ML17055E027
| ML17055E027 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 07/20/1988 |
| From: | Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17055E026 | List: |
| References | |
| 50-220-88-15-EC, NUDOCS 8808010361 | |
| Download: ML17055E027 (46) | |
See also: IR 05000220/1988015
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
Docket No.
License
No.
Fac i 1 ity:
Location:
Date:
Approved by:
MEETING SUMMARY
88-15
50-220
Niagara
Mohawk Power Corporation
301 Plainfield Road
Syracuse,
13212
Nine Mile Point Unit
1
NRC Region
I Office, King of Prussia,
July 11,
1988
go A. g~~
J.R.
Johnson,
Chief, Reactor
Projects
Section
2C,
y/uoJap
Date
An Enforcement
Conference
was held to discuss
findings described
in
Inspection
Report 50-220/88-15,
dealing with the licensee fire protection
program
and specific deficiencies with fire protection barrier
8808010361
880721
ADOCK 05000220
G
PNU
0
DETAILS
Partici ants
Niagara
Mohawk Power Corporation
J. Endries,
President
J. Perry,
Vice President,
guality Assurance
C. Terry, Vice President,
Nuclear Engineering
and Licensing
J. Willis, General
Superintendent,
Nine Mile Point
S. Wilczek, Manager Nuclear Technology
G. Gresock,
Manager Nuclear Engineering
P. Finnerty, Fire Barrier Penetration
Task Manager
E. York, Fire Protection
Program Coordinator
G. Wilson, Attorney
M. Wetterhahn,
Attorney (Conner
and Wetterhahn)
Nuclear Regulatory
Commission
S. Collins, Deputy Director, Division of Reactor Projects
W. Johnston,
Deputy Director, Division of Reactor
Safety
'E. Wenzinger,
Chief, Projects
Branch 2,
ORP
J. Johnson,
Chief, Projects
Section
2C
,
ORP
R. Benedict,
Project Manager,
D. Holody, Enforcement Coordinator
J. Strosnider,
Acting Chief, Engineering
Branch,
T. Koshy, Acting Chief, Plant
Systems
Section,
W. Cook, Senior Resident
Inspector
W. Schmidt,
Resident
Inspector
J.
Lara, Reactor
Engineer
New York State
P.
Eddy, Site Representative,
New York State Public Service
Commission
~Pur ose
The Enforcement
Conference
was held at the request of NRC Region I to
discuss
the results of an inspection
conducted
by the
NRC resident
inspectors
on May
6 to 24,
1988 at Nine Mile Point (No. 50-220/88-15).
The report documents
that numerous fire barrier penetrations
have
been
determined
The report included
an apparent Violation of 10 CFR 50, Appendix
R,Section III.G.
This apparent violation deals with the
possibility that
a design basis fire has
the potential of damaging
both
remote
shutdown
panels
and the control
room resulting in the inability to
reach or maintain
HOT
SHUTDOWN.
Discussion
NRC management
convened
the meeting with a statement
of the purpose of the
Enforcement
Conference
and then turned it over to Mr. Endries the
President
of Niagara
Mohawk.
The Niagara
Mohawk presentation
followed the
Presentation
package
(Attachment 1).
During the presentation
the licensee
discussed
the status of their fire
protection
program dealing with fire barrier penetrations.
Barrier
walkdowns (observations)
have
been
completed
and correction of deficiencies
continues.
The method of assuring
the operability of penetrations
that
have not been,
or planned to be, destructively
examined
was. discussed.
This method is
a statistical
sampling
and destructive testing of penet-
rations.
The licensee
was requested
to review their plans for choosing
the population set
and to provide this to the
NRC.
The licensee
stated
that their complete evaluation of existing conditions
and their safety
significance
was not yet complete.
The safety significance of the breached
was discussed.
The
licensee
stated that
a violation of 10 CFR 50, Appendix
R, did not occur,
because
the plant could have
reached
HOT
SHUTDOWN with both the control
room (CR) and both remote
shutdown
panels
(RSP)
The licensee
would in this case rely on two trains of the Shutdown Supervisory Control
system
(SSC),
located
in the reactor building, to automatically initiate
both Emergency
Condensers
(EC).
Without the
CR and
RSP the cooldown rate
provided by the
ECs would not be regulated
and would exceed
100
F in one
hour.
The licensee
stated that exceeding this rate
has
been
analyzed
and
was not
a concern.
The licensee
was asked
to determine
the existence
of
or need for emergency
or abnormal
operating
procedures
detailing
the
use
of the
SSC since
the
NRC inspectors
were only aware
o7 procedures
specifying
operations
from the
CR and
RSP.
