IR 05000528/1994008

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Insp Repts 50-528/94-08,50-529/94-08 & 50-530/94-08 on 940214-18.No Violations Noted.Major Areas Inspected: Implementation of Fire Protection & Prevention Activities
ML17310B151
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 03/17/1994
From: Ang W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML17310B150 List:
References
50-528-94-08, 50-528-94-8, 50-529-94-08, 50-529-94-8, 50-530-94-08, 50-530-94-8, NUDOCS 9403310098
Download: ML17310B151 (16)


Text

APPENDIX U. S.

NUCLEAR REGULATORY COMMISSION

REGION V

Ins ection Re ort:

0 eratin Licenses:

Licensee:

~dill II d

Ins ection Conducted:

50-528/94-08 50-529/94-08 50-530/94-08

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NPF-41 NPF-51 NPF-74 Arizona Public Service Company P. 0.

Box 53999, Station 9082 Phoenix, Arizona 85072-3999 Palo Verde Nuclear Generating Station Units 1, 2, and

Wintersburg, Arizona February 14 through 18, 1994 W. Wagner, Reactor Inspector

~ll dd Pa W. P. A, Chief Engineering Branch zi he Date Signed Ins ection Summar

Areas Ins ected Units

2 and

This announced, routine inspection reviewed the licensee implementation of fire protection/prevention activities and the licensee's actions for open items identified in NRC inspection reports.

NRC Inspection Procedures 64704 and 92701 were used as guidance for this inspection.

Safet Issues Mana ement S stem SIMS Item:

None Results:

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The inspector concluded that the licensee's fire protection/prevention activities observed were performed in an effective manner.

9403310098 940317 PDR ADOCK 05000528 Q

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Summar of Violation or Oeviations:

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No violations or deviations of NRC requirements were identified during this. inspection.

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Open Item 50-528/529/530/89-38-01 was closed (Section 2. 1)

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Open Item 50-528/529/530-91-21-03 was closed (Section 2.2)

Attachments:

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Attachment 1 Persons Contacted and Exit Meeting

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DETAILS

FIRE PROTECTION/PREVENTION PROGRAM (64704)

1.1 Administrative Controls Procedure Review The inspector reviewed a sampl'e of the *latest revisions of fire protection procedures.

This review was to assure continued compliance with the fire protection program procedures previously reviewed by the inspector.

The inspector found the majority of the changes were either administrative or involved an enhancement to the existing procedure.

Fire protection procedures were being revised to conform to the form and format requirements of 01AC-OAP01,

"Format and Content of Nuclear Administrative and Technical Procedures."

Procedural enhancements included adding reference to applicable fire protection codes or procedures.

The inspector found that the procedures were technically adequate to ensure continued compliance with the fire protection program.

1.2 Fire Protection Personnel Trainin The inspector reviewed the Fire Department's two-year training schedule.

The training schedule was divided into two sections.

One section covered general plant fire protection related responsibilities, and the other section addressed fire fighting practices and drills as described in 10 CFR 50, Appendix R.

Fire Department training courses were performed quarterly with required participation from all three Fire Department shifts (A, B, and C).

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CFR 50, Appendix R, training courses were repeated over a two-year period covering topics such as fire. hazards, fire behavior, and fire fighting strategies and procedures.

The inspector reviewed the training records and found that all three Fire Department shifts had attended the required training courses on contamination injury, impairments, self-contained breathing apparatus (SCBAs), sprinklers, and confined space rescue.

The inspector concluded that the Fire Department's training program was being implemented in compliance with 10 CFR 50, Appendix R.

1.3 Ins ection of Plant Fire Protection features The inspector conducted a walkdown of the fire protection systems and equipment in the fire pump house and the following Unit 2 plant areas:

the 70-foot level of the auxiliary building, the 100-foot level of the auxiliary building, the emergency diesel control equipment room, and the 100-fool level of the control building.

The control building walkdown also included the engineered safety features (ESF) switchgear room J-114, and the remote shutdown room J-113.

The purpose of these walkdowns was to verify the following:

Fire barriers (doors, penetration seals, fire dampers)

and cable raceway and equipment fire barriers were operabl l

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Portable fire extinguishers were operable.

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Housekeeping was being properly maintained.

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The general condition of fire suppression devices was satisfactory.

Transient combustibles were being properly controlled.

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Manual fire hose stations were operable and in good material condition.

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Fire detection equipment was operable.

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Compliance with procedure 14FT-'9FP06,

"Fire Equipment Locker and Emergency Equipment Cabinet Inspection."

