ML17285A880
| ML17285A880 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/24/1989 |
| From: | Huey F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17285A879 | List: |
| References | |
| 50-397-89-30, GL-81-12, NUDOCS 8912120173 | |
| Download: ML17285A880 (22) | |
See also: IR 05000397/1989030
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION
V
Report Nos.
50-397/89-30
Docket Nos.
50-397
License
Nos.
Licensee:
Mashington Public Power Supply System
P.O.
Box 968
Richland, .Mashington
99352
Facility Name:
Mashington Nuclear Project
No.
2 (MNP-2)
Inspection at:
MNP-2 Site,
Benton County, Mashington
Inspection
conducted:
October 23-27,
1989
Inspectors:
C.
Ramsey,
Reactor
Inspector
'.
'ea
to
Inspector
Approved by:
uey,
>e
Engineering Section
~Summer:
a e
cygne
Ins ection on October 23-27
1989'(Re ort No, 50-397/89-30
Areas Ins ected:
Routine
unannounced
inspection of fire protection program
imp emen
a
~on and related activities.
In addition,
a followup was performed
by the inspectors
on previously identified open items.
Inspection
Procedures
Nos.
64704,
92701
and 30703
and related procedures
referenced
therein were
used.
Results:
General
Conclusions
and
S ecific Findin s:
The inspection identified that you had improperly deleted fire protection
requirements
from your Technical Specifications without first incorporating
those
requirements
into your Final Safety Analysis Report, and.that certain
fire protection procedures
were inadequate
for their intended purpose.
Si nificant Safet
Matters:
None
Summar
of Violations:
Sq12120173
8911203q7
ADOCK 0
PNU
8
Seven previously identified violations were closed.
One
new violation
regarding failure to implement appropriate
procedural
requirements
for remote
shutdown
was identified.
(paragraph
3.8).
Summar
of 0 en Items:
Ten previously identified Unresolvea
and
Open items were closed.
'One
previously identified Open Item remains
open.
One
new Unresolved
Item was
identified.
DETAILS
1.
Persons
Contacted
Mashin ton Public Power
Sup
1
S stem
~J.
Baker, Assistant Plant Manager
"J
~ Arbuckle, Compliance
Engineer
- H. Fowler, Fire Marshal
- H. Aeschelman,
Nuclear Licensing
"M. Hoylman, Supervisor Industrial Safety
- J. Bell, Manager,
Health
8 Sciences
~N.
Richmond,
Supervisor Occupational
Health
"D. Kerlee, Principal equality Assurance
Engineer
- D. Moon,
DERD
- R. Madden, Principal guality Assurance
Engineer
- T. Messersmith,
Principal Operations
Engineer
.*J. Civay, Generation
Engineer
- P ~ Harness,
Generation
Engineer
D; Kreig, Generation
Engineer
R. Eyre, Generation
Engineer
R.-Muyco, Generation
Engineer
L. Noble, Generation
Engineer
D. Baynad,
Generation
Engineer
Bonneville
Power Authorit
kD
NRC
Nil 1 iams,
Nuclear Engineer
- C. Bosted,
Senior Resident
Inspector
C.
Sor'ensen,
Resident
Inspector
- Denotes those attending
the exit meeting held on October 27,
1989.
2.
.
Licensee Actions on'Previous
Ins ection Findin
s (92701)
A.
(Closed) Violation 397/86-05-01
"Safe Shutdown Methodolo
".
This
v)o a
1on invo ve
e
licensee
s
a1 ure
o prove
e requ>red fire
protection features for the safe
shutdown
method using Reactor
Core
Isolation Cooling/High Pressure
Core Spray identified in the
and the original
SER; or the method using Automatic Depressurization
System/Low Pressure
Coolant Injection chosen
by the licensee
and
described
in a March 23,
1983 submittal to the
NRC.
The inspector verified that the licensee
has provided the required
fire protection features for the ADS/LPCI safe
shutdown methodology,
as described
in the current approved fire protection program
(FSAR
Ammendment
No. 39).