The root causes
of the problems
were discussed
and are listed on sheets
10,
11,
and
13 of Attachment
( 1).
Most significantly these
causes
point
to lack of effective management
of the fire protection
program, failure to
take appropriate
action
on deficiencies
already identified and lack of
engineering
dedication to the fire protection area.
Conclusion
Niagara
Mohawk maintains that the safety significance of the breached
was minor and that the fire protection
program
was very
extensive.
The licensee
also plans
on strengthening
the engineering
support provided to fire protection issues.
The
NRC staff acknowledged
the licensee
plan to come into full compliance prior to restart
and stated
that further inspection efforts would be directed to the area of fire
protection to determine
the effectiveness
of these actions.
The licensee
is still developing
plans to strengthen
the communication
and teamwork of
nuclear operations.
0
ATTACHMENT
NIAGARA MOHAWK POWER
CORPORATION
PRESENTATION
JULY 11,
$ 9BB
AGENDA
Introduction - J.
N. Endries
Background of Fire Protection
Program - G, J.
Gresock
Status of Current
Program - P. J. Finnerty
Safety Significance - G. J. Gresock
Root Cause
Evaluations - P. J, Finnerty
Corrective Actions - P. J. Finnerty
Overall
Root Causes - C.
D. Terry
Evaluation of Other Programs - G. J,
Gresock
Concluding Remarks - C.
D. Terry
0
BTP 9.5-1
H3D
CÃLETE
PENE.
PROGRAH
ON HOLD
MALKOOMN
I t@EPENOENT
VERIFICATION
QK RESPONSE
TO 9. 5-1
NM'1
9. 5-1
UL TEST
COlfLETE
QfC RESPONSE
TO APP,
R
CQFLETED T.S.
PENE.
INSPECTION
MISCONSIN TEST
COH'LETE
PENE.
DI SCOYERE
MITH MOOD
1976
1977
1978
1979
1988
1981
1982
APP.
R
PENE.
PROGBAH
UPGRADE
19&3
1984
1985
1986
1987
!
NLKDON
1988
O.T.P.
9. 5-1
APP.
A
APP.
R
APP.
B
GENERIC LETTER
SBP
I SSUED
EFFECTI YE
83-33
9.5.1
BEY.3
GENERIC LETTER
86-18
INFO.
NOTICE
88-N
3 REVISIONS
0
FIRE BARRIER PENETRATION REVIEW PROGRAM
Event Oescri tion
On March 26,
1988, six nonconforming fire barrier
were discovered
and reported via LER 88-09.
Based
on this discovery, additional
inspections
were
performed which identified additional
nonconforming fire
barrier penetrations,
leading to a 100% walk-down of all
required barriers.
FIRE BARRIER PENETRATIO
REVIEM PROGRAM
CURRENT
PROGRAM DESCRIPTIO
PERFORM A VXSUAL (NONDESTRUCTIVE EXAMINATION) OF
100~o
OF THE PENETRATXONS THROUGH REQUIRED BARRXERS AND-
REWORK PENETRATIONS CONSISTENT WXTH DESIGN
REQUIREMENTS.
PERFORM A DESTRUCTIVE EXAMINATION AND REWORK OF
PENETRATXONS,
WHICH THROUGH DRAWING RESEARCH,
ARE
CONSIDERED QUESTIONABLE.
