ML14184A197
| ML14184A197 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 01/16/1980 |
| From: | Conlon T, Miller W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14184A192 | List: |
| References | |
| 50-261-79-29, NUDOCS 8003270317 | |
| Download: ML14184A197 (12) | |
See also: IR 05000261/1979029
Text
o,
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N.W., SUITE 31
ATLANTA, GEORGIA 30303
Report No. 50-261/79-29
Licensee:
Carolina Power and Light Company
411 Fayetteville Street
Raleigh, North Carolina 27602
Facility Name:
Robinson
Docket No. 50-261
License No. DPR-23
Inspection at Rob
son si
near Ha tsvi e, South Carolina
Inspector:
.
/
. H. Miller, Jr.
tate igned
Approved b:
T.
Conlon, Section
ief, RCES Branch
Date Signed
SUMMARY
Inspection on December 10-14, 1979
Areas Inspected
This special, unannounced inspection involved 36 inspector-hours on site in the
area of fire protection/prevention.
Results
Of the area inspected,
one deviation was found (Inadequate and substandard
control and sectional valves for fire protection water system).
8003270 317
DETAILS
1.
Persons Contacted
Licensee Employees
- R. B. Starkey, Jr., General Plant Manager
- C. W. Crawford, Manager of Operations and Maintenance
- F. Lowery, Operations Supervisor
- B. W. Garrison, QA Supervisor
D. H. Baur, QA Specialist
- H. S. Zimmerman, Manager of Technical and Administrative Services
- J. M. Curley, Engineering Supervisor
S. B. Clark, Plant Engineer
- M. C. Morrow, Engineering Technician
K. H. Dripps, Engineering Aide
J. Murray, Training Department
NRC Principal Inspector
- T..J. McHenry
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on December 14, 1979, with
those persons indicated in Paragraph 1 above.
3.
Licensee Action on Previous Inspection Findings
Not inspected.
4.
Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve noncompliance
or
deviations.
New unresolved items identified during this inspection are
discussed in Paragraphs 5.b.(50), 5.b.(72), and 6.a.
5.
Fire Protection/Prevention Modifications
This inspection evaluated the licensee's corrective action on the fire
protection modification and improvement commitments made to the NRC.
The
NRC Fire Protection Safety Evaluation Report (FPSER)
for this facility
dated February 28, 1978 (Amendment 31 to Operating License No. DPR-23) with
Supplement No.
1 dated September 4,
1979, and licensee's Fire Protection
Program Review -
APCSB 9.5.1,
H. B. Robinson Unit No.
2
(FPPR)
dated
January 1, 1977, were used in this evaluation.
These documents describe
-2
the fire protection modifications and improvements required and dates of
implementation. With the exception of the lube oil shielding system (FPSER
Item 3.1.21),
all items were required to be completed prior to the end of
the 1979 refueling outage.
The modifications and findings are as follows:
a.
The fire protection/prevention modifications, FPSER paragraph which
discusses the modifications and current status of the modifications
are listed in the following table. Additional information on all open
and on closed items identified by an * is included in Paragraph 5.c.
