ML16342D852
| ML16342D852 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/29/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16342D850 | List: |
| References | |
| 50-275-97-17, 50-323-97-17, NUDOCS 9711050068 | |
| Download: ML16342D852 (28) | |
See also: IR 05000275/1997017
Text
ENCL'jQQF~
U.S. NUCLEAR REGULATORY COMMISSION
REGION
I I/
Docket Nos.:
License Nos.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved By:
50-275
50-323
DPR-82
50-275/97-1 7
50-323/97-1 7
Pacific Gas and Electric Company
Diablo Canyon Nuclear Power Plant, Units
1 and 2
7
/~ miles NW of Avila Beach
Avila Beach, California
September
15 through 19, 1997
D. Pereira, Reactor Inspector, Engineering Branch
P. Quails, Reactor Inspector
T. Stetka, Acting Chief, Engineering Branch
Division of Reactor Safety
Attachment:
Supplemental Information
97ii050068 97i029
ADQCK 05000275
8
-2-
X
TIV
M
RY
Diablo Canyon Nuclear Power Plant, Units
1 and 2
NRC Inspection Report 50-275/97-1?; 50-323/97-17
This inspection reviewed the licensee's
fire protection program and the processes
to
prevent; detect, and mitigate plant fires.
The inspection determined that Diablo Canyon's
fire protection program was effective.
The procedures
for the administration and implementation of the fire protection
program were considered to be effective (Section F3).
Both the fire brigade and the fire watch personnel were knowledgeable of the fire
protection program, including their respective duties, responsibilities, and re uired
ire. The use of annual medical examinations to assure that fire
i i ies, an
require
brigade personnel were physically able to perform their required duties as fire
brigade members was consid'red to be a positive indication of management
support
for the fire protection program (Section F5).
The fire protection program audits were found to be self-critical and aggressive.
The
'
i
e
annual audit, regarding the failure to perform sensitivit
te t
on several sm
smoke detectors, was considered to be an example of a failure of the fire
protection corrective action program and to be a violation (Section F7).
The fire protection equipment was being effectively maintained.
H
k
maintained and
e
aine
.
ouse
eeping was
maintaine
and, except for the intake structure, there was no buildup of tra
'
materials.
There was a lack of control of transient combustibles
in the
i upo
intake structure, which was considered to be a violation (Section F8.1).
The fire barrier seal reverific
'ation program appeared to be progressing
as planned.
The program was effective in ensuring that adequate
seals were installed in fire
barrier penetrations
(Section F8.2).
-3-
R
or
De ails
mmr
fPI n
Units
1 and 2 remained at full power for the duration of the inspection period.
V.
I
S
F3
Fire Protection Procedures
and Documentation
a,
n
i n
47 4
The inspectors reviewed the fire protection program implementation procedures to
ensure technical adequacy
in the following areas: combustible material control, fire
hazard reduction, housekeeping,
fire control capabilities, and maintenance evolutions
that involved a high risk of causing
a fire.
In addition, the inspectors reviewed
associated
action requests,
and interviewed management
and working level
personnel.
b.
v in
Fi
The inspectors determined that Program Directive OMS established
the overall policy
for the fire protection program.
Procedure OMS provided the program objectives,
requirements,
responsibilities, and key implementing documents for the program.
The inspectors determined that one of the key implementing documents
was the
inter-departmental Administrative Procedure OMS.ID4, "Control of Flammable and
Combustible Materials," Revision 5, which specified the administrative controls for
transient combustible materials.
The scope of this procedure limited and controlled
the introduction of bulk quantities of combustible materials and maintained them
within the design basis of the fire hazards analysis.
The inspectors verified that Procedure OMI.ID4 provided for the control of
flammable and combustible liquids, flammable compressed
gases,
and ordinary
combustibles.
In addition, the inspectors noted that Procedure OMI.ID4 provided for
the granting of transient combustible permits which specified material type, amount
and weight, start and removal date, and compensatory
measure requirements.
C.
The inspectors concluded that the licensee had effective procedures for the
administration and implementation of the fire protection program.
r
-4
F5
Fire Protection Staff Training and Qualification
ln
in
47 4
The inspectors evaluated the fire brigade and fire watch personnel to dete
'
o
e ermine t eir
'i y o prevent and fight fires.
The inspectors reviewed records of the fire brigade
training and personnel medical records with the plant's doctor.
