JPN-92-014, Responds to Open Items Noted in Special Team Insp 50-333/92-80 of Fire Protection Program.Util Will Perform Any Mods Necessary to Assure Plant Can Be Shutdown in Event of Fire.Schedule for Completion of 16 Open Items Encl

Responds to Open Items Noted in Special Team Insp 50-333/92-80 of Fire Protection Program.Util Will Perform Any Mods Necessary to Assure Plant Can Be Shutdown in Event of Fire.Schedule for Completion of 16 Open Items Encl

ML20094P512
Person / Time
Site:	FitzPatrick
Issue date:	03/27/1992
From:	Ralph Beedle POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
JPN-92-014, JPN-92-14, NUDOCS 9204080190
Download: ML20094P512 (7)

Text

. .._ __.___.._._ _ _ _

O*' j 1

1. b NewYorkPower o.,-,,,,,,

I

& Authority ,

Msrch 27,1992 '

JPN 92014 l

Regional Administrator l

U. S. Nuclear Regulatory Commission 1 475 Allendal0 Road King of Prussia, PA 19406 '

GUBJECT: . James A. FitzPatrick Nuclear Power Plant Docket No. 50 333 Fire ProteWon Program

REFERENCES:

1. NYPA lettsr, R. E. Boedle to the NRC, dated August 16,1991 (JPN 91443),

regarding a schedule for the short term fire protection actions,

2. NYPA letter, R. E. Boedle to the NRC, dated September 13,1991 (JPN 91 050), regarding a schedule for the long term fire protection acnons.

Dear Sir:

The Authoriti has been conducting an extensive review of the Fire Protection Program at the FitzPatricx plant. As a result of this ongoing effort, the Authority has i entified deficiencies in the program. Recently the NRC conducted a Special Team inspection (92 80) of the FitzPatrick Fire Protection Program.'.During the exit meeting cn March 20,1992, the NRC identified sixteen cyn items. This letter bhefty summariz6a the Authority's actions to resol a inese open items.

The Authority will complete significant fire protection progremri aric improvements, including a root cause analysis, prior to startup f om the current refueling outage. Specifically, any modifications or program improvements neesssary to assure that the plant can be safely shutdown in the event of a fire will be completed prior to startup. The meterial condition of the i plant will be improved to reduce the probability of a fire. The deficiencies in the fire brigade equipment, training and procedures w41 be corrected.

Work on these improvements has already startod. To improve the physical condition of the ,

n plant, all work was stopped until unnecessary transient combustibles were removed from the s@$ plant. Hot process fire watch personnel and station fire watch personviei are being retrained. A QO'- new Safe /A!!arnetive Shutdown Analysis is being completed. Be draft anatysis anct ns gk recommendations were discussed with the NRC inspection team.

50 38 m<

TC 2 g(lZ[f gg L T'* G'70108 CJ Fge 7 G4'

\ k0#g

j -

1 All the elemonts of the FitzPatrick Fire Protection Prooram have not boon finalized.

Specifically, issues identified by the new Safu/ Alt 6mative Shutdown Analysis are being evaluated by Engineering and resolutions are being developod. Technically justifiable iritonm compensatory measures may be developod for some of the issues and implementod for modifications requiring long load times. A description of the issuo and the associatod compensatory measures will bo submitted to the NRC for review.

Attachment 1 is the Authority's schedute for resolving the sixtoon open items discusted at the exit mooting. In addidon, the Authorrty will provide a comprohonsive plan and schedule to address fire protection issues by A.pril 15,1992. The plan will includo the alsovo sixtoon open

tems; the long term and short term actions discussed in References 1 and 2; and a schedulo for the completion of each issue.

If you have any questions, please contact Mr. J. A. Gray, Jr.

Very tru!y yours,

/

/ *

^  ;.  ?

rat >h E. Osodle ExocutivaVice President Nuclear Gonoration ec: U. S. Nuclear Regulatory Comrrsssion ATTN: Document Control Desk Mail Stal!on P1 137 Washington, DC IXY45 Offico of the Resident inspector U.S. Nuclear Regulatory Commission PO Box 136 Lycoming, NY 13093 Mr. Brian C. McCabe Project Directorate I 1 Division of Reactor Projects 1/11 U. S. Nuclear Regulatory Commission Mail Stop 14 B2 Washington, DC 20555

. l

\

ATTACHMENT _1 TO JPN 92-014 (page 1 of 6)

I SCHEDULE FOR COMPLETION OF THE SIXTEEN OPEN ITEMS DISCUSSED ATTHE EXIT MEETINO FOR die NRC SPECIALINSPECTION (92 80) ON THE FITZPATRICK FIRE PROTECTION PROGFMM NUMBER DESCRIPTION SC,HEDULE 1 This item consists of the following:

a) No high impedance 'ault analysis Note 1

[NYPA identified itom) b) Lack of guidance to operators in To be fire responso procedutos to achieve resolved and a Sato shutuown and to assist with correctivo diagnosis of significant spurious actions actt,ations of equipment [ Discussed to be in DET Sect!:>n 2.32.8 (3)) implemented prior to startup.

) Fajluro to includo spurious To be actuation vulnerabilities in fire iosolved and responso procedures for correctivo communications and indication actions circuitry [NYPA identified itom; to be discussod in DET Section implomonted 2.32.8 (6)) prior to startup.

d) Lack of odginal or subsequent To be verification of illumination lovels resolved and of lighting [ Discussed in DET correctivo Soction 2.32.8 (7)] actions to bo implomonted prior to startup.

c) Unreviewod poter.tlal common modo Note i failuros of electrical cables due to lack of separation [ Discussed in DET Section 2.32 8 (9)]

\

l l

ATTACHMENT 1 TO JPN 92 01!.