During the walkdown, the inspector noted that the Emergency Equipment Cabinets, located by the control room and the DC equipment room, contained the required portable equipment necessary to support safe shutdown and fire response activities.

The inspector concluded that overall, the material condition of the fire protection features and the housekeeping in the fire pump house and the Unit 2 areas inspected were satisfactory.

During the walkdown, the inspector randomly selected eleven

CFR 50, Appendix R, emergency lighting units and two halon fire suppression system dampers to verify that the required functional test were performed.

The inspector reviewed the functional test records of these components and found that the operability for these components was satisfactorily demonstrated at the required frequencies.

1.4 Ade uac of Fire Protection En ineerin Involvement In Plant Fire Protection Problems The inspector discussed the role of fire protection engineering involvement in plant problems related to fire protection with plant personnel.

The inspector found that the Fire Protection Engineering Unit, along with the Work Control Unit and Maintenance Unit, were part of a department called Fire Protection Support Services (FPSS).

FPSS was originally established to reduce the corrective maintenance backlog that existed in 1991-92.

FPSS had since expanded their role to include daily interfaces with each Unit and the Fire Department.

The inspector reviewed five 1993 Engineering Evaluation Requests (EERs)

and four Condition Report/Disposition Requests (CRDRs) resolved by Fire Protection Engineering.

The inspector considered that Fire Protection Engineering was actively involved in initial resolution of fire protection feature problems.

The inspector also concluded that engineering support was adequate to assure prompt resolution of plant problems related to fire protectio '

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1.5 'Fire Protection S stem FPS Actuation The inspector reviewed 'the CRDRs assigned to Fire Protection Engineering to determine the number of FPS actuations that have occurred over the past two years.

The purpose of this review was to determine whether any FPS actuations had resulted in a plant transient, equipment failure, or a reactor trip.

The inspector found that five FPS actuations had occurred since 1992 which were documented on CRDRs.

The inspector's review of the CRDRs revealed that none of the FPS actuations had resulted in a plant failure, equipment failur'e, or a

reactor trip.

No violations or deviations from NRC requirements were identified.

FOLLOWUP (92702)

2.1 Closed Unresolved Item 50-528 529 530 89-38-01 Inade uate Dedication of Commercial Grade Items This item involved inspector-identified concerns regarding

.the adequacy of the licensee's procurement requirements for dedication of commercial-grade items for safety-related use.

The procurement program appeared to address the requirements for identifying each commercial-grade item's critical characteristics that must be inspected or tested to verify its suitability for use in a safety-related application.

However, the inspector was concerned with the technical adequacy of the dedication process. regarding insufficient verification of the critical characteristics.

The inspector had identified eight examples of inadequately dedicated commercial-grade procured items.

Five of the eight items were installed in the plant, the remaining three were available for installation.

Specific concerns involved the adequacy of the engineering evaluations associated with the dedication of these eight items.

The inspector's review of the engineering evaluations revealed that, in some cases, the critical characteristics were missing to properly dedicate the item, or, as in most cases, the method of verification was insufficient to verify the critical characteristics.

The licensee provided the inspector with additional information, including an engineering evaluation, regarding the eight identified examples of potentially inadequately dedicated commercial-grade procured items.

NRC Report No. 50-528/529/530/89-53 reviewed the licensee's evaluation and additional information addressing the inadequate dedication of the eight commercial-grade procured items.

The inspector's review of this information did not substantiate the licensee's conclusion that all items were acceptable for use.

Specifically, three of the eight items appeared to have been inadequately dedicated.

The technical adequacy of the dedication process regarding insufficient verification of the critical characteristics was a

concern for the procurement of the following safety-related items:

a camshaft hub drive, a journal bearing and throat bushing, and 153 packing gland eyebolts.

During this inspection, the licensee provided additional information regarding the verification of the critical characteristics for dedication of the

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eyebolts, 'the journal bearing and throat bushings, and the camshaft hub drive.

Testing laboratory reports provided information such as Certified Haterial Test Reports or Certificates of Conformance, attesting to verification of the item's critical characteristics.

The inspector reviewed the laboratory test reports for compliance with the applicable code material specification.

The inspector found that the required mechanical properties (hardness, yield and tensile strength, elongation and reduction of area)

and chemical composition were within the code specification requirements for the materials being dedicated.

The inspector also reviewed Procurement Engineering's enhancements to the commercial-grade dedication program.

The enhancements were made'o Procedure 12DP-OHC37 Revision 0,

"Commercial Grade Dedication Requirements,"

issued on June 30, 1990.

