, 50-499-93-37, NUDOCS 9312020335 | |
| Download: ML20058C077 (20) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-498/93-37 50-499/93-37 Licenses: NPF-76 NPF-80 Licensee: Houston Lighting & Power Company P.O. Box 1700 Houston, Texas Facility Name: South Texas Project Electric Generating Station, Units 1 and 2 Inspection At:
South Texas Project Electric Generating Station Inspection Conducted: October 18-22, 1993 Inspectors:
M. E. Murphy, Reactor Inspector, Plant Support Section Division of Reactor Safety, J. E. Whittemore, Reactor Inspector, Plant Support
- Section iv.ision of Reactor Safety, 9[97
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Approved:
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D4te G Es-tUliYtable, Chief, Plant Support Section, Division of Reactor Safety Inspection Summary Areas Inspected (Units 1 and 21: Routine, announced inspection of the licensee's corrective action to resolve previous inspection findings related to fire protection.
j Results (Units 1 and 21:
The licensee had verified that the training program for fire brigade
leaders _ met the requirements specified in Appendix R of 10 CFR 50.
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Additional personnel were being qualified as fire brigade leader to reduce the burden on operations personnel. (Section 2.1.4)
The Unit I fire protection computer system had undergone hardware and
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software changes.to enhance usability and reliability. As a result, the.
nuisance alarms and operator distraction attributed to the fire i
protection system computer had decreased significantly.
Changes to I
j 9312O20335 931123 PDR ADOOK 05000498
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computer alarm descriptions had improved system reliability.
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(Section 2.2.5)
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The licensee had correctly identified all the work necessary to improve
the material condition of the fire protection systems. However, a significant portion of the work remained to be done by a licensee
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contractor. (Section 2.3.3)
The licensee had correctly identified, investigated, and resolved the
problems with fire barrier penetration seals. Additional occurrences of
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seal problems would be identified and corrected by the licensee's surveillance and corrective action programs. (Section 2.4.3)
The licensee program for control of transient combustibles had improved,
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but required additional management attention to improve the collective employee attitude toward fire safety. (Section 2.5.3)
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STPEGS management appeared aggressive toward correcting identified
problems and identifying additional problems. (Section 5)
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Summary of Inspection findings:
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Violation 498;499/9235-06 was reviewed concerning two examples of
failure to meet requirements of the fire protection program and remains open. (Section 3.1)
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Inspection Followup Item 498;499/9331-02 was reviewed concerning the
l effect on operators of degraded equipment and remains open.
(Section 3.2)
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Inspection Followup Item 498;499/9331-04 was. reviewed concerning poor
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support to operations and remains open.
Fire protection issues had been resolved. (Section 3.3)
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t Inspection Followup Item 498;499/9331-17 was reviewed concerning.
- multiple fire protection issues. This item remains open pending the i
material improvement of Unit 1 fire protection systems. (Section 3.4)
Inspection Followup Item 498;499/9331-22 was reviewed concerning
numerous fire protection issues. This item remains open pending the l
material improvement of Unit 1 fire protection' systems. (Section 3.5)
i Inspection Followup Item 498;499/9331-75 was reviewed concerning
numerous fire protection issues. This item remains open pending the material improvement of Unit 1 fire protection systems. (Section 3.6)
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Violation 498;499/9309-01 was closed. (Section 4.1)
t Inspection Followup Item 498;499/9331-33 was closed. (Section 4.2)
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i-3-f Inspection Followup Item 498;499/9331-58 was closed. (Section 4.3)
Attachment:
Attachment - Persons Contacted and Exit Meeting
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-4-DETAILS 1 PLANT STATUS
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During this inspection period, both units were shut down and defueled. Unit 1 was being prepared for core load and startup.
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2 FIRE PROTECTION AND PREVENTION (64704)
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During a Diagnostic Evaluation Team (DET) Inspection conducted March 29
_hrough April 30, 1993, by the NRC Office for Analysis and Evaluation of Operational Data, several issues were identified that raised questions about i
the adequacy of fire prevention and protection at the South Texas Project Electric Generating Station (STPEGS), Units 1 and 2.
The licensee responded and agreed to initiate and implement corrective actions to address the fire
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t protection-related findings. The licensee informed Region IV that corrective action to address the identified issues had been initiated and in some cases, fully implemented for Unit 1.
This inspection was conducted to evaluate.the adequacy of the corrective actions taken or planned to address DET and
previous findings related to fire protection for STPEGS, Units 1 and 2.