FPSER Comment
Number
Location/Item
Paragraph
Status
Diesel Generator Rooms (Areas 1 & 2)
5.1
(1)
Insulate fuel oil and
service water piping
3.1.17
Closed
(2)
Ventilation fans
3.1.18
Closed
(3)
Fire door (3-hr)/detectors
3.1.26
Closed
(4)
Fuel supply - operating pro-
3.1.25 &
cedure
3.2.6
- Open
(5)
Smoke seal for bus bar
5.1.6
Closed
(6)
Floor drain backflow device
3.1.27
- Closed
Safety Injection Pump Room (Area 3)
5.2
(7)
Fire detectors
3.1.2
Closed
(8)
Fire barrier/door (3-hr)
3.1.2
Closed
(9)
Fire damper
3.1.1
Closed
(10)
Cable coating
3.1.4
Closed
Charging Pump Room (Area 4)
5.3
(11)
Fire detectors
3.1.2
Closed
(12)
Fire door (3-hr)
3.1.3
Closed
Component Cooling Water Pump Room
(Area 5)
5.4
(13)
Fire detectors
3.1.2
Closed
(14)
Cable coating
3.1.4
Closed
(15)
Fire door (3-hr)
3.1.3
Closed
(16)
Fire dampers
3.1.1
Closed
(17)
Administrative Procedures
5.4.6 &
3.2.6
- Open
Hot Chemical Lab and Counting Room
(Area 6)
5.5
(18)
Fire detectors
3.1.2
- Closed
(19)
Fire door (3-hr)
3.1.3
Closed
(20)
Fire dampers
3.1.1
Closed
-3
FPSER Comment
Number
Location/Item
Paragraph
Status
Auxiliary Feedwater Pump Room
(Area 7)
5.6
(21)
Fire detectors
3.1.2
Closed
(22)
Fire door (3-hr)
3.1.3
Closed
(23)
Cable coating
3.1.4
Closed
(24)
Fire dampers
3.1.1
Closed
South Cable Vault (Area 9)
(25)
Carbon dioxide system
3.1.5
- Closed
(26)
Fire door (3-hr)
3.1.3
Closed
(27)
Cable coating
3.1.4
Closed
Auxiliary Building Hallway (Areas
5.8
(28)
Reroute hydrogen piping
3.1.12
Closed
(29)
Fire detection
3.1.2
Closed
(30)
Cable coating
3.1.4
Closed
(31)
Sprinkler system
3.1.6
- Closed
Demineralizer Room, Waste Evaporator
Equipment Room, Heat Exchanger Room,
Pipe Alley, and Waste Hold Tank-Room.
(Areas 1OD-1OH and 14)
5.9
(32)
Hose station
3.1.10
Closed
(33)
Fire dampers
3.3.3
Closed
(34)
Fire door/tank room (3-hr)
3.1.3
- Closed
(35)
Fire detectors
3.1.2
Closed
(36)
Administrative procedures
5.9.6 &
3.2.6
- Open
Auxiliary Building Entrance Area
(Area 11)
5.10
(37)
Fire doors
3.1.3
Closed
Solid Waste Handling Room (Area 13)
5.11
(38)
Pre-action sprinkler system
3.1.7
- &**Open
(39)
Fire dampers
3.1.1
Closed
(40)
Fire doors (3-hr)
3.1.3
Closed
Auxiliary Building Hallway-Upper Level
5.12
(41)
Fire detectors
3.1.2
Closed
(42)
Cable coating
3.1.4
Closed
-4
FPSER Comment
Number
Location/Item
Paragraph
Status
Chemical Stge, Boric Acid Tank
(Area 14D)
5.13
(43)
Fire door (3-hr)
3.1.3
Closed
(44)
Fire dampers
3.1.1
Closed
Battery Room (Area 15)
5.14
(45)
Fire door (3-hr)
3.1.3
Closed
(46)
Upgrade ventilation
5.14.6
- Closed
(47)
Ventilation flow monitor
3.1.23
- Closed
HVAC Room for Control.Room (Area 16)
5.15
(48)
Fire detectors
3.1.2
Closed
(49)
Storage cabinet
3.1.19
- Closed
Unit 2 Cable Spread Room and Computer
Room (Area 18)
5.16
(50)
Halon system/fire detectors
3.1.9
- Open
(51)
-
Fire dampers/Halon system
3.1.1
Closed
(52)
Cable coating
3.1.4
Closed
Electrical Equipment Area (Area 19)
5.17
(53)
Halon system/fire detectors
3.1.9
- Open
(54)
Fire dampers
3.1.1
Closed
(55)
Fire doors (3-hr)
3.1.3
Closed
(56)
Cable coating
3.1.4
Closed
Rod Control Room (Area 20)
5.18
(57)
Fire doors (3-hr)
3.1.3
Closed
(58)
Fire dampers
3.1.1
Closed
(59)
Cable coating
3.1.4
Closed
Control Room (Area 21B
5.19
(60)
Fire detectors for consoles
3.1
Closed
(61)
Fire door (3-hr)-"Hagan" Room
3.1.3
Closed
(62)
Upgrade electrical penetrations
3.1.24
Closed
(63)
Hose stations
3.1.10
- Closed
(64).