Enforcement action on this item will be the
subject of separate
correspondence.
(Closed) Violation 397/86-05-02
"Safe Shutdown Train Se aration/
ro ec ion
.
is vio a ion invo ve
e
icensee
s
ai ure
o
~pqi
d
p
ti
p t ti
f9'
18'
of thermolag
on intruding steel) of cabling and equipment
necessary
to support safe
shutdown in the Reactor Building and Cable Spreading
Room.
The inspector verified that the licensee
has provided the required
separation
or protection for safe
shutdown cabling and equipment
necessary
to support safe
shutdown in the Reactor Building and Cable
Spreading
Room.
Enforcement action
on this item will be the subject
of separate
correspondence.
(Closed) Violation 397/87-02-01
"Failure. to Install
uglified Fire
arriers
or
e
ro ec ion o
a
e
u
own
rains
.
is
vio ation invo, ve
e
icensee
s app ication
o
an unqualified one
hour fire barrier (Thermolaq extrusion spray) for the protection of
redundant
safe
shutdown train cabling in conduit and cable trays
located in the Reactor Building, Radwaste
Building Cable
Chase
and
Cable Spreading
Room.
The inspector verified that the licensee's
Nonconformance
Report
(NCR) No. 286-440
and Maintenance
Work Requests
MIIIR Nos.
AT2895 and
AT1048, required the removal of the unqualified fire barrier
material
and the installation of a "tested configuration" qualified
one hour fire barrier,
and that this work had been independently
verified and signed off as complete
by the licensee.
The rework of
the fire barrier installation was performed in accordance
with
licensee
Procedure
No.
PPM-10.25.89.
The inspector performed
a
'alkdown
and verified that fire barrier installations
met the
criteria for
a "tested configuration" one hour fire barrier rating.
Enforcement action
on this item will be the subject of separate
correspondence.
(Closed) Violation 397/88-16"Ol
"Failure to Provide
Re uired Three
our
ire
arrier
ro ec ion
or
esi
ua
eat
emova
s
em
a ve
o.
-
a
in
in
e
eac or
ui
in
.
is
vio ation invo ve
e
icensee.
s
ai. ure
o provi
e required three
hour fire barrier protection to protect against
a Loss of Coolant
Accident (LOCA).
The postulated
accident would be caused
by fire
induced hot shorts which open the
RHR System high-low pressure
interface motor operated isolation valve No. V-9.
The inspector verified that the licensee's
high-low pressure
interface analysis
had been revised
so that appropriate
consideration
was given to the high-low pressure
interface concern
in accordance
with NRC Generic Letter 81-12 and Branch Technical
'osition
RSB 5-1.
The licensee's
Basic Design
Change
(BDg) No.
88-0211-0A, requiring 'the installation of three
hour fire barrier
protection
on the subject
RHR System motor operated isolation valve
cabling in the Reactor Building.had been verified and signed off as
complete
by the licensee.
Enforcement action on this item will be
the subject of separate
correspondence.
E.
{Closed) Violation 397/88-16-02
"Failure to Provide
0 erator
roce ura
ns ruc ions
or
e
oss
o
0
ower
u
lies
F.
ue
o
u
i
e
i
mpe ance
au
s
.
is vio,ta ion invo ve
he
icensee
s
ai ure to prov>
e opera ing procedures
for loss of the
525 volt OC power distribution system resulting from high. resistance
faults during a Design Basis Fire (OBF).
The inspector verified that the licensee's
High Impedance
Fault
Analysis Calculation
No. NE-02-85-19-5c,
dated August 8, 1988,
appropriately
considered
the failure of the normally energized
125
volt OC power feeders
due to a high resistance
ground, with a fault
'current increasing to 'just below the fuse rating breaker trip
setting.
The analysis
also considered
normally de-energized
125
volt OC power feeders
and interconnected
control circuits to
determine if other possible failure modes exist.
Based
on the analysis results,
the licensee's
Remote
Shutdown
Procedure
No.
PPM 4. 12. 1. 1 (Revision
No.