2.1 Fire Briaade leader Trainina The DET inspection raised questions regarding the adequacy of the licensee's
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fire brigade leader training program. Specifically at issue was the safety-related system knowledge of the brigade leaders and members.Section III.H of Appendix R to 10 CFR 50 states in part, "The brigade leader and at least two members shall have sufficient training in or knowledge of plant safety-related systems to understand the effects of fire and fire suppressants on safe shutdown capability."Section III.H 1ater states, "Such competence by the.
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brigade leader may be evidenced by possession of an operator's license or equivalent knowledge of plant safety related systems." Licensed personnel are not assigned duties as fire brigade members or leaders at STPEGS.
A second issue was raised by NRC staff concerning the impact on operations personnel because of the need to replace fire brigade personnel due to overdue requalification training. The concern was that an extra burden was
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being placed on the'non-licensed operating staff.
2.1.1 History of Fire Brigade Leader Training at STPEGS
The licensee established the initial-fire brigade leader training program in
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1985.
Part of this curriculum included training on the systems required for safe shutdown.
In 1987, licensed operators were assigned as subject matter experts to develop learning objectives for systems knowledge required of non-
licensed fire brigade members and leaders. The curriculum was finalized by
the action of a technical advisory council to approve the objectives as the basis for a fire brigade member and leader training program. This program did
not have all the attributes of the systematic approach to training (SAT)
methodology as formal job and task analysis had not been performed to develop-
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or the period of 1987-1993, the training program length varied between sean and nine weeks. This program existed until April 1993 when STPEGS planniny and assessments issued Station Problem Report 931337 which asked if the cerrent curriculum of systems training was sufficient to meet the Appendix R requirements.
The licensee's current program encompassed a 6-week classroom course intended to meet regulatory requirements regarding the system knowledge of fire brigade'
leader personnel. The last 3 days of the course were designed to provide a student with the knowledge and skill to exercise effective command and control at a fire scene.
In addition to providing instruction for the identified safety-related systems, the curriculum included instructior nn systems that had the potential to be involved in a fire, such as lubricat.ng and fuel oil systems.
2.1.2 Licensee Action to Assure Regulatory Compliance The licensee's initial response was to evaluate the current fire brigade l
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leader traiaing program content to assess compliance with regulations. The initial evaluation effort was to compare fire brigade leader training program system learning objectivos against the system learning objectives of the licensed operator training program. This effort verified that the fire brigade leader training course provided the fire brigade leaders with adequate knowledge of plant safety-related systems required for safe shutdown.
Adequate knowledge was aetermined to be those knowledge, skills, and abilities for brigade leaders to assess the potential consequences of a fire and fire suppressants on the system contribution to safe shutdown.
The inspectors reviewed the results of the licensee's comparison of the two training programs by reviewing learning objectives in a sample of fire brigade leader program system lesson plans. Those licensed operator objectives to assure knowledge, skills, and abilities required to operate, perform operational surveillance, and interpret license requirements had not been included as part of the fire brigade leader program. However, fire brigade leader training lesson plans routinely required students to master learning objectives to support knowledge of system interfaces, specific component location, system functions, component functions, flow paths, power supplies, l
control stations, and methods of transferring control of components and i
systems. Additionally, a typical system lesson plan contained a terminal objective that reauired a student to describe how the loss __of a given component would affect the system's continued operation, and safe shutdown c;pability.
l l-The licensee determined that the current fire brigade leader training program
met the requirements of Appendix R to 10 CFR 50. However, in an effort to enhance the knowledge and skill of fire brigade leaders, the licensee had initiated the design and implementation of a SAT based training program for fire brigade leaders. At the time of the inspection, the licensee had l
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conducted a job analysis and from this analysis had identified the tasks for which an individual must demonstrate proficiency to fill the position of fire i
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brigade leader. The inspectors reviewed the task list and determined that it was an adequate list for identifying the knowledge required for a fire brigade leader to perform effectively. Effort was underway to perform task analysis to identify the knowledge, skills, and abilities needed to perform these
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tasks.
Learning objectives would be developed to incorporate the knowledge, skills, and abilities intt, the training program. The inspectors believed that the final program objectives would not significantly differ from the existing objectives.
The inspectors also agreed that the current program met the
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regulatory requirements.
2.1.3 Fire Brigade Leader Training Program Overview The inspectors conducted a broad review of the existing fire brigade leader training program. The training program was implemented by Procedure IP-8.14Q,
" Fire Protection Training Program," Revision 3.
This review was performed to
assure that incumbent fire brigade leaders were periodically evaluated for the desired proficiency. Additionally, the licensee's corrective action for performance problems was assessed.