The inspector reviewed Procedure Change Notice (PCN)

Numbers 01 through 08 that were i'ssued, between August 1900 and January 1992, to procedure 12DP-OHC37.

The inspector reviewed these PCNs to determine the adequacy of the changes made to enhance the methods by which commercial grade items are dedicated.

The inspector concluded that the licensee had provided sufficient evidence to demonstrate that the critical characteristics were adequately verified for the commercial-grade procurement of the eyebolts, the journal bearing and throat bushings, and the camshaft hub drive.

Therefore, these items were properly dedicated for use in a safety-related application.

The inspector also concluded that the enhancements made to procedure 12DP-OHC37 provided adequate guidance to procurement engineers for establishing commercial grade dedication requirements.

2.2 Closed Followu Item 50-528 529 530 91-21-03 Identification of Thermo-La Fire Barriers This item involved the concern that it was difficult in some plant areas to identify which Thermo-Lag fire barrier enclosures were required for 10 CFR 50, Appendix R, and which were required for Regulatory Guide (RG) 1.75 "Physical Independence of Electric Systems."

CFR 50, Appendix R, fire barriers have a specified fire rating, dependent upon the period of resistance to standard fire exposure, of one-hour or three-hours as applicable for fire protection to ensure safe shutdown capability.

RG 1.75 fire barriers, required for electrical separation, are not fire rated, nor are the barrier structures required to be maintained at the same quality level of integrity as the

CFR

.50, Appendix R, barriers.

The inspectors were concerned, from a performance based inspection perspective, that neither the licensee's staff or NRC inspectors could readily identify Thermo-Lag fire barrier enclosures required for 10 CFR 50, Appendix R, compliance.

The licensee acknowledged the inspectors concerns and indicated that they would develop a method to field identify the

CFR 50, Appendix R, barriers and those required to meet RG 1.75.

The inspector reviewed CRDR 9-1-0073 which addressed actions the licensee had taken to determine field identification of Thermo-Lag fire barrier structures.

CRDR Action No.

13 provided a method to determine in the field, which Thermo-Lag installations were required for RG 1.75 and which were required for 10 CFR

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50, Appendix R.

To accomplish this the licensee developed a new set of drawings that were unit-unique showing the location of the Thermo-Lag installations for RG 1.75 requirements.

Unit-unique drawing had previously been developed and issued showing

CFR 50, Appendix R, Thermo-Lag installations.

Utilizing these two sets of unit-unique drawings, the inspector performed a walkdown of 10 CFR 50, Appendix R, and RG 1.75 Thermo-

'ag installations located at the 70-foot elevation.of the Unit 2 Auxiliary Building..

The inspector had no difficulty in identifying electrical raceways installed with 10 CFR 50, Appendix R, Thermo-Lag from those installed for RG 1.75.

The inspector concluded that the licensee had taken adequate measures to develop a method to field identify, without difficulty, the

CFR 50, Appendix R, fire barriers and those required to meet RG 1.75.

No violations or deviations of NRC requirements were identifie,~

ATTACHMENT PERSONS CONTACTED 1.1 Licensee Personel

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  • D Austin, Deputy Fire Chief Belford, Technical Advisor, Fire Protection Bauer, Senior Engineer, Nuclear Regulatory Affairs Crozier, Administrative Supervisor, Fire Department Czarnylas, Operations Supervisor, Fire Department Fisher, Manager, Fire Protection Support Services Flood, Plant Manager, Unit 2 Fongemie, Supervisor, Fire Protection Engineering Fountain, Supervisor, guality Assurance Monitoring Garrett, Manager, Fire Protection Gauge, Director, Plant Support Hoffman, Technical Advisor, Fire Protection Kanitz, Senior Engineer, Nuclear Regulatory Affairs Lamontagne, Supervisor, Procurement Engineering O'eill, Senior guality Assurance Monitor Sattelmaier, Standards Coordinator, Fire Department Webb, Technical Advisor, Fire Department 1.2 Other Personnel
  • J. Draper,.Site Representative, Southern California Edison Company
  • F. Gowers, Site Representative, El Paso Electric
  • R. Henry, Site Representative, Salt River Project 1.3 NRC Personnel

+A. MacDougall, Resident Inspector The inspector also held discussions with other licensee and contractor personnel during the course of the inspection.

  • Denotes those attending the exit meeting on February 18, 1994.

EXIT MEETING An exit meeting was conducted on February 18, 1994.

During the exit meeting, the inspector reviewed the scope and findings of the report.

The licensee acknowledged the inspector's findings as identified in this report.

The licensee did not identify as proprietary any of the information provided to, or reviewed by, the inspector during this inspectio l I

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