(pago 2 of 6)

NUMBER DESCRIP110N SCHEDULE 2 This item consists of the following:

a) Assignment of only one indivictual Additional part timo to walk down the plant personnel for transient combustibles and will be tvaluate th conditon ol the firo assigr.ed protection system [ Discussed in prior to DET Section 2.3.2.8 (4)) startup.

b) Lack of a design basis document for See fite orotection [NYPA identified Reforonce 2 tiem; discwalin DET Soction 222.8(5)]

c) No procedares governing fire watcnos Additional (Discussed in DET Section proceduios 1.3.2.8(8)] will be developed and implomonted prio to ste.rtup.

d) Uncontrolled storago of flammables Appropriato in safety related oquipment rooms controls

[ Discussed in DET Section will be 2.328(10)] devoloped and implemented prior to startup.

3 Short and long term firo protection See ection lists Reforonces 1 and 2.

1 I

(

i i

ATTACHMENT 1 TO JPN 92 014

. (page 3 of 6)

NUMBER DESCRIPTION SCHEDULE 4 Corrective actions for the 43 items A schedule prewntly identified by the new will be Safo/Attornative Shutdown Analysis provided by April 15,1991.

Also see Note 3.

5 Use of ADS /LPCI shutdown methodology A decision in the new Safo/Altemative Shutdown on the Analysis methodology to be used will be provided by April 3,1992.

6 Validity of present shutdown methodology See schedule due to tM different systems used to for item 4.

achieve safe shutdown in the old Safe /Attemative Shutdown Analysis and the now Safe /Nternative Shutdown Analysis (10 CFR 50. Appendix R, Ill.G }

7 in walking down AOP 43,tha labeling To be and lighting was inadequate resolved and corrective actions to be implemented prior to stadup.

8 Configuration of the one-hour fire Note 3 baniers 9 inadequacies in the suppression and Note 2 detection systems, especially the design basis of the carbon dioxide system (i.e.,

sensors not installed at ceiling, system not designed to NFPA 72E, etc.)

?

- .- - . - , , . , - - - - , . , ,- _ _ . w-, ,

ATTACHMENT 1 TO JPN 92-014 (page 4 of 6) f[ UMBER DESCRIPTION SCHEDULE 10 No periodic testing of the safo shutdown Revice panois procedures and Completo SurveillanCO tosts prior to Startup.

11 Oporato<s tequiro walkthrough training of Training the AOP43 at least twice a year schedules will bo implomonted and operator an walkthrough will be conducted prior to startup.

12 Establish the basis for the two hours Information allowed after a fire to bogin the that was implomontation of AOP 58 p'ovided to the NRC during the inspection is presently under NRC roVio N.

No further information is requited from the Authority at this time.

._. m.__ _ -. .._ ~ . _ . _ _ _ . _ _ _ _ _ . _ _ __ _ _ _ _ .. _ . ._ _ _ _ . .__.___._

1 1

, 1

b '

I i

i ATTACHMENT 1 TO JPN 92414 (page 5 of 6)  !

NUMBER DESCRIPTION SCHEDULE '~

l 13 Inadequate emergency lighting due to To be physical problems (i.e., poor or no resolved and illumination, aimed incorroctly, cortactive i inadequate mountings, etc.) actions

[10 CFR 50. Appendix R. Ill.J) to be impkmented prior to startup. .

, 14 Inadequate emergency lighting due to Revise failute to include manufacturer procedures recommendations in the _ maintenance and and complete surveillance procedures [10 CFR 50, surveillance Appcndix R. Ill.JJ tests prior to startup.

15 Inadequacies in :he Fireorotection Weaknesses .

Program including Fire Plans, no and qualified personnel to issue bum inadequacios permits, controi c4 combustibles, to be i weakness in ignition source control, resolved weakness in f;te watch training, and weaknessirlfde brigade training,- corrective little hands-on trallWng (l.a., actual actions -

fires, equipment u*.4, etc.), inadequate to be * ,

pre-fire plans, outdated equipment, etc. implemented

[ Amendment 47 cithe RtzPatrick prior to  ;

Operating Ucetae ) startup.

16 Failure to take adequate corrective Note 4 actions on the findings from the QA audits of the Fire Protection Program

[10 CFR 50, Appendix Bj l NOTES:

1. This information is included in the new Safe / Alternative Shutdown Analysis.

i I

l l

l

• s. .--+e- o n,

ATTACHMENT 1 TO JPN-92-014 (pago 6 of6)

NOTES:

{ cont'd)

2. The following actions will be completed prior to startup:

a) Install a Battory Room Corridor Supprossion Systom; b) Install a Fire Detoction System north of ino Electric Bey; and c) Evaluato the adoquacy of the Automatic Fire Supptossion and Detection Systerns toquirod to support Appendix R and implomont componsatory actions as roquirod.

In adQtion, the following actions will be comploted after stattup:

a) Perform an NFPA Codo review and compile tho design basis for ex sting Firo Suppression and Detoction Systems and completo the NFPA Code review one year after startup; b) Evaluate, justify or mcdify the systems as required. Complete the evaluations, Jtntifications, and/or modifications one year after the completion of the NFPA Codo review; and c) Implomont required cynponsatory actions prior to any rocuirod modifications.

3. Althcugh the Authority will make every reasonable effort to complete these itoms prior to startups those items must be ovaluated by Enginoaring before the most affoctive solution or modification can be identified. Technically justifiablo interim componsatory measures may b6 developod and implomonted for modifications requiring long load timte. A description of the issue and the astaciated xr,1ponsatory measures will be submitted to the NRC for review.

4. The QA findings are being revieweded. This action wi!! be completed prior to startup. Training and procedural changes recommended by the review will bo implomonag! prior to startup. Modifications recommended by the review will be comp!oted as discussed in Note 3.

__-