Fire brigade leaders were maintained in a state of proficiency by the following program attributes:
All fire brigade leaders and members were currently enrolled in a
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continuing training program. The program was implemented on a 2-year cycle and contained all the learning objectives of the initial training program.
Individuals were tested at the end of each 2-year cycle.
Each fire brigade leader was required to participate in one ainual fire l
drill acting as brigade leader. The inspectors reviewed records indicating that performance was evaluated. The drill evaluations contained criteria in the form of objectives to be met by the brigade and leader. One of the criteria to be evaluated was the management of safety-related systems.
The inspectors reviewed records that documented the occurrence of hands
on training under real conditions conducted by offsite departments or
institutions on an annual basis.
Records indicated that fire brigade leaders were evaluated during this training.
Records indicated that those individuals exhibiting performance
deficiencies in written examinations or dynamic evaluation were provided remedial training and re-examined or re-evaluated.
The inspectors reviewed the content of an initial fire brigade leader
course that was being administered at the time of the inspection. The review ascertained that the previously validated cbjectives related to knowledge of safe shutdown systems were included in this course of
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instruction.
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i A monthly memorandum was provided to management which specified the current
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status of all fire brigade members and leaders. This correspondence indicated
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those personnel with lapsed leader or member qualification and the actions necessary to re-instate those personnel. According to records provided to the inspectors, lapsed qualification had resulted from failure of written
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examinations, poor performance on drills, and failure to attend required training.
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The inspectors reviewed the current status of shift fire brigade personnel.
Each shift brigade consisted of five members, three of unich were certified as'
fire brigade leaders. However, only one was designated as brigade leader for the assigned shift. This arrangement allowed the licensee to meet the
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Appendix R requirement that at least two brigade members, in addition to the brigade-leader, had adequate knowledge of safe shutdown systems. The
inspectors also verified that an initial training course was currently in progress which would, in the near term,. provide extra personnel qualified as
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fire brigade leader. There were six students enrolled in the course who, when
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qualified, would ease the burden on operating personnel. A licensee
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representative stated that with the qualification of the students in the current class, there would be enough qualified fire brigade leaders per crew to completely eliminate the need to use operations personnel.
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l The inspectors agreed that the current fire brigade leader training program i
met the regulatory requirements of Appendix R to 10 CFR 50 regarding the fire
brigade leader's knowledge of safe shutdown systems. The effort to validate i
the current program learning objectives by a comparison review against the
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licensed operator training program was effective. Upon completion of the
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design and implementation of the new program, requirements for an industry accredited training program would be in place, should accreditation ever be t
required. The licensee's effort to provide extra personnel, qualified to perform as brigade leaders, would remove burden from operating personnel. The j
issue concerning the fire brigade leaders' knowledge of facility safe shutdown
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systems should be removed as a condition for startup of both STPEGS units.
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2.2 Fire Detection and Computer System 2.2.1 Background During the diagnostic evaluation team inspection, the team concluded that the fire detection and computer system had the potential to distract control room
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operators from their safety-related duties and responsibilities.- This
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resulted from the observation of excessive spurious system failure and false alarms generated by the system during a normal shift. The team also concluded
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that the potential existed to delay action to mitigate the consequences of ar
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actual fire should the control room operators become desensitized by repetitive false alarms.
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-8-h 2.2.2 Licensee Initial Actions to Reduce Spurious Alarms The inspectors noted that the licensee planned to replace in their entirety, i
the fire detection and computer systems for Units 1 and 2, during future outages.
For the interim period, the Unit I fire detection and computer systems have undergone hardware, software, and procedural changes to enhance usability and reliability. As a result, the spurious alarms and operator distraction attributed to the fire protection system computer had decreased
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significantly.
An initial action by the licensee was to review the cause(s) of spurious alarms for Unit 1.
The major cause was determined to be field devices such as transmitter boards, mechanical relays, local panel power supply modules, and
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detectors.
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The inspectors reviewed the effort initiated by the licensee to improve the
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performance of field components. Service Request FA 165056 was approved and issued to replace 246 older style mechanical relays in the local alarm relay.
s panels. This effort resulted in replacement of about 25 percent of all Unit 1
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fire protection system mechanical relays.
The number of spurious alarms received daily were noted to decrease significantly following-the replacement of these relays.
Shortly after relay replacement, the licensee initiated a
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practice of trending all fire protection system alarms. This action was taken
to icentify repetitious alarms for the purpose of identifying other components
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that were contributing to alarms. At the time of the inspection, the trending
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effort was ongoing and the number of nuisance alarms continued to decrease.