Also, the inspectors
interviewed fire brigade and fire watch personnel to determine their skills,
knowledge, and physical ability to fight fires.
rv in
Fini
The inspectors'nterviews
of three fire brigade personnel indicated a hi h I
f
knowfed
e and
r
'
g
training in fire fighting, confined space retrieval methods
h
d
i
ica e
a
ig
evelo
materials
handl'andling, and emergency medical technician training.
In addition, the
o s,
azar
inspectors noted that fire brigade personnel were maintaining themselves
in good
physical condition.
The inspectors'nterviews
also indicated that the fire brigade
was comprised of both licensed and nonlicensed operators,
and that the licensee
was planning on separating operations personnel from fire brigade duties.
The
inspectors determined that in.all cases for the dates sampled, there were five fire
briga
e personnel onsite as required by the Technical Specifications.
The ins ectors
e
ire
riga
e
id not include the shift supervisor or other members of
s.
e inspectors
the minimum shift crew necessary
for safe shutdown of the unit.
The inspectors reviewed several fire brigade personnel reco ds
h
h
f
d
r, w ic
con irme
a
ig
eve
o continuing and refresher fire fighting training.
The inspectors noted
that this trainin
includ
' 'd fire fighting practical exercises,
instruction in events at
other facilities, such as the Waterford Steam Electrical Station, Unit 3, electrical fire,
confined space retrieval methods,
and hazardous
material handling.
The inspectors reviewed
11 fire brigade medical records with the licensee's doctor.
The inspectors verified that an annual medical examination of fire brigade personnel
was conducted and forwarded to the appropriate personnel for notification.
In
a dition, the inspectors verified that any individual unfit for the fire bri ade was
an
notification of such removal was sent to operations and plant
u
i
or
e
ire
riga
e was
management
personnel.
In these cases,
the licensee's doctor placed the individual
on a
itness or diet schedule to correct the condition and enable the individual to
resume active fire brigade status.
-5-
The inspectors interviewed three fire watch personnel to determine their knowledge
de
c
of duties, responsibilities,
and required actions in case of
f'
Th
etermined that the fire watches were knowledgeable of their duties.
During the
interviews, the inspectors determined
that additional duties assigned
to fire watch
personnel were:
to extinguish fires when the fire was within the capability of the equipment
available
N
to ensure welding personnel follow welding permit requirements
to meet the requirements of cnntinuous and hou;ly roving fire watches when
fire protection systems or fire barriers were impaired
The inspectors conducted
a plant tour in both units with one of the fire watch
personnel.
The inspectors verified that the fire watch knew the fire system
impairments in the toured areas and was knowledgeable of combustible loading
requirements.
The inspectors noted that the fire watch knew the classes
of fires
and the required extinguishers needed to suppress them.
I
i n
The inspectors concluded that both the fire brigade and fire watch
I
ire wa c
personne
were
now e geab e of the fire protection program, including their respective duties,
responsibilities,
and required actions in case of a fire. The inspectors noted that the
annual medical examinations for the fire brigade were a positive indication of the
licensee's support in ensuring that the fire brigade personnel were physically able to
perform their required duties as fire fighters.
F7
Quality Assurance
in Fire Protection Activities
47 4
The inspectors reviewed four quality assurance
audits to determine the level of
involvement in and compliance with fire protection activities as required by the Final
Safety Analysis Report and license conditions.
In addition, the inspectors
interviewed the auditors and reviewed selected action requests from these audits.
rv
i n
n
Fi
in
The inspectors found these audits to be aggressive
and self-critical and to be
Audi
identifying problems within the fire protection program.
0
d'e
au it,
u it
MS 970150021, "1997 Annual Fire Protection Prevention Audit,"
0
-6-
dated May 8, 1997, and conducted from February 21 through April 10, 1997, was
found to have a negative finding that remained uncorrected.
The uncorrected
negative finding involved a lack of smoke detector sensitivity testing.
This audit
finding was documented
in Action Request A0432046.
Action Request A0432046, identified an inconsistency with the National Fire
Protection Association (NFPA) Code, Section 72, licensing commitment.
The
licensing commitments in the Final Safety Analysis Report and NRC Branch
Technical Position 9-5.1, required that smoke detec:ors satisfy the requirements of
NFPA 72, in that sensitivity testing be conducted
in accordance with the
manufacturer's
instructions.