Standpipe deluge valve (5.19.6)
3.1.10
- Closed
(65)
Fire door (3/4-hr)-Kitchen
3.1.20
Closed
(66)
Kitchen smoke detector
3.1.20
Closed
(67)
Kitchen appliances
3.1.20
Closed
(68)
Fire extinguisher-(Water)
3.1.11
Closed
Relay ("Hagan") Room (Area 21C)
5.20
Closed
(69)
Fire detectors
3.1.2
Closed
(70)
Hose station
3.1.10
Closed
-5
FPSER Comment
Number
Location/Item
Paragraph
Status
Containment Cable Penetration Area
(Area 27A)
5.25
(71)
Fire detectors
3.1.2
- Closed
(72)
Fire extinguishers (large type)
3.1.11
- Open
(73)
Cable coating
3.1.4
- Open
Primary Coolant Pumps (Area 27B)
5.26
(74)
Fire detectors
3.1.2
Closed
(75)
Lub oil shield
3.1.21
- Open
(76)
Addition hose-outside contain-
3.1.10 &
ment
5.26.6
Closed
Containment (Area 27C)
5.27
(77)
Fire detectors-air recircula
tion units
3.1.2
- Closed
(78)
Fire extinguishers (large type)
3.1.11
- Open
-
RHR Pump Pit (Area 28)
5.28
(79)
Fire detectors
3.1.2
- Closed
(80)
Hose station-outside pit
3.1.10
Closed
North Cable Vault (Area 34)
5.7
(81)
Carbon dioxide system
3.1.5
- Closed
(82)
Fire doors (3-hr)
3.1.3
Closed
(83)
Cable coating
3.1.4
Closed
General Plant Areas
(84)
Emergency power supply for fire
detection systems
3.1.2
- Closed
(85)
Storage of combustibles (dry ion
exchange resin)
3.1.8
- Open
(86)
Replace hose racks with reels
3.1.10
Closed
(87)
Addition hose for stations
located at cable vaults, rod
drive room, containment exhaust
fan room and lower level of
auxiliary building
3.1.10
Closed
(88)
Separate fire water connection
with isolation valves
3.1.13
- Open
(89)
Self-containing breathing
apparatus
3.1.14
Closed
(90)
Fire fighting equipment storage
building
3.1.15
Closed
(91)
Portable ventilation equipment
3.1.16
Closed
(92)
Sound powered telephone cable
3.1.22
Closed
(93)
Electrical cable penetrations
3.1.24
Closed
-6
FPSER Comment
Number
Location/Item
Paragraph
Status
(94)
Protective posts for (PIV) post
indicator valves and fire
hydrants
4.3.1.3
Closed
(95)
Supervision of control valves
4.3.1.3
- Open
Notes:
- See comments in Paragraph No. 5.c.
- Not inspected due to high radiation.
b.
Procedures for Fire Protection Modifications
The following procedures and documentation data for the design, receipt,
installation, inspection and tests for the fire protection modification
were reviewed:
Number
Title
(1)
445A
Fire doors
(2) -445B
Ventilation system fire dampers
(3)
445C
Automatic fire detection and actuation systems
(4)
445D
Halon suppression systems
(5)
445E
Carbon dioxide suppression systems
(6)
445G
Fire water system
(7)
445J
Support (fire) walls
(8)
445K
Diesel generator room floor drains
(9)
445M
Battery room modification systems
(10)
445N
Fire retardant cable coating and smoke seal
c.