- i The inspectors determined that 14 service requests had been issued to replace Unit I components or sets of components that were determined to be deficient through the alarm trending effort. Additionally, a design change had been initiated as a result of analyzing the trend data. Analysis prompted the licensee to contact the vendor that supplied the system smoke detectors. The vendor indicated that the ionization smoke detectors used at STPEGS would not perform well in locations with an atmosphere of high humidity. As a result,
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document change notice (DCN) JD-1658 had been implemented to allow
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installation of either ionization or infra-red detectors in any location.
Licensee representatives informed the inspectors that plans were to continue the trending process until the detection and computer systems were replaced, and the same effort was being implemented on Unit 2.
2.2.3 Improvements to the Fire Protection Data Acquisition Computer
The licensee had identified an undesirable condition related to the fire j
protection computers in bcih units.
Computer alarm messages were vague and at
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times misleading.
There/ ore, the centrol room operators sometimes failed to
respond rapidly to the condition identified by the alarm. The licensee initiated corrective action to address this condition.
'j The licensee initiated and implemented DCN JD-1261 which changed the fire protection data acquisition computer alarm descriptions for Unit 1.
Every
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This change was implemented by service request FA 118780 over an approximate
two week period. However, post modification testing to validate the improved alarm descriptions indicated that all points were essentially blank and did not contain the correct information. The licensee commenced troubleshooting and eventually determined that the computer memory space was too limited to store the enhanced alarm messages; therefore, all alarm messages had been
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deleted from memory. Memory space was seriously limited because the original computer installation was configured with two single-sided floppy disk drives and there was no hard drive.
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assist in providing a method to increase the computer memory. The vendor provided two double-sided floppy disk drives which the licensee installed to
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significantly increase the fire protection computer memory. The licensee installed the new drives by revising service request FA 118780 for enhancing
the alarm descriptions, by adding a step to change the disk drives. The inspectors were concerned that the licensee had affected a design change without utilizing the design modification process.
In response to the inspectors' concern, the licensee provided correspondence from the computer
vendor as well as the computer technical manual. The inspectors noted that i
the disk drives were not described in the vendor ter.hnical manual and were
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treated as an off-the-shelf replacement item. Additionally, the vendor stated that the vendor part number for the new double-sided drives would not be
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changed. The vendor considered any commercially available disk drive to be suitable for this application. After seeing this information, the inspectors were no longer concerned that design or configuration control had been bypassed.
The inspectors observed that the revised computer alarm messages were a significant improvement over the previous format and content. Additional information was available from the adjacent printer. The present system
.1 provided operators with clear descriptions of location, device actuated, and clear reference to the fire pre-plan. Onshift operators indicated that the i
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system had significantly improved.
2.2.4 Additional Fire Detection System Improvements
The inspectors noted that the licensee had replaced the monochrome monitor at the computer interface terminal with a color monitor. The new monitor would
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show systcm trouble alarms and fire alarms in different colors. This provided i
operators a quicker assessment of the severity of the problem causing the
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The new computer disk drives allowed the generation of four lines of i
descriptive data for each alarm message.
However, the monitor would display
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only the first line of the alarm message.
In order to provide the operators
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i with more information, a printer located adjacent to the computer interface terminal monitor, would provide a printout of all four lines of Lie alarm i
message. As a result of the improved alarm messages, the added information j
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This feature provided ready access for operators and brigade members to important information.
The inspectors reviewed samples of new fire pre-plans which the licensee was implementing.
Each plan reviewed consisted of a single laminated page with information on both sides.
This information included:
A color-coded map depicting primary and alternate routes to the area and
zone; A description of the access and egress;
Information on the adjacent fire zones;
Equipment and personnel staging areas;
Radiological, chemical, obstructions, and physical hazards within the
fire zone; Instructions for smoke and heat removal;
Equipment needed;
Combustibles loading;
Potential damage to and management of safe shutdown systems; and
A general notes section which dealt with fire fighting tactics,
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additional equipment to consider, and the recommended extinguishing agents.
The licensee had improved both the quality and retrievability of information from the fire protection data acquisition computer. The fire pre-plans were well integrated into the overall fire protection scheme.
2.2.5 Conclusions The inspectors determined that the licensee's efforts to significantly reduce the distraction of control room operators by the fire detection system had beea successful.
The number of spurious alarms noted during the DET had been characterized as 20-30 per day. During this inspection period, the inspectors observed 4-5 alarms per day.
There was ample indication that system information retrieval had been improved due to the improved alarm descriptions.
There was an apparent increase in operator sensitivity to the j
information provided by the fire detection system.
Control room operators appeared to be less distracted.