The audit also identified that the following detectors
did not have the required sensitivity testing completed in the past 5 years:
Unit
1 - Panel B, Zone 15,
Detectors 10 and 12 and Zone 3, Detector 3
Unit 2 - Panel B, Zone 15,
Detector 10
The licensee summarized the issue to the inspectors by stating that in 1979, the
beginning year for the smoke detector testing, they decided to perform a smoke
detector operability test every 6 months and a sensitivity test annually.
This was
consistent with th'e manufacturer's
instructions, which stated that a semi-annual
smoke detector operability test was adequate
to determine detector functioning and
that sensitivity testing should be done periodically.
In January 1988, Action Request A0096909, was initiated to identify a problem
with the inaccessibility of smoke detectors
in the 12 kV switchgear rooms.
This
inaccessibility affected the ability to perform detector sensitivity testing, in that
testing personnel
had to be able to access the detectors to perform the testing.
Subsequently,
between 1988 and 1993, approximately 21 additional action requests
were written documenting problems associated
with inaccessibility and the resultant
lack of sensitivity testing of various smoke detectors.
The subject action requests
identified approximately 24 detectors out of a population of 627 detectors, which
were inaccessible
and, therefore, lacking sensitivity testing.
In 1994, the licensee changed the frequency for performing sensitivity testing from
1 to 5 years based on a generalized performance history for the detectors.
The
licensee stated that the 1993 NFPA code required that the detector sensitivity be
within a certain range following initial installation testing, followed by another test in
1 or 2 years, prior to extending the sensitivity testing frequency to 5 years.
From
this generalized performance history, the licensee determined that detector
sensitivity remained within the required range during the detector's initial sensitivity
test and all subsequent
tests.
Based on this information, the licensee considered
their position, regarding the extension of the testing frequency, to be justified and
implemented 5-year sensitivity testing.
In all cases,
the licensee routinely conducted
-7-
the smoke operability test of the subject detectors every 6 months.
The inspectors
noted that this smoke operability test was conducted with a smoke generator,
which did not require access to the detector and that this test verified proper
operation of the detector and its associated
alarm.
4
The licensee initiated Action Request A0444378, as the result of this NRC
inspection, to investigate the resolution of smoke detector inaccessibility and lack of
sensitivity testing for the detectors identified in Audit EDMS 970150021.
The
licensee researched
the NFPA code and their licensing requirements to determine the
appropriate corrective actions and concluded that they were committed to
Section 72E of the NFPA code for sensitivity testing.
NFPA Code, Section 72E,
required
a 5-year sensitivity testing frequency based on the demonstrated
ability of
the detectors to remain within their required range during this period.
Following review of the licensee's investigation, the inspectors determined that the
licensee completed sensitivity testing on 20 of the 24 smoke detectors, but had not
performed sensitivity testing on the four detectors identified by the audit.
While the
inspectors considered the 5 year sensitivity testing interval to be justified, the
inspectors noted that the sensitivity testing for three detectors in Unit
1 and one
detector in Unit 2 exceeded the 5-year interval and still had not been accomplished.
Operating License DPR-80, Condition 2.c(5) (Unit 1) and DPR-82, Condition 2.c(4)
(Unit 2), states that Pacific Gas and Electric Company shall implement and maintain
in effect all provisions of the approved fire protection program as discussed
in the
Final Safety Analysis Report.
Appendix 9.5 B to the Final Safety Analysis Report
required that nonconformances
be promptly corrected.
The failure to promptly
correct the lack of the required sensitivity testing for the smoke detectors was
considered to be a violation of the fire protection corrective action program
(50-275;-323/971 7-01).
i n
The inspectors concluded that the fire protection program audits were self-critical
and aggressive.
The inspectors also concluded that the findings in the 1997 annual
audit, regarding the failure to perform sensitivity testing on several smoke detectors,
was an example of a failure of the fire protection corrective action program.
This
was considered to be a violation of this program.
FS
Miscellaneous
Fire Protection Issues
F8.1
~PI-i~nT~r
In
in
The inspectors toured the
I
p ant to visually inspect and assess
the implementation of
the fire protection
ro ram
r
p
g am procedures
and to determine if transient combustible
materials were being properly controlled.
The inspectors also observed firefighting
equipment and the turnout protective clothing (protective gear worn during
.firefighting activities) of the fire brigade to determine availability and operability
that no buildu
The inspectors observed that, in general, housekeeping
was well rn
'
'
d
p of transient combustible materials was noted.