12)
had been revised to
instruct operators
to remove certain
loads
from the main
distribution panel
(No. DP-SI-2) within two hours following a fire
and Control
Room ev'acuation.
Additional
emer gency lighting was
provided to support operator
accomplishment
of these actions.
The
inspector verified that the High Impedance
Fault Analysis
Calculation
No. NE-02-85-19-.5c
had been verified and checked
'independently.
The licensee
indicated that these
actions would be
referenced
in the next
FSAR revision
(Ammendment
No. 41),
as part of
the approved fire protection program.
Enforcement action
on this
item will be the subject of separate
correspondence.
Closed) Violation 397/88-16-04
"Failure to Provide
Re uired Fire
arrier
ro ec ion
or
mer enc
iese
enera or an
arious
er
a e
u
own
s
em
a
in
oca
e
in
e
a
e
rea in
oom
.
is vio a ion invo ve t e
icensee
s
ai ure
o provi
e
ire
barrier protection in the Cable Spreading
Room for the Division II
Emergency Diesel Generator cabling and the associated
cabling for
safe
shutdown
systems identified by the licensee
in a March 21,
1983
submittal to the
NRC.
This submittal
changed
the licensee's
original safe
shutdown methodology.
The inspector verified that the licensee's
HMR Nos.
AT5712 and
AT5920, requiring the installation of Thermolag fire barrier
material
on the Division II Emergency Diesel Generator
and required
safe
shutdown
system cabling located in the "20 Foot Exclusion Zone"
of the Cable Spreading
Room,
had been verified independently
and
signed off as complete
by the licensee.
The work requests
required
that the Thermolag fire barrier material
be installed in accordance
with licensee
Procedure
No.
10.25.89.'he
inspector performed
a walkdown and verified that the fire
barrier material
was installed
on cable trays located in the "20
Foot Exclusion Zone" of the Cable Spreading
Room.
The licensee
had
distinctly identified the boundaries
of the "20 Foot Exclusion Zone"
by placing metallic tape
on the length and width of the protected
cable trays.
Enforcement action
on this item will be the subject of
separate
cor respondence.
G.
(CIosed)
Unresolved
Item 397/86-25-01
"Control
Room Desi
n
e iciencies
.
is i
em i en i ie
e
concern
a
ontrol
Room design deficiencies
reported to the
NRC by the licensee
in LER
No.84-031
and its six revisions
were associated
with Allegation
File No.
RV-86-A-0004.
The inspector verified that the licensee's
corrective actions for
. the Control
Room design deficiencies
reported in LER No.84-031
and
its six revisions
had
been
implemented.
This issue will be tracked
with Allegation File No.
RV-86-A-0004.
This item is closed.
H.
(0 en) Followu
Item 397/86-25-03
"Fire Mains Routed Beneath Safet
e a
e
ruc ures in
io a ion o
a iona
ire
o
e
e uiremen
s
.
is i
em i enti ie
e
concern
a
un ergroun
ire mains
installed in the vicinity of and under Catagory
1 structures
may .
compromise
the integrity of the structures
in the event of a pipe
separation
or rupture.
In response
to this concern,
the licensee
demonstrated
that several
of the underground fire mains could be properly isolated in the
event of pipe separation
or rupture,
and their installation was in
accordance
with National Fire Protection Association
(NFPA) code
requirements.
However, the actions required to satisfactorily
mitigate
a rupture of the
12 inch fire main No. FP(43)-1,
beneath
the Diesel Generator Building have not been resolved with NRR.
This
issue
has
been the subject of considerable
discussion
between
and the licensee.
The licensee
informed the inspector that an
additional submittal
(G02-89-158 dated
September
11, 1989)
had been
made to NRR.
This submittal provided
a revised justification and
code expert opinion regarding this condition.
This item will remain
open pending
NRR resolution.
I.
Closed) Violation 397/87-19-29
"Instrument Rack Terminations".
is vio a ion invo ve
e
icensee
s
ai ure
o proper y ins all
terminal
lugs in Class I instrument
racks.
The licensee's
corrective action for the violation included:
rework
of the instrument rack terminations;
revision of procedure
No.