The inspectors concluded that the current
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performance of the fire detection and computer system should not be an issue
affecting the scheduled startup of Unit 1.
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I 2.3 Fire Detection and Suppression Systems Maintenance Backloo
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2.3.1 Background
i According to the DET inspection report, the licensee did not resolve numerous fire protection issues in a timely manner. The issues included a large
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backlog of service requests on fire protection systems. Management did not t
adequately oversee and direct the efforts to resolve this issues in a timely manner.
At the time of the. evaluation, the licensee had a total backlog of f
361 open service requests for fire protection systems which included 164 for
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Unit 1, and 75 that were common to both units. These backlogged service
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requests were associated with fire detection and suppression systems. There
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was an additional backlog of 68 service requests for Unit 1 pertaining.to fire l
barrier breaches including Thermo-Lag installations and Hydrosil penetration
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seals.
The large backlog suggested that the reliability of fire protection
systems was questionable.
i 2.3.2 Licensee Corrective Action to Resolve Backlog Issue
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The licensee initiated a review of the corrective maintenance backlog. The scope of the review included open work requests, system walkdowns, and. system
health reports for the following systems
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Fire Water Suppression Systems,
Halon Fire Suppression Systems,
Fire Detection Systems, arid
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The important criterion for this review was the projected reliable operation of the systems for the next 18 months by evaluating the cumulative effects of
open service requests on system operability. This review resulted in the-generation of additional work requests. This review was conducted as a part i
of the licensee's Startup Readiness Review Program in April 1993.
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review program for fire protection systems. The inspectors reviewed the results of this effort in order to assess fire protection adequacy. This
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section addresses fire detection and suppression systems.
Fire barriers are
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addressed later in this report.
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The licensee intended to completely work down the fire protection backlog for.
Unit 1 and common items prior to the Unit I startup.
This was evident to the
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inspectors because the only documented deferral of work was the complete
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replacement of the Unit I computer and detection system, scheduled for the 1996 outage. As a result of this intention, the licensee recognized early on
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i that the STPEGS staff would have to be augmented if the Unit I backlog was to be completely addressed prior to Unit startup. Therefore, the licensee had acquired contract support to address the material condition of the fire i
protection and suppression systems. During the week of the inspection, these j
contract personnel were onsite receiving general employee and familiarization '
training from the licensee staff.
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The inspectors reviewed the fire protection systems status with the fire protection supervisor and the fire suppression system engineer. As stated
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i previously the licensee did not plan to defer any work items and planned for the contractor to work the work list to completion. There was no discussion
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of plans to handle any emerging work. A printout indicated that there were
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169 open service requests related to fire protection for Unit 1 and common
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systems. A detailed joint review revealed that 17 items on the printout had
been closed since the list had been printed during the previous week, leaving
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a total of 152 major work items to be addressed for Unit 1.
A review of the open station problem reports against Unit I and common fire i
protection systems indicated that all except one had been or would be closed out prior to restart of Unit 1.
This report was written because of an
apparently mis-wired module which provided a supervisory-(valve position).
i trouble alarm for Valves IFP-248 and IFP-3213 located in the turbine building.
The operation of the fire detection system or any safety-related equipment was l
not affected.
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Additional review indicated that there were no substantial ISEG, QA, or
licensing concerns for fire protection issues, except those related to replacing the fire protection computer and detection system. There were two
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design modifications that would remain open. One addressed the computer _
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replacement, and the other dealt with relocating an installed smoke detector.
2.3.3 Conclusions
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The inspectors concluded that the licensee had identified all the work necessary to address the material condition of the fire detection and suppression systems. Although a large amount of work had been done, a
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significant amount remained to restore the material condition of the fire detection and suppression systems. A determination of work progress and quality will be made during a future inspection to assess the improved condition of the fire protection systems.
2.4 Hydrosil Fire Barrier Penetration Seals
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2.4.1 Background
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During the DET inspection it was found that " Excessive shrinkage and resultant cracks of Hydrosil-type penetration seals allowed free air to pass between l
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-13-fire areas and raised questions of structural integrity, making the seals ineffective fire barriers. The problem was previously identified in 1990 and was thought to have been corrected after a 100 percent survey in 1991-92 and
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subsequent repairs / rework. The cracking was again identified in March 1993."
This inspection was to determine the extent of the problem, the actions taken by the licensee to resolve the issue and the effectiveness of the corrective actions.
2.4.2 Licensee Actions to Address Fire Barrier Penetration Seal Issues During the conduct of the regularly scheduled Surveillance Test OPEP03-FP-0123, " Fire Barrier Penetration Seal Visual Inspection," in February 1990 of both Units, the licensee identified out of a total of 2257 Hydrasil penetrations, 610 that failed the acceptance criteria.