Durin
the
ain aine
an
walkthrough ins ection t
uring t e
between the fire
rp,
he inspectors observed discussions
regarding th
p otection staff and various other site personnel.
The ins
i g
e program,
noted that the fire
rotection
nne
.
e inspectors
p
tion personnel had a very good working relationshi
with
other onsite organizations.
Ip WI
The inspectors also observed the fire brigade's firefighting equipment.
The
inspectors determined tha
was
ro erl
s o
at the firefighting equipment was in excellent co d't'
p
p
y t red and secured.
In addition, the inspectors noted that the fire
n iionan
brigade locker was ins ected
a
p
nd inventoried weekly. The inspectors reviewed the
fire brigade's turnout clothing and noted that they were in each fire brigade
member's locker and in excellent condition.
'uring
an inspection of the intake structure, which contained redundant trains of
safety-related equipment, the inspectors observed the following:
Five aerosol cans and a one gallon plastic container of flammable liquid
stored in lockers that were not flammable liquid lockers
Several untreated wooden pallets
Combustible
acka
in
p
g'
material consisting of several cardboard boxes, which
were storing work-related materials
Combustible materials consisting of a pla t'
'
left un
s ic c air an
a temporary air duct
permitted
e t unattended
and located in a area in which combu t'bl
us
i
e materials were not
-9-
Technical Specification 6.8.1 requires the implementation of the fire protection
program procedures.
Procedure OM8.ID4, "Control of Flammable and Combustible
Materials," Revision 5, required in Section 4.4 that flammable liquids be stored in
flammable liquid cabinets when not in use; Section
4.2 required that wood used in
areas containing safety-related
equipment be fire retardant treated; Section 4.6
required that combustible packaging material inside the plant be removed and
disposed of as soon as possible; and Section 4.8 required that combustible materials
taken into a red painted, non combustible storage area be attended at all times.
The
failure to adhere to the requirements of Procedure OM8.ID4 was contrary to the
requirements of Technical Specification 6.8.1 and was considered to be a violation
(50-275;-323/971 7-02).
C.
nl in
combustibles
in
F8.2
i
rri r
n
The inspectors concluded that the fire protection equipment was being effectively
maintained and, except for the intake structure, that housekeeping
was maintained
with no buildup of transient combustible materials.
The lack of control of transient
the intake structure was considered to be a violation.
The inspectors interviewed licensee personnel regarding the current status of the
Appendix A and Appendix R fire barrier penetration seal reverification program,
which was verifying the integrity of the seals in the fire barriers separating
. redundant safe shutdown trains.
During the plant tours, the inspectors visually
inspected numerous installed fire barriers to determine penetration seal condition.
b.
i n
n
Fin in
On January 30, 1997, the licensee met with the NRC staff concerning the ongoing
fire barrier penetration seal reverification program being performed at the site.
The
inspector's determined that the licensee's
schedule for completion of the
Appendix R reverification program was the end of 1997.
In addition, the inspectors
determined that the Appendix A reverification program would be completed by the
end of the second quarter of 1998.
-10-
During the reverification effort, which included approximately 13,500 seals, the
licensee stated that approximately 12 percent needed rework of some kind. Of this
12 percent, approximately half were reworked because
the seal was damaged
during the design reverification.
The licensee stated that, of the remaining 6 percent
of the seals, most were in place and would have inhibited the spread of a fire. Very
few seals were found to be missing.
During the plant tours, the inspectors visually inspected
a sample of fire barrier and
penetration seals in various plant areas.
All penetrations
inspected were properly
sealed.
The seals were well maintained and in good condition.
No seal
discrepancies
were noted by the inspectors.
The fire barrier seal reverification program appeared to be progressing
as planned.
The program was effective in ensuring that adequate
seals were installed in fire
barrier penetrations.
n
P r
r
The inspectors reviewed pyrocrete fire tests completed to test the installed barriers
and visually inspected pyrocrete fire barriers installed in the plant.
n
Fi
i
The inspectors observed that the fire test for the pyrocrete passed the 3-hour test
required by the NRC. The inspectors also observed that the configurations installed
in the plant were in accordance with the configuration tested.
CQQQIQRQQ'i
The inspectors concluded that the barriers installed in the plant were acceptable.
i n
The inspectors reviewed test results for the Ceilcote 658-N epoxy grout barrier
penetration seals.
Also, the inspectors visually inspected selected Ceilcote 658-N
epoxy grout fire barrier penetration seals installed in the plant.