10-25-19 (Revision 13) to include specific instructions regarding
45
to 90 degree
bends
on terminal lugs;
and implementation of formal
requirements
for "pull tests",
including documentation of test
results.
This violation is considered
closed.
J.
(Closed
Followu 'tem 397/88-16-03
"Conformance With Re ulator
Guide
is i
em i en >>e
e
concern
a
ivision
an
U>v>sion II components
and associated
cabling instalied in the
Remote
Shutdown
Panel
were not provided with the physical separation
required
by Regulatory
Guide 1.75.
The inspector verified that the licensee's
Basic Design
Change
(BDC)
No. 88-0186-0A, requiring the installation of a fire barrier to
maintain
6 inch separation
between residing
and intruding cabling of
Division I and Division II components
in Remote
Shutdown
Panel
No.
E-CP-C61/POOl
had been verified independently
and signed off as
complete
by the licensee.
During plant walkdowns,
the inspector
observed that the required fire barrier
had been installed to
maintain the specified physical
separation.
This item is considered
closed.
K.
(Closed)
LER No. 397/87-30
"U
raded Technical
S ecification
ire
a
ot
onstruc
e
to
ua i
as
a
ree
our= ire
arr>er
e
licensee
reporte
o
e
>n
o.
-
a
e
a waste
Building block wall "3W3", located
on the 487 to 507 foot level
between
column lines 15.6 and 17.0 did not have the required three
hour fire rating.
The inspector verified that. the licensee's
HMR No.
AT7669, requiring
the installation of Thermolaq to upgrade
the rating of the wall, was
verified independently
and s>gned off as complete
by the licensee.
During plant walkdowns; the inspector
observed that the Thermolag
had
been applied to the wall as specified
by the tOR.
This item is
considered
closed.
L.
(Closed)
LER No. 50-397/89-27
"Inade uate Seismic Restraints"
~
The
licensee
s
en
) )e
a
seismic
res rain
s were m)sslng
rom two
Post Accident Sampling
System valves.
The inspector
found that,
upon identification of this condition, the
appropriate
Technical Specification action statement
was entered.
Plant shutdown
was initiated when the restraints
could not be
restored
in one hour.
Records
indicated that the supports
may have
been
removed during system modification in 1983.
A sample of
similar work at that time showed that supports
were correctly,
reinstalled
on similar valves.
A sample of current work orders
showed that supports
were identified and reinstalled appropriately.
The inspector
reviewed the licensee's
program to identify and
reinstall supports.
It appeared
satisfactory.
The missing
restraints
appeared
to be
an isolated occurrence.
This item is
closed.-
H.
(Closed)
LER No. 50-537/88-26 "Instrument Sensin
Line Su
orts".
n
a
e y
va ua
1on
epor
s
en
1 le
a
ere
was
a
potential for fire damage to instrument sensing line supports.
By analysis,
the licensee
determined that modification of the
supports
was required.
The inspector
reviewed the licensee's
analysis
and found it satisfactory.
Based
on this analysis,
the
licensee
plans to install Thermolag
and replace bolts
on supports
to
satisfy fire protection requirements.
The scheduled
completion date
is December
31,
1989. Until that time,
MNP-2 (L. Aeschelman)
has
confirmed that the areas
containing these
supports will remain
on
a
fire watch in accordance
with MNP-2 fire protection plan and
procedures.
This item is closed.
I
(Closed)
LER No. 50-397/89-7 ".Failure 'to com
1
with Fire
rotec ion
s
em
e ector
urvei
ance
ec nica
eci ication
equirement
.
wo
ire protec ion survei
ance
proce ures
were not
~fh IINP-2 T
h i
1
Sp if'i
3.3.7.9,
hi
h
addressed
fire protection surveillances.
The procedures
reflected
the actual plant configuration of a thermal fire detector in the
standby service water
pump houses
rather than
an ionization fire
detector
as required
by Technical Specifications.
Also, the
procedures
and plant have
seven ionization fire detectors
in the
Power Generation
Control Cabinet rather than eight as required
by
Technical Specifications.