The failure mechanisms were surface cracking and separation of the seal material from the base material.
The licensee initiated an extensive investigation into the root cause of the failures. This investigation included the determination of the material properties and a petrographic examination of hydrosil samples taken from floor and wall penetrations. The conclusica of this investigation was that the shrinking and cracking was apparently related to the loss of entrained water during the drying process.
The quantity of water loss was
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related to the strength LF the cured hydrosil material and the strength of the cured material was in direct relation with the water-to-dry-mix ratio used during the preparation of the material for placement.
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The licensee's fire protection consultant developed an acceptable repair procedure using a damming agent and an epoxy seal material. This repair
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system was subjected to a 3-hour fire resistance evaluation and qualification test and the results reported in a penetration seal fire resistance test report, identified as Project No. 8610-90222, dated June 13, 1990.
The test was successful and the repaired configurations were declared 3-hour qualified.
All fire penetrations that had failed the inspection were repaired.
A subsequent inspection conducted in November 1991, identified 100 additional seals that required repair. The original investigation had determined that the seal material desiccation process was, in all probability, continuing and there would be additional shrinking. Another seal inspection in early 1993 identified an additional 60 penetration failures due to shrinkage.
None of the failures identified in 1991 or 1993 were in previously repaired penetration seals.
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During a tour of the plant, the inspectors observed several examples of repaired penetrations and those not requiring repair.
These penetrations were in the floor, wall and ceiling areas. Generally the repairs were for separation of the hydrasil material from the encasement material.
Facial cracking was limited and in all observed cases appeared to originate at the point of entry by the penetrating commodity into the barrier material.
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Repairs of the penetration seals, except for 8 repairable and 12 inaccessible penetrations were completed at the time of this inspection. The licensee had documented the appropriate Generic Letter 86-10 evaluations for the
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t-14-i inaccessible penetrations. The inspectors reviewed these evaluations and determined that although they lacked clarity and some detail they were i
acceptable. The licensee plans to have the remaining repairable penetrations completed prior to Unit I startup.
l 2.4.3 Conclusions
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The ir.:.pectors concluded that the licensee had taken appropriate and timely corrective action for the shrinking and cracking of the hydros 11 fire barrier penetration seals.
Since the desiccation process was highly time dependent,
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the failures extended over a long period and show a rapid decrease in failure rate, from 27 percent in 1990 to 6.1 percent in 1991 and 3.9 percent in 1993.
It was the licensee's opinion that the most significant amount of shrinkage and cracking has already taken place. The development of further shrinking and cracking should be very limited, and will be repaired on a case-by-case
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basis, when identified within the normal surveillance program.
There was no evidence that the evaluation, investigation, and repair processes were unduly del ayed.
It appears that management was well aware of the problem and-supported the recovery efforts.
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2.5 Control of Transient Combustibles 2.5.1 Background The OET inspection identified that "In April 1993, the licensee located l
significant quantities of transient combustibles such as wooden tables, waste
oil, oil-soaked rags, and miscellaneous combustible items located throughout the plant.
The presence of such large amounts of transient combustibles was
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indicative of an inadequate control program." This inspection was to
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determine that the licensee had established an effective control program for
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transient combustibles.
2.5.2 Licensee Actions to Control Transient Combustibles
Control of transient combustibles was identified by the NRC as a concern in violations issued by NRC Inspection Reports 50-498;499/92-35 and 50-498;499/93-09. The licensee's responses to these violations were issued in i
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April 1993, and identified the proposed corrective actions. The licensee has relied upon these proposed corrective actions to correct the perceived
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transient combustible control problem. These corrective actions consisted of issuing a general letter to the maintenance department to emphasize the need to control transient combustibles, conveying this concern directly to
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personnel in crew meetings and pre-job briefings, revising the pre-job briefing checklists, and incorporating the requirements for the use and i
storage of flammable or combustible materials in the General Employee Training program.
The inspectors reviewed a letter, MAINT-93-9-356, dated July 12, 1993, which
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was issued and became Maintenance Department Standing Order MG-21, Rev. 1.
This letter provides the general directive to comply with the corrective'
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actions placed in effect as a result of the concern for controlling transient
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combustibles. The inspectors also reviewed several memoranda that documented
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the completion of the action to convey the concern for the control of
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transient combustibles directly to personnel and the revised pre-job briefing check lists that included this requirement as a permanent reminder.
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inspectors further determined that the requirements regarding the use and storage of flammable or combustible materials was included in the General
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Employee training program in Lesson Plan GET001.03.