Findings
Additional information on the "open" items and on some of the "closed"
items in paragraph 5.a are listed below.
The below listed numbers
correspond to the numbered items in paragraph 5.a.
(1) The fuel oil makeup line to the "A" diesel formerly routed through
the "B" diesel room has been relocated to the exterior of the
structure. This arrangement should prevent a fire in the "B"
diesel room from affecting the fuel flow to the "A" diesel.
The
service water piping to the "B" diesel generator which is located
in the "A" diesel room has been enclosed with 3-hour fire rated
insulation.
(4) The review of the Administrative Fire Protection Procedures is
currently being conducted by NRC/(NRR).
This area will be exam
ined during a subsequent NRC/(IE) inspection and is listed as an
Unresolved Item (50-261/79-29-04),
Substandard Fire Protection
Adminstrative Procedures.
For details refer to paragraph 6.a.
-7
(6)
In lieu of providing a backflow device in each diesel generator
room floor drain, the former interconnected floor drains have
been revamped and arranged such that each drain discharges into a
separate storm drain pipe.
This arrangement appears to meet the
intent of the FPSER.
(17) Refer to Item (4) above.
(18)
The fire detectors installed do not cover all areas of the labora
tory and counting room; however the detectors are located in the
vicinity of the door penetrations to the adjacent fire areas which
contain safety related equipment and components.
This arrangement
appears to meet the commitments within the FPSER.
(25) The activation circuits from the fire detection system to the
fire suppression system are not electrically supervised.
The
licensee is to evaluate this feature to determine if this circuit
should be electrically supervised or the circuit frequently
tested during the surveillance inspection and tests of the fire
detection system. This item is identified as Inspector Followup
Item (50-261/79-29-05), Nonsupervised actuation circuits to fire
suppression systems, and will be reviewed during a subsequent NRC
inspection.
(31)
The sprinkler heads for the system in the auxiliary building hall
way are installed at the ceiling level as required by NFPA-13,,
"Sprinkler Systems" but due to obstructions created by ventilation
ducts, pipes, electrical ducts, etc., the system will not provide
adequate protection against fires involving transient combustibles.
However, the system appears to provide acceptable protection for
the electrical cables in the area which was the intent of the FPSER.
See also Item (25) above.
(34) A 3-hour fire door has been provided to separate the auxiliary
building corridor (fire area 10C) from the residual heat exchangers
and waste holdup tank room (fire area 10H) which appears to meet
the intent of the FPSER.
(36) Refer to Item (4) above.
(38) The preaction sprinkler system for this area was originally pro
posed to be activated by a combination of smoke detectors and
fixed temperature-rate compensated heat detectors.
However, the
(cement dust) within this area causes the smoke detectors to operate
and thus the transmission of false alarms.
Therefore, the licensee
has removed all smoke detectors from this system and is to initiate
a request to NRC/(NRR) for approval to replace the smoke detectors
with fixed temperature-type heat detectors.
This item will remain
outstanding pending the results of this evaluation and is identified
as Inspector Followup Item (50-261/79-29-06),
Actuation devices for
preaction sprinkler system in solid waste handling room.
Refer also
to Item (25) above.
-8
(46) &
(47) The battery room ventilation system has been modified by the
installation of two new exhaust fans and two supply air inlets in
the exterior wall.
The licensee has evaluated this design and
found that adequate ventilation should be provided.
Air flow
indicators have not been provided in the exhaust systems; however,
the 3 fans are supplied power from separate power sources and are
provided with power status indication in the control room.
This
arrangement appears to meet the intent of the FPSER requirements.
(49) The metal cabinet containing the storage of computer tapes has
been removed.
(50) The current design of the halon system for this area will provide
a 5% concentration of halon for approximately 8 minutes.