The licensee
states
in LER 89-7, that, with respect to these
specific detectors,
the Technical Specifications
were incor rect as
submitted for approval
in November of 1983.
The licensee
states
that, with respect
to these fire detectors,
the Technical
,
Specifications
do not reflect the plant as designed.
The current
number
and type of- these fire detectors
installed in the plant and
referenced
in the procedures
do reflect the plan as designed.
The inspector confirmed that
a walkdown of Technical Specification
fire protection
systems
was conducted.
No additional
inconsistencies
were found between applicable fire protection
systems,
surveillance
procedures,
or Technical Specifications.
The
inspector also confirmed that the subject areas
were maintained
on
a
fire tour until Technical Specifications for fire protection were
deleted in May, 1989.
The licensee
states all inconsistencies
with
procedures
were resolved after that date.
This item is closed.
(Closed)
Followu
Item No. 50-397/88-19-01 "Labelin
of Status of
tan
ower.
n ica ors
.
uring a review o
e
os
cci
en
onitoring
ys
em,
our gauges
which monitor the status of standby
power were found to have inconsistencies.
Three
ammeters
were not-
labled to denote
charge
or discharge,
and
a voltmeter was labeled to
denote
an incorrect bus.
In addition, the meters
were labeled
by
bus only and not with the instrument tag number.
The inspector
observed
the labels.
The subject instruments
were
correctly labeled
and the inspectors'oncerns
were addressed.
This
item is closed.
(Closed)
LER No. 88-22
"Missin
Thermola
in Radwaste Buildin
a
e
rea in
oom
ire
arrier.
n
inspec or i en i ied
ive ca
e
rays par ia
y ex en ing into the 20 ft. fire barrier
area which did not have required insulation.
The inspector verified that the licensee
corrected this deficiency
by installing the required insulation.
The licensee
determined that
these deficiencies
were caused
by personnel
error and ineffective
corrective action of earlier deficiencies.
This item is closed.
(Closed)
SER 0 en Item No.
5
"Se aration
and Protection of
e un an
rains in
e
a
e ween
e
rimar
on ainmeni; Vessel
an
e
io o ica
ie
a
.
is i
em i en i ie
e
,concern that the'gnition of the polyurethane
foam material
installed in the annulus
space
between
Vessel
and the Biological Shield Mall would cause
the inoperability
of redundant
safe
shutdown train cabling routed within the annulus
space.
The inspector verified that licensee
Procedure
No. 80-FPT-0702-LP,
".Fire Match Training", contai'ns specific instructions to personnel
performing fire watch duty to identify penetrations
through primary
containment that must be protected
from ignition sources.
This item
is considered
closed.
R.
(Closed)
SER 0 en Item No.
27
"Re ulator
Guide 1.39
Com liance".
is i
em i en i ie
e
concern
a
e
me
o
o
e
licensee's
compliance with Regulatory Guide 1.39 guidelines for
implementation the fire protection program was not'clearly defined.
I
The inspector
reviewed the licensee's fire protection program
implementation
Procedure
Nos.
PPM 1.3. 10 "Fire Protection
Program",
. 1.3. 19 "Housekeeping",
1.3.35,
"Administrative Procedures"
and
1.3.36 "Fire Protection Training".
The procedures
appear to
establish
a program that adheres
to the imp'lementation guidelines of
This item is considered
closed.
Im lementation of Routine Fire Protection
Pro
ram (64704)
A.
Technical
S ecification Surveillances
Limitin Conditions for
era ion an
erne ia
c ions
During a review of surveillance
procedures
and the site fire
protection program,
the inspector
found that the licensee
had not
followed the requirements
of Generic Letters 86-10 and 88-12.
The
Generic Letters state actions which the licensee
must accomplish
before the fire protection section of Technical Specifications
can
be removed
from the'operating
license.
Specifically, the Generic
Letters required
MNP2 to incorporate all fire procection Technical
Specification'Sur veillances,
Remedial Actions and Limiting
Conditions for Operations
(LCOs) into the
FSAR fire protection
program before removing the'fire protection section
from Technical
Specifications.