During a tour of the facility, the inspectors observed general cleanliness and -
housekeeping.
In the Train C electrical penetration room, the inspectors found a large rag in an overhead cable tray.
In the Train C relay room, the inspectors found four metal work tables with wood tops, a large pile of
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plastic trash bags, and a rag in an overhead cable tray. The tour also encompassed the emergency diesel generator rooms, and the electrical i
penetration rooms, cable spreading rooms, and relay rooms for the other
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trains. Generally, the plant was clean and outage work areas _ were well policed. The licensee investigated the wooden table tops and trash bags and
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determined that they were within the revised combustible loading for the area.
The licensee advised the inspectors that a fire protection representative, on tour in the radiation controlled area had found two instances of trash not
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being moved out of the controlled area in a timely manner.
l 2.5.3 Conclusions The inspectors concluded that the increased emphasis on control of transient
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combustible material in conjunction with the licensee's existing programmatic administrative procedures appear to provide an effective program. However, it appears that general plant personnel concern and awareness had again deteriorated. The continued effectiveness will require close control and involvement by licensee management with specific emphasis on generating a sense of individual responsibility by all plant personnel.
3 STATUS OF ITEMS RELATED TO RESTART ISSUES j
The following items related to Restart Issues were reviewed concerning the manner that the licensee had resolved the issue within the scope of fire
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protection and prevention adequacy. These issues were generally broad scoped
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and sometimes covered numerous licensee systems or programs. They will remain open pending further NRC inspection effort to completely resolve the items during future Restart Issue inspections.
3.1 (00en) Violation 498:499/9235-06: Two Examples of Failure to Meet Reauirements of the Fire Protection Procram
The example of a failure to meet the fire protection program by not providing i
proper control of transient combustibles was considered closed. Refer to paragraph 2.5.3 of this report for substantiating details.
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3.2 (0 pen) Inspection Followuo Item 498:499/9331-02: Operators Were Sianificantly Affected by Dearaded Plant Eauipment. Includina Eauipment Workarounds and the Administrative Burdens Associated With the Hiah Rate'
of Removal and Return of EauiDment to Service At the time of the inspection, the licensee had not implemented a significant portion of the corrective action that had been identified as needed to improve the material condition of the fire detection and suppression systems. This l
item remains open.
3.3 (0 pen) Inspection Followup Item 498:499/9331-04:
Poor Support to Operations Was Adversely Impactina the licensee's Capability to Safely Operate the Plant At the time of the inspection, fire protection and prevention issues were no
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longer a negative impact on plant operations as noted in paragraph 2.2.5 of this report. This item remains open pending the resolution of issues that are not related to fire protection.
3.4 (0 pen) Inspection Followuo Item 498:499/9331-17: The Licensee Did Not
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Resolve Several Chronic Fire Protection Issues In a Timely Manner.
The Issues Included Excessive Shrinkaae of Penetration Seals. an Unreliable Fire Alarm System. a Laroe Backloa of Service Reauests on Fire Protection Systems. and Inadeauate Control of Transient Combustibles in the Plant The inspectors determined that the licensee had adequately addressed the problem of penetration seal shrinkage as noted in paragraph 2.4.3 of this report.
Paragraph 2.2.4 provides information to disposition the concern of an unreliable fire alarm system. The licensee's satisfactory control of transient combustibles is noted in paragraph 2.5.3.
This item remains open pending the licensee's satisfactory disposition of the adequacy of the
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material condition of fire protection systems by reducing the corrective maintenance backlog.
3.5 (0 pen) Inspection Followuo Item 498:499/9331-22: The Licensee Did Not
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Resolve Numerous Fire Protection Issues In a Timely Manner. The Issues included Excessive Shrinkaae of Penetration Seals, an Unreliable Fire Alarm System. a Lerce Backloa of Service Reauests on Fire Protection Systems. and inadeauate Control of Transient Combustibles in the Plant
These identical issues are addressed in paragraph 3.4 above.
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3.6 (0 pen) Inspection Followup Item 498:499/9331-75: The NRC Will Assess
Action to Resolve Fire Protection Deficiencies at STPEGS.