VIA A STATXSTICAL SAMPLING PLAN,
PERFORM A
DESTRUCTXVE EXAMXNATION AND REWORK OF THE REMAINING
0
FIRE BARRIER PENETRATIO
REVIEW PROGRAM
RESULTS
OF WALK-DOWNS
O
PERCENTAGE
OF
REQUXRED BARRIER PENETRATIONS
OBSERVED
0
ESTIMATED PERCENTAGE
OF PENETRATXONS WXTH
NO DISCREPANCIES
0
ESTIMATED PERCENTAGE
OF PENETRATIONS WITH
ONLY FLAMEMASTIC (COSMETIC) DEFXCIENCIES
0
ESTIMATED PERCENTAGE
OF PENETRATXONS
THAT REQUXRE
FURTHER ANALYSIS
ESTXMATED PERCENTAGE
OF PENETRATIONS THAT
MILL NOT BE CAPABLE OF MAINTAININGTHE FIRE
BARRIER S RATING
FIRE BARRIER PENETRATION REVIEW PROGRAM
TYPE OF
ETRATIONS WXTH A QUESTI
ABLE FIRE RATING
0
PENETRATIONS CONTAINING WOOD PLUGS
0
PENETRATIONS WITH MORTAR DEFICXENCIES
0
PENETRATXONS CONTAINING PLASTXC PIPES
0
OPEN
PENETRATXONS
0
PENETRATIONS CONTAINXNG ONLY DUCT SEAL/PUTTY
0
OVERSIZED PENETRATIONS
PENETRATIONS WITH KAOWOOL DEFICIENCIES
MORTAR DEFICIENCIES
(6 1/2')
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X-Y7
(6 1/2')
Y7
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a
SAFETY SIGNIFICANCE
CRITERIA OF 3
HOUR BARRXER CONSERVATXVE
HAVE NOT TAKEN CREDIT FOR DETECTORS
AND SUPPRESSION
IN MANY AREAS
LXKELY J USTIFY LOWER RATING
0
FXRE HAZARDS ANALYSIS
0
SAFE
SHUTDOWN ANALYSIS
0
BARRXER PENETRATIONS PROVIDED A LEVEL OF PROTECTION
0
BARRIERS
NOT THE ONLY PROTECTION
DETECTORS
DEDICATED FXRE BRIGADE WITH MANUAL SUPPRESSION
IN MOST AREAS t
AUTOMATICALLY INITXALLY SUPPRESS ION
0
REDUNDANT TRAXNS
SAFE
SHUTDOWN CAPABILITXES
0
2
SHUTDOWN PANELS
0
4
CORE SPRAY SYSTEMS
0
2
EMERGENCY CONDENSER TRAINS
0
2
SHUTDOWN SUPERVISORY
CONTROL SYSTEMS
0
CONCLUSION TO DATE
r
SAFE
SHUTDOWN CAPABXLITIES NOT JEOPARDIZED
APPENDIX R,
SECTION III.G COMPLXANCE
ROOT CAUSE PROCESS
Specific Causes
of Penetration
Oeviations
Kepner-Tregoe
Systematic
Evaluation
Programmatic
Causes
of Penetration
Oeviations
HPES
Overall Root Causes
FIRE BARRIER PENETRATIO
SPECIFIC
CAUSE
0
INCOMPLETE DRAWING RESEARCH
0
PREVIOUS WaLK-DOWN TEAMS LACKED AN INDOCTRINATION
WITH THE UNIT 1 DESIGN DATA BASE
0
THE FXRE DEPARTMENT SURVEILLANCE PROCEDURE
ONLY
REQUIRED INSPECTXON
BY PENETRATXON DETAXL
0
ADEQUATE INSTRUCTXONS WERE
NOT PROVIDED BY
ENGINEERXNG TO INVESTIGATE POTENTIAL DEVXATXONS
DURING THE 1985 - 1986 TIME FRAME
0
LACK OF A FOLLOW-UP TO THE XNITIAL IDENTIFICATXON
OF A WOOD PLUG
(ilUNE 1981)
AND LACK OF A FOLLOW-UP
TO THE GAGE-BABCOCK AUDXT (1984 - 1986)
0
LACK OF A PROPER
UNDERSTANDXNG BY DESXGN AND
STATXON PERSONNEL
OF WHAT CONSTITUTES A DEGRADATXON
OF A FIRE BARRIER
0
PRESENT
AND PAST PENETRATION SEALING DETAIL
DRAWXNGS DO NOT PROVIDE ADEQUATE INSTRUCTXONS
Pro rammatic Causes
Niagara
Nohawk did not recognize
the scope,
impact and
implementation
requirements
of the
commi
ment
Lack of an integrated
program plan and definition of
responsibilities
design data base
not maintained
Assumed
the
UL test program/Engineering
evaluations
encompassed
all exis
ing penetration configurations
Qa
FIRE BARRIER PENETRATION REVIEW PROGRAM
CORRECTIVE ACTIO
SCHEDULE
INITXATION OF
COMPENSATORY MEASURES
ASSXGNMENT OF A TASK MANAGER
C
REVIEW OF PLANT SPECIFIC
NRC COMMITMENTS
REVISION OF DRAWING CONTROL PROCEDURES
PERFORMANCE
OF
ROOT CAUSE EVALUATIONS