I
Contrary to the Generic Letters guidance,
the inspector
found the
fire protection section of Technical Specifications
had been
'eleted,
while the
FSAR fire protection program did not contain any
of the required remedial
actions or LCOs.
Also, the
FSAR contained
only general
references
to surveillances
associated
with fire .
protection,
and did not contain the specific requirements
of the
surveillances
which had been required by'he deleted section of
Technical Specifications
section.
(1)
Although the licensee
stated that individual fire protection
surveillances
were being accomplished
by specific surveillance
procedures,
there
was
no plant procedure
implementing the
overall programmatic or schedular
requirements
which had been
(2)
(3)
deleted
from Technical Specifications.
The inspector
was
informed by the
MNP2 Fire Marshall
(S.
Fowler) that all the,
sui vei llances
were still required to be performed
on schedule
because
they were
NRC commitments
and listed by the computer
tracking system.
The inspector did not consider the tracking
system sufficient to implement programmatic control.
In a letter dated
November
14,
1989,
the licensee
confirmed
that all fire protection Surveillances,
Remedial
Actions and
LCOs deleted
from Technical Specifications
had been
incorporated in the
MNP2 fire protection program.
In letters to the
NRC dated February
10, 1987,
and Harch 31,
1989, the licensee
requested
that the fire protection section
oi Technical Specifications
be deleted
based
on the guidance of
Generic Letters
86'-10 and 88-12.
In fact, the licensee
had not
fully implemented
the Generic Letter guidance
upon which
NRC
approval of the license
amendment
was based.
In particular,
the
NRC issued
a Safety Evaluation Report with License
Amendment 67, the
ammendment
which allowed
MNP2 to delete the
fire protection section
from Technical Specifications.
This
report noted that "the licensee
confirmed that the operational
conditions,
remedial actions
and test requirements
associated
with the removed fire protection technical s~ecifications
have
been included in the fire protection program'.
Although this
statement
was incorrect,
the licensee
incorporated
the
amendment
and did not notify the
NRC of the incorrect statement
upon reciept of the report.
The licensee
states
that after the license
amendment
was
approved in Nay, 1989, the fire protection remedial actions,
surveillances,
and
LCO's were
no langer
maintained
as part of
Control
Room logs.
During discussions
with the inspectors,
on
November 1, 1989, licensee
enqineers
stated that they would not
be able to quickly determine if they would currently be subject
to a remedial action or
LCO which would have
been required by
the deleted section of Technical Specifications.
The licensee
later confirmed on November 14, 1989, that all remedial
actions
that would have
been required
by the
LCOs in the deleted
Technical Specifications
section are in place.
Because
the
licensee
engineers
were unable to quickly determine fire
protection system status in the area of remedial actions
and
LCOs, more detailed
NRC inspection is warrented of the
administrative control of the fire protection program.
This is
considered
an unresolved
item (89-30-01)
and requires further
inspection.
B.
Safe
Shutdown
Procedures
The inspector
reviewed the plant procedures
to be'used
in the event
of a fire or Control
Room evacuation.
The procedures
are Revision
5
of 4. 12. 4. 1, "Fire"; Revision 12 of 4. 12. 1.1, "Control
Room
Fire/Evacuation";
and Revision
3 of 4.12. 1.2,
"RPV Remote
Cooldown".
The following deficiencies
were found in procedure
4. 12.1.1.:
(1)
Step A.10) requires
valve RHR-Y-1238 to be closed.
The correct
valve is RMR-Y-123A.
RHR-Y-123B is the similar valve in the
other train.
The purpose of this step is to isolate the
low
pressure
RHR system
from the high pressure
side for Division I
(A train).
This deficiency is mitigated in part because,
in
previous
correspondence,
the
NRC (NRR) noted that during
a fire
in the control
room, heat
induced short circuits could open
both of these
valves,
causing
an intersystem
loss of coolant
accident.