-11-
rv in
n
in in
The fire tests were conducted at Omega Point Laboratories on December 20, 1996.
The tests were satisfactory for penetrations
where the penetrating item was no
greater than 6 inches, with a maximum gap of 0.50 inches between the penetrating
item and the concrete,
and a minimum depth of 7-5/8 inches.
The inspectors noted
no examples of Ceilcote 658-N epoxy grout penetrations
in the plant, which did not
meet the tested criteria.
C.
The inspectors concluded that the Ceilcote 658-N epoxy grout fire barrier
penetration seals installed in the units were satisfactory.
X1
Exit IVleeting Summary
The'team presented
the inspection results to members of licensee management
at
the conclusion of the inspection on September
19, 1997.
The licensee
acknowledged the findings presented.
The team asked the licensee whether any materials examined during the inspection
were proprietary.
No proprietary information was identified.
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
~in~,
R. T
B. W
>me
D. Allen, Resident Inspector
.
C. Belmont, Director, Nuclear Quality Services
B. Crockett, Manager, Nuclear Quality Servic
Elis, Fire Brigade Instructor, Learning Services
Grebel, Director, Regulatory Services
J.
Griffin Supervisor, Nuclear Quality Services
S.
Hamilton, Director Engineering, Nuclear Quality Services
D. Hampshire, Supervisor,
Fire Protection
Johnson,
Fire Marshal, Operations
S.
Ketelsen, Supervisor,
Regulatory Services
S.
Laforce, Engineer, Fire Protection
R.
M
F.
Peralt
artin, Technician, Regulatory Serv'vices
eralta, Consulting Engineer, Appendix R/Fire Protection
B.
D. Powell, Engineer, Fire Protection S
t
E
Powers, Vice President and Plant Manager
hierry, Director En in
hitsell
g'ering, Essential Services/Balance
of Pl
, Director, Nuclear Quality Services
o
ant
LIST OF INSPECTION PROCEDURES USED
IP 64704:
IP 92700:
Onsite Follow up of Written Re orts of N
por s o
onroutine Events at Power Reactor
ITEMS OPENED AND CLOSED
97-1 7-01
97-17-02
Chmd,
Failure of Fire Prote
otection Corrective Action to Correct the Lack of
Smoke Detector Sensitivity Testing.
Failure to Control Transient Combustible Materials.
LER 95-03-01
P
Untested Pyrocrete Fire Barriers
-2-
LER 96-11-01
Untested Ceilcote 658-N Epoxy Gro t F'
rout
ire
arrier Penetration Seals
DOCUMENTS REVIEWED
OM8,
OMB.ID1,
OMB.ID2,
OMB.ID3,
OMB.ID4,
AD4.ID1,
TQ1.DC12,
OP1.DC12,
OP AP-BA,
STPM-69A,
Lesson Guide
Fire Protection Program, Revision 2
Fire Loss Prevention, Revision 6
Fire System Impairment, Revision 5
Fire Watch and Welding Personnel Training and Res po
ma
e an
ombustible Materials, Revision 5
ousekeeping,
Revision 3
Fire Brigade Training, Revision 3
Conduct of Routine Operations, Revision 9
' '- stablishing Hot Standby, Revision 9
Control Room Inaccessibilit
-E
2321
onthly Fire Extinguisher Inspection
Revisio
21A
, Fire Suppression
Techniques,
Revision 0
1997 Annual Fire Protection and Loss Prevention Au
i
d t for Diablo Canyon Power Pl
t,
1996 Annual/Biennial/Triennial Fire Protection Au
'
rotection Audit, conducted from January 23 to
1995 Annual Fire Protection and Loss Preven
Audit 950071.
oss Prevention Audit, dated April 28, 1995,
Audit of Postfire Safe Shutdown, conducte
f
Audit 940231.
own, conducted from July 19 to August 3, 1994,
A0432046
A0444378
A0432034
A0432042
A0443795
A0443855
A0443816
A0392311
Fire/smoke detector sensitivity testin
5 I
n ime y Resolution of detector inaccessibility
Fire Watch Training Program development
Human Factors for Fire Watch requirements
Verify BOL 1-24R Lamp aiming and apply torque seal
Damaged
Fire Stop Material on Cable tray
Temporary equipment may be inappropriately attached
Excessive combustibles
in the plant computer rooms
-3-
A0426430
A0268853
Low Pressure
Cardox licensin
, Inadequate
Fir
q
Fire Suppression
System Testing