'ERFORMANCE OF WALK-DOWNS OF REQUIRED
WORK OF REQUIRED BARRIER PENETRATXONS
REWRITXNG OF SURVEILLANCE PROCEDURE
UPGRADXNG OF PENETRATION DESIGN DATA BASE
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
PRIOR
TO
STARTUP
PRIOR
TO
USE
PRIOR
TO
STARTUP
REVIEW,
REVXSE AND ISSUE
EXXSTING FXRE
PROTECTXON
PROGRAM PLANS AND PROCEDURES
PERFORMANCE
OF TRAXNING
ONGOING
ONGOING
FIRE BARRIER PENETRATIO
OVERALL ROOT CAUSE
O
LACK OF MANAGEMENT ATTENTXON AND DIRECTION XN
IMPLEMENTING COMMITMENTS RELATXNG TO FIRE BARRIER
LACK OF ADEQUATE PROCEDURES
AND DOCUMENTATXON
RELATING TO
CONTROL OF FIRE BARRXERS
LACK OF INDIVIDUALS APPRECIATION AND UNDERSTANDING
OF
FXRE BARRIER COMMITMENTS
CONTRIBUTING FACTORS
TO OVERALL ROOT CAUSES
Major Effort
Plant modifications
Field walk-downs
Analysis
Severe
Time Constraints
Imposed over day-to-day operations
In periods of heavy workload
Evolving Criteria
Interpretation
NRC direction
ACTIONS TO ADRESS
ROOT CAUSES IN THE FUTURE
UNDERSTANDXNG COMMITMENT
INITIALASSESSMENT
OF SEVERITY OF XSSUE
ANYTHXNG QUESTIONABLE - EVALUATED FURTHER BY
NUCLEAR DIVISION MANAGEMENT
TASK MANAGER ASSXGNED TO DEFINE SCOPE,
RESPONSXBILITXESt
RESOURCES
AND
SCHEDULE PRIOR
TO COMMITMENT
0
CLEAR ROLES
AND ACCOUNTABXLXTY
NUCLEAR DIVXSION REORGANXZATXON
NUCLEAR COMMITMENT TRACKXNG
DESIGN DATA BASE
DESXGN DATA BASE RECONSTITUTXON
DEVELOP SYSTEM DESXGN BASIS DOCUMENTS
INCLUDES RECOVERY OF EXISTING DESIGN DOCUMENTS
IMPROVEMENTS TO THE CONFIGURATION MANAGEMENT SYSTEM
0
PROCEDURES
LONG-TERM PROGRAM TO IMPROVE
0
ADMINXSTRATXVE PROCEDURE
0
NUCLEAR ENGINEERXNG 8t LICENSING
0
RADIATXON PROTECTION
e
DESIGN DATA BASE RECONSTITUTION
Preliminary Plan
Design criteria documents to be developed
Interpret Licensing Basis
Design codes
Design inputs
Load definitions and combinations
Acceptance criteria
Develop System Design Basis
Documents
Describe
Design
Operation
Naintenance
Reliability features
Includes
Recovery of existing Design documents
Enhancement
of existing Configuration Management
System
0
EVALUATION OF
OTHER
PROGRAMS
METHODOLOGY
Identify Other Major Programs/Projects
1977-1986
(Selection
Process)
Does
a Program/Project
Satisfy
Two or More of
the Contributing Factors
(Screening
process)
NO
Do Not
Consider
Further
YES
I
Evaluate
Programmatic
Causes
Are there Indications
That Programmatic
Causes
May Have
Been Present
(Evaluation Process)
NO
Do Not
Consider
Further
YES
Address Program/Project
'(Verification Process)
Conclusion
CO CLUSIONS
0
WITH THE FOLLOWING EXCEPTIONS t
HAVE NOT IDENTXFXED
SIMILAR SXTUATION IN OTHER
PROGRAMS
0
GENERXC LETTER 83-28
NEEDS
FURTHER EVALUATXON
O
BTP 9.5-1
NEEDS
FURTHER EVALUATION
o
SUMMARY
EXTENSIVE FERE
PROTECTION
PROGRAM AT NINE MXLE
POXNT UNXT
NMPC IDENTXFIED BARRXER PROBLEMS - INXTXATED
THOROUGH REVIEW WITH MANAGEMENT OVERSIGHT
0
PLANT SAFETY NOT I3EOPARDI2ED
MULTIPLE PROTECTION
FEATURES
MOST PENETRATIONS FULLY OPERABLE - OTHERS
PROVXDE A MEASURE OF PROTECTION
THOROUGH
ROOT CAUSE AND CORRECTIVE ACTION
REVIEW
EVOLVING PROGRAM AFFECTING MULTIPLE
DISCIPLXNES
PENETRATIONS MET REQUXREMENTS AT TXME OF
INSTALLATION
INFORMATION NOTXCE 8-04
PENETRATIONS WILL BE CONSISTENT WITH DESIGN
REQUXREMENTS BEFORE
RESTART
'1
~-