The
NRC determined that the only acceptable
assur ance 'of avoiding this possibility
was to remove
power from
the valves
RHR-Y-123A and -B.
The licensee
stated that the
valves were closed
and power has
been
removed
from these
valves
by administratively requiring the circuit breakers
to remain
open.
Nonetheless,
this i's
a significant procedural
deficiency.
The licensee
changed, the procedure to specify the
correct valve..
(2)
Step A.3) requires
the reactor vessel
level to be monitored,
.
and lists instrument.MS-LI-10R,
which does
not exist.
The
correct instrument,
which is correctly labeled
on the remote
shutdown panel,
is HS-LI-10.
The licensee
changed
the
procedure
to specify the instrument correctly.
(3)
Step A,27) requires that cooling equipment
RRA-FN-j. be
made
before the
RMR 2B pump
room exceeds
specified
temperature
limits.
The correct equipment is RRA-FN-3.
RRA-FN-1 cools
a different pump room.
The licensee
changed
the
procedure to specify the correct cooling equipment.
The licensee
stated that this deficiency is mitigated because,
when the
RHR 2B pump is energized,
RRA-FN-3 is automatically
energized.
In addition, the procedure
requires hourly
temperature
monitoring of the
pump room.
If the temperature
exceeds
150'F, operators
are instructed to make the cooling
equipment
(which was incorrectly identified as
RRA-FN-1)
The highest safe operating temperature
for the
pump
is listed as
200 F.
The licensee
state'd that the following
would have to occur for the
pump
room to exceed the safe
operating temperature:
(a)
The fan would fail to auto'matically energize
(b)
The temperature
would have'to rise above 150'F
(c)
The operator would energize
(the incorrent) fan RRA-FN-1
(d)
The temperature
would climb if the incorrect fan was
energized
(e)
On the next hourly temperature
reading,
the operator would
not notice that, althouqh
a fan'was
energized to cool the
room, the
room was getting hotter and the
2B pump room'fan
was not running.
(f)
Step (e) would be repeated
every hour until the
room
temperature
exceeded
200
F.
The licensee
considers it .unlikely that all the above steps
would occur.
(4)
Step A.27) requires that cooling equipment
WHA-TI-9 be
made
oper able before the
Remote
Shutdown
Room exceeds
specified
temperature
limits.
WMA-TI-9 is a temperature
indicator.
= The
Remote
Shutdown
room is cooled by the
same cooling equipment
that cools the cable spreading
room.
The licensee will
determine .the corrective action for this error during the next
biannual
review required by plant procedures.
Individually, these
procedure deficiencies
do not prevent the safe
shutdown of the plant i.f a Control
Room fire occurs.
However, these
deficiencies
would delay important plant corrective actions
and would
require already burdened
operators
to search for and verify the correct
equipment.
f
Deficiencies similar to the ones listed above
can
be found in the
Alternate
Remote
Shutdown section of the
same procedure,
and in the
"RPV
Remote
Cooldown" procedure
4. 12. 1.2.
The deficiencies listed above
are considered
a violation of Criterion V
of Appendix
B to 10 CFR 50 and Condition No. 2.C(14) of Facility
Operating
License
No.
This violation (397/89-30-02) will be the
subject of separate
correspondence.
C.
Fire Bri ade
Readiness
ualifications of Fire Bri ade
Members
The licensee's
Procedure
No. 1.3. 1 "Conduct of Operations",
Revision
No. 16, section 1.3. 1.5.B.5 requires that a minimum of five
individuals serve
on the Plant Fire Brigade.
At least
two of these
individuals are required to be equipment operators.
The on-duty
Shift Support Supervisor is the designated
Fire Brigade Leader.
The
remainder of the fire brigade is composed of fire brigade support
personnel (i.e. Chemistry/Health
Physics Technicians)
as specified
by licensee
Procedure
No. 1.3.36 "Fire Protection
Program Training".
Section 1.3.36.5.B of licensee
Procedure
No. 1.3.36 requires all
fire brigade
members
to have
an initial physical examination
by a
physician to determine that they are fit for strenuous
physical
activity, as experienced
in firefighting activities.