The
licensee advised that the system is to be redesigned so as to
maintain a 5% concentration for at least 15 minutes.
This item
will remain outstanding pending completion of the modifications
to the system and is identified as Unresolved Item (50-261/79-29
02), Halon system discrepancies.
Also, refer to Item (25) above.
(53) Refer to Item (50) above.
(63) The hose station has not been installed within the control room
but has been installed within the adjacent "Hagan" Room but is
equipped with sufficient hose to reach all portions of the control
room.
This arrangement appears to meet the intent of the FPSER.
(64) A dry pipe valve has been installed in the supply piping to the
control room ("Hagan"
Room) station in lieu of a motor operated
valve as indicated within the FPSER.
This arrangement appears
to meet-the intent of the FPSER.
(70) Refer to Item (63) above.
(72), (73) &
(75) D. Waters of CP&L advised M. Virgilio of NRC/(NRR) during a tele
phone conversation in March 1979 that the fire protection features
for the containment area were to be reevaluated and that the
portable fire extinguishers, coating of the electrical cables and
reactor coolant pump oil shield were not to be provided pending
the results of this evaluation.
The licensee is presently drafting
a letter to the NRC substantiating this conversation.
This item is
identified as Unresolved Item, (50-261/79-29-03) Fire Protection
Requirements for Containment, and will be reviewed upon completion
of this reevaluation.
(78) Refer to Item (72) above.
(81) Refer to Item (25) above.
-9
(84)
A new fire detection system has been provided for all safety
related areas of the plant.
The control panels for the new
system are supplied from emergency power panels.
This arrange
ment meets the intent of the FPSER.
(85)
Refer to Item (4) above.
(88)
The outside post indicator type control valve to the interior
fire hose (standpipe) system in the auxiliary building and the
sectional control valve in the northeast portion of the fire
protection water distribution system as indicated on construction
drawing No. 5137M2017RI were not installed.
A field change request
(FCR) was prepared by the licensee's construction division to delete
these two valves and to provide an interior control valve for the
standpipe system. This FCR (No. FCR-M-174) was initiated due to
the high water table in the area and due to obstructions created
by equipment and other structures existing in the area.
The FCR
was forwarded to the licensee's engineering division for review
but was rejected since the proposed change did not meet the require
ments of Section 3-3.1 and 3-5.1 of NFPA-24, "Outside Protection".
However, this FCR was accomplished without the approval of the
enigineering division and without the issuance of a design change
notice (DCN)
as required by the licensee's Field Change Request
Procedure No. AP-VII-02.
Table 4-1,
Item E.2.a in Section 4.0
of the FPPR states that the underground yard fire main loop
complies with NFPA-24,
"Outside Protection".
Section 3-3.1 of
NFPA-24 requires every connection from the yard main to a
building to be provided with a post indicator type valve.
Section 3-5.1
of NFPA-24 requires large yard systems to be
provided
with sectional controlling valves
at appropriate
points. Construction installation drawings were developed to
provide an adequate number of control valves in the system.
The
failure to follow these design documents resulted in the existing
system not meeting the requirements of NFPA and the commitments to
the NRC and is identified as Deviation Item (50-261/79-29-01),
Inadequate and substandard control and sectional valves for the
exterior fire protection water system.
Also, the failure to follow the construction documents resulted
in the installation of an interior non-indicating type control
valve which does not conform to the NFPA criteria.
The instal
lation of this nonconforming control valve is part of the above
deviation.
(95)
Refer to Item (4) above. Presently, all post indicator sectional
control valves and OS&Y type control valves are sealed in the
correct position and are inspected monthly.
Table 4-1,
Item
Nos. E.2.a.2.a.
and E.3.E.3.c. state that the fire protection
water system and automatic sprinkler systems will comply with the
-10
requirements of NFPA-24, "Outside Protection" and NPFA-13, "Sprinkler
Systems".