These Deficiencies Included:
(1) Fire Protection Computer Alarm System and Operator Trainina on the System: (2) a Larae Backloa of Service Reouests on Fire Protection Systems: (3) Control of Transient Combustibles in the Plant: and (4) Fire Briaade leader Qualifications and the Impact on
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Operations Staffina
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Paragraph 2.1.4 addresses the licensee's action to improve the fire brigade leader training and the impact on operations, due to a lack of qualified brigade leaders, and the current fire brigade leader qualification. The
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computer alarm system and control of transient combustibles were addressed in paragraphs 2.2.5 and 2.5.3 of this report. Within this item the only item requiring further corrective action by the licensee was the service request backlog for fire protection systems, s
4 CLOSED ITEMS RELATED TO RESTART ISSUES
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The inspectors reviewed the licensee's actions to address the following issues related to fire protection and prevention.
4.1 (Closed) Violation 498:499/9309-01:
Failure to Store Transient
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Combustibles in Accordance With the Recuirements of the Fire Protection Procram Licensee actions described in paragraph 2.5.3 of this report provide
substantiating details that addressed the licensee's effort to resolve this issue.
4.2 (Closed) Inspection Followup Item 498:499/9331-33: Technical Services will Further Support Operations by Oualifyina More Personnel as Fire Briaade Leaders Licensee actions described in paragraph 2.1.4 of this report provide substantiating details that addressed the licensee's effort'to resolve this issue.
4.3 (Closed) Inspection Followuo Item 498:499/9331-58:
A Proaram Modification to the Fire Protection Computer Revisina Over 1000 Alarm Messaaes to a More User Friendly Format Which Provides the Tvoe and-Location of Each Fire Alarm Device and Automatically Provides a Hard Copy Printout of the Associated Fire Pre-Plan Document Number for Ease of Reference Will be Installed.
The licensee's implementation of DCN JD-1261, which upgraded the format and content of computer fire alarm messages as described in paragraph 2.2.3 of
this report, resolved this issue.
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ASSESSMENT OF MANAGEMENTS RECEPTIVENESS TO IDENTIFYING AND CORRECTING PLANT PROBLEMS The inspectors determined that licensee management had responded in a l
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proactive manner to identified fire protection and prevention problems.
Actions taken included: a major enhancement of the fire brigade leader
training program, a demonstrated reluctance to defer emerging work, contracted '
assistance obtained to improve the material condition of the fire detection and suppression systems, and the rigorous adherence to the operational
readiness program for fire protection and prevention.
These positive actions were indicative of management-driven initiatives that should result in improved reliability of fire protection and prevention.
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ATTACHMENT
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1 PERSONS CONTACTED 1.1 Licensee Personnel H. Bergendahl, Manager, Technical Services
J. Blevins, Supervisor, Records Management and Administration B. Brown, Supervisor, Mechanical Fluid Systems J. Calloway, Participant Services
M. Chambers, System Engineer, Plant Engineering Department
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J. Conly, Licensing Engineer, Nuclear Licensing
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T. Cloninger, Vice President Nuclear Engineering W. Cottle, Group Vice President, Nuclear D. Daniels, Administrator, Corrective Action Group
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J. Groth, Vice President, Nuclear Generation E. Halpin, Systems Manager, Plant Engineering Department A. Harrison, Supervising Engineer, Nuclear Licensing S. Head, Deputy, General Manager Nuclear Licensing
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T. Jordan, General Manager, Nuclear Engineer W. Jump, Assistant to Group Vice President, Nuclear M. Kanavos, Manger, Mechanical and Nuclear Engineering, Design Engineering Department D. Keating, Director, Independent Safety Engineering Group
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A. Khosla, General Supervisor, Chemical Operations
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J. Labuda, Supervisor, Fire Protection M. Ludwig, Manager, Nuclear Training L. Martin, General Manager, Nuclear Assurance L. Myers, Plant Manager, Unit 1 M. Pacy, Manager, Design Engineering G. Parkey, Plant Manager P. Parrish, Senior Specialist, Nuclear Licensing E. Stansel, Division Manager, Plant Engineering Department C. Stephenson, Licensing Engineer, Nuclear Licensing
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J. Sheppard, General Manager, Nuclear Licensing
S. Thomas, Assistant, Vice President Nuclear Engineering D. Tower, Supervisor, Quality Assurance
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L. Walker, Licensing Engineer, Nuclear Licensing W. Waddell, Manager, Operations Support K. Wissman, Engineer, Material Technical Service Nuclear
The personnel above attended the exit meeting.
In addition to the personnel l
listed above, the inspectors contacted other personnel during this inspection period.
1.2 NRC Personnel
M. Satorius, Pr Engineer
D. Garcia, Reside.
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2 EXIT MEETING
An exit meeting was conducted on October 22, 1993.
During this meeting, the i
inspectors reviewed the scope and findings of this report. The licensee did not express a position on the inspection findings documented in this report.
The licensee did not identify as proprietary any information provided to, or reviewed by, the inspectors.
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