In addition,
once every year,
the procedures
require fire brigade
members to be
re-examined to determine
continued fitness for performing
strenuous'irefighting
activities.
The procedure
references
Appendix
R as
one of the bases for this requirement.
Section III.H
= of 10 CFR 50; Appendix
R requires that the qualifications of the
fire brigade -include an annual
physical
examination to determine
their ability to perform strenuous firefighting activities.
During a licensee quality assurance
surveillance
(No.86-114) in
July 1986, several
deficiencies
were identified associated
with the-
qualification and training of fire brigade personnel.
Among these
deficiencies
were: (a), failure to estab'lish
a fire brigade
on
several shifts;
and (b), annual. physical
examinations for strenuous
firefighting activities were not conducted.
The inspector's
followup activities regarding these
concerns
included
a review of an October 23,
1989 listing of qualified fire
brjgade personnel
and
random comparison of this list to the Radwaste
Control
Room Log of fire brigade
member assignments
on each shift
during the period July 13 through October 26,
1989.
The review
disclosed that all personnel
assigned
to the fire brigade during
this period were
on the list of qualified fire brigade personnel.
The inspector further reviewed the licensee's
annual. physical
examination requirements
for fire brigade personnel
and reactor
operators.
The criteria for each examination requires slightly
different special tests,
but neither examination requires
a physical
fitness stress test to determine
the ability of fire brigade
personnel
to perform strenuous firefighting activities.
According
to the licensee,
either of the annual
physical
examinations
can
be
used to satisfy the fire brigade physical
examination criteria of
the licensee's
Procedure
No. 1.-3.36.
During the exit meeting the licensee
indicated that consideration
had been given to implementing
a physical fitness stress test
as
part of annual fire brigade personnel
physical
examinations,
but
decided against it.
The licensee further stated that it was their
belief that .no such
NRC requirement exists.
However, the licensee
agreed to reconsider
the need for
a physical fitness stress
test to
determine
the ability of fire brigade personnel
to perform strenuous
firefighting activities.
D.
Results of maintenance
Surveillance Testin
Performed
The inspector performed
a limited scope review of the results of the
following maintenance
surveillance tests:
Test Procedure
la%
2.4. 9
Title
Remote
Shutdown
Panel Operability
7.4.3.7.9.45
Instrumentation (Fire Detection)
7.4.3.7.9.50
Instrumentation (Fire Detection)
ANI File N-219
E.
Results of Inde endent
ualit
Oversi ht Reviews
Annual Fire
Pump Test Results
The electric
and diesel
driven fire pump (Nos.
annual testing
was performed
by American Nuclear Insurers
(ANI) in .
June
1989.
The results of this testing indicated that the pumps
performed satisfactorily.
The Remote
Shutdown
Panel
and fire
detection
system operability testing
was performed by the licensee
in April 1989.
The test results indicated that these
systems
also
performed satisfactorily.
The inspectors
reviewed
two of the licensee's
independent quality
oversight review audits that were performed pursuant
to the
requirements
of Technical Specification 6.8.1.
Audit No.88-455
was
a three year audit which was-performed
during the period September
. 14 through September
18,
1989.
The audit results
were compared to
the previous fire protection audit and the results
showed 'that
significant improvement
had
been
made in fire protection
program
implementation in that there were noticeably fewer audit
findings.'he
previous
annual audit (No.87-418)
was conducted
during the
period September
26 through 30,
1988.
The audits
appeared
to be
thorough
and of sufficient depth.
The licensee's
quality assura'nce
representative
provided the
inspectors
with the plan for auait
No.69-501.
The audit was
scheduled
to be conducted
during November
1989.
The audit scope
was
broad
and contained
plans for auditing key fire protection'orogram
parameters,
including followup on the licensee's
response
to
previous audit findinas.
4.
Exit Neetina
30703)
An exit meeting
was held with the licensee's
staff on October 27,
1989.
The items of concern in this report were discussed
at that time.
The
licensee
acknowledged
the scope
and content of the inspection findings.