Section 2-14.2.3. of NFPA-13 and Section 3-6 of NFPA-24
requires control valves to either be locked in the correct position
or sealed in the correct position and inspected weekly.
The Admin
istrative procedures for the plant are currently being reviewed by
NRC/(NRR); therefore, this substandard method of supervising valves
is listed as an example of Unresolved. Item (50-261/79-29-04),
Sub
standard fire protection administrative procedures,
and will be
reexamined during a subsequent NRC inspection.
6.
Fire Protection/Prevention Program
The following items of the fire protection/prevention program for the plant
were reviewed:
a.
Procedures
The fire protection administrative control procedures for the plant are
currently being evaluated by NRC/(NRR).
However, a review of the plant's
Fire Protection Manual (Plant Operating Manual - Volume 19) indicates that
the current procedures do not fully meet the requirements of NRC document
"Nuclear Plant Fire Protection Functional Responsibilities, Administrative
Controls and Quality Assurance".
The licensee's Operations Surveillance
Report No. OQAS-79-13(R)
dated November 19-21, 1979, listed a number of
areas in which these procedures failed to meet various commitments to the
NRC. The licensee is currently reviewing and making a number of revisions
to the existing procedures.
Upon completion of the administrative review
by NRC/(NRR) and completion of revisions to the existing procedures by the
licensee, these procedures and their implementation will be evaluated during
an NRC/(IE) inspection.
This item is identified as Unresolved Item
(50-261/79-29-04),
Substandard Fire Protection Administrative Procedures.
b.
Fire Protection Systems
The following periodic test data on the fire protection systems and
equipment conducted in 1979 were reviewed and inspection frequency found
satisfactory except as noted:
(1) PT-9
Fire Protection Pumps and Power Supply (Monthly)
(2) PT-9.OA
Unit 2 Motor Driven Fire Pump and Fire Detection
(24OVAC) System (Monthly)
(3) PT-9.OB
Unit 2 Engine Driven Fire Pump and Water System Valves
(Monthly)
(4) PT-9.1
Fire Detection System Test (Semi-Annual)
(5) PT-9.2
Unit 1 Fire Pumps, Fire System Valves for Units 1 and 2,
Fire Detectors Crusher Pit (Monthly)
(6) PT-9.3
Inspection of Fire Protection System (Yearly)
(7) PT-9.4
Portable Fire Extinguishers, Fire Hose Stations and
Houses (Monthly)
Inspection records for March were not filed; however, licensee had
previously identified this problem and verified by inspections of
extinguisher inspection tags that the March inspection was apparently
conducted.
c.
Fire Protection Inspections
The most recent fire protection insurance inspections report on the
plant which was dated September 19-20,
1979,
and conducted by M&M
Protection Consultants for Nuclear Mutual Limited, was reviewed. This
report did not contain any current recommendations concerning safety
related areas within the plant. A review was made of the entire list
of previously withdrawn recommendations and it appears that all recom
mendations which were not corrected have been addressed by the FPSER.
d.
Fire Brigade Training and Drills
(1) A review was made of the fire brigade roster and training records
and found satisfactory. The shift assignments for December 8-14
were reviewed and indicated that at least 5 fire brigade personnel
were available on each shift for fire fighting operations as required
by the Technical Specifications.
(2) On December 13, 1979, representatives from the Hartsville and Pine
Ridge Volunteer Fire Departments were given a tour of the plant to
review the available fire protection and fire fighting equipment
and features.
Additional inspections and training sessions are
scheduled for key personnel from these departments during early
1980.
e. Facility Tour of Critical Fire Areas
A tour was made of the following critical plant areas:
(1) Cable Spreading Room
(2) Electrical Equipment Room
(3) Lower Level Hallway
(4) Battery Rooms
The housekeeping within these areas was satisfactory.
No open flame
type work was being accomplished in these areas.
The fire protection
equipment in the areas was found operational and appeared to be properly
maintained.