ML17304B064
| ML17304B064 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/24/1989 |
| From: | Andrea Johnson, Ramsey C, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17304B063 | List: |
| References | |
| 50-528-89-02, 50-528-89-2, 50-529-89-02, 50-529-89-2, 50-530-89-02, 50-530-89-2, NUDOCS 8903150019 | |
| Download: ML17304B064 (30) | |
See also: IR 05000528/1989002
Text
-
U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report
Nos.
50-528/89-02,
50-529/89-02,
50-530/89-02
Docket Nos.
50-528,
50-529,
50-530
License
Nos.
Licensee:
Arizona Nuclear
Power Project
P.O.
Box 52034
Phoenix,
Arizona 85072-2034
Facility Name:
Palo Verde Nuclear Generating Station Units 1, 2,
and
3
Inspection at:
Phoenix,
Inspection
conducted:
January
9-13,
1989
Inspectors:
Joh'on,
Enforcement Officer
C.
amsey,
Reactor Inspector
Approved by:
S.
Richards,
Chief
Engineering Section
D te Si
ned
pe
Date Signed
29 89
Date Signed
~Summer:
Ins ection Durin
The Period Januar
9-13
1989
Re ort Nos.
50-528/89-02,
50-529/89-02
and 50-530/89-02
Areas Ins ected:
An unannounced
reactive inspection of the licensee's fire
protection program
by two regional
inspectors
to followup on allegations
received
by the
NRC.
Results:
General
Conclusions
and
S ecific Findin
s
1.
Two of the allegations
were substantiated.
One of the substantiated
allegations
regarding offsite fire department
assistance
resulted in a
violation of NRC requirements
and the other resulted in an open item that
will require
subsequent
NRC followup on corrective actions that have
been
initiated by the licensee.
2.
Two of the allegations
were partially substantiated.
However,
based
on
corrective actions
taken
by the licensee,
no further
NRC action is
required.
'-v~9~04.t ~ll.)()g '.)
O'W
e-))Ag(}i A..<()a.')q!
3.
One allegation
was not substantiated.
Therefore,
no further
NRC action
is required.
Si nificant Safet
Matters:
The violation concerning offsite fire department
assistance,
and the unresolved
item concerning qualifications of the fire
protection staff, are considered
to be significant safety matters.
During the
inspection,
the licensee
indicated that corrective action would be taken
expeditiously regarding the assistance
of offsite fire departments.
The.
licensee
had already initiated training to improve the qualifications of the
fire protection staff prior to the inspection.
According to the licensee,
training for the fire protection staff will be
a continuing process until
their qualifications meet or exceed
the criteria specified in ANSI 3. 1.
These
corrective actions will be verified by the
NRC during subsequent
inspections.
Summar
of Violations:
One violation was identified.
Summar
of Deviations:
None
Summar
of 0 en Items:
One
new unresolved
item and
one
new open item were
identified.
DETAILS
1.
Persons
Contacted
Arizona Nuclear'ower
Pro ect
"J.
Haynes,
Vice President,
Nuclear Production
T. Shriver,
Compliance
Manger
"K. Clark,
Lead Compliance
Engineer
"W. Marsh, Director, Nuclear Production
"0. Zeringue,
Manager,
Unit 3
"R. Adney, Assistant Plant Manager
"J. Allen, Manager,
Unit 2
"C'. Thurman,
Manager,
Unit 3
"R. Pontes,
Nuclear Engineering
"T. Thompson,
Nuclear Engineering
"J.
Tench, Acting Director, Site Services
- L. Souza,
Manager,
equality Audits and Monitoring
"C. Belford, Supervisor,
Fire Protection
"F. Garrett,
Fire Protection
Engineer,
Risk Management
"H. Bieling, Manager,
Emergency Planning/Fire Protection
"A. McCabe,
Manager,
Unit 1 Maintenance
"S. Karimi, Senior Compliance
Engineer
"Denotes
those attending the exit meeting held on January
13,
1989.
2.
Followu
on Alle ation File No.
RV-88-A-0057
On November 8, 1988,
Region
V received information alleging to possible
safety related
concerns
at the Palo Verde Nuclear Generating Station.
Followup activities relative to these
concerns
were performed
by the
inspectors
to address
each of the issues
discussed
in the allegation
and
their implied impact on safe operation of the plant.
Characterization
Alle ation File RV-88-A-0057a - An allegation
was received
by the
NRC indicating that the licensee's
staff did not understand
the
technical
design criteria relevant to required functional testing
o'
carbon dioxide fire suppression
systems.
It was alleged that due to
a lack of familiarity with the system design,
and fear of
inadvertent actuation of the systems
during required functional
testing,
the licensee's
staff falsified test results for the
systems.
It was further alleged that one individual's employment
was terminated
by the licensee for falsifying carbon dioxide system
functional test records,
but that the licensee's
investigative staff
believed that another individual, who is currently employed
by the
licensee,
was also involved in the falsification of the test
records.
i
Im lied Si nificance to Plant Desi
n
Construction
or 0 eration
The licensee's
operations staff may not be adequately
trained in the
design
and operation of carbon dioxide fire suppression
systems.
Therefore,
these
systems
are not properly being verified operable in
accordance
with Technical Specification requirements.
Assessment
of Safet
Si nificance
Carbon dioxide fire suppression
systems
are required to be verified
through periodic functional testing to ensure their ability
to extinguish
a fire that threatens
redundant
safe
shutdown trains.
The operability of these
systems
is placed in question
by the
'lleged
falsified surveillance test results.
The inspectors
interviewed cognizant licensee
personnel
and examined
two reports of investigation relating to the termination of two
licensee
employees.
One of the investigations
was performed
by the
ANPP Affirmative Action Group,
dated
November 2, 1987,
and the other
investigation (involving falsification of surveillance test record
No.
on August 1, 1987)
was performed
by the site security
group,
dated August 18,
1987.
The reports
were found to be detailed
and substantive,
and provided the basis for the licensee's
termination of the employees.
With respect to the allegation that another individual was involved
in the instance
of falsification of carbon dioxide fire suppression
system surveillance test records,
an individual who participated in
the site security group investigation dated August 18,
1987, stated
that
he did not believe
any other individuals employed
by the
licensee
were involved.
He documented
in the investigation report
that the working environment significantly contributed to the
confusion
and error that resulted in the termination of the
individual who performed the test.
The investigation reports
concerning the falsification of the test record did not support the
allegation that anyone other than the employee that was terminated
was involved.
The falsification of the test record
was immediately detected
by
licensee
personnel.
The falsification involved recording
a volt
meter identification number
on the test record other than the one
that was actually used in the test.
Although the wrong voltmeter
was
used in the test
by the individual who was terminated,
the
individual recorded unsatisfactory
conditions at steps
in the test
procedure
where the voltmeter was
used
and additionally noted that
there
was
no receipt of an alarm in the control
room when expected.
(i.e.
step
No. 8.2.3.3 of the August 1,
1987 test).
The falsified
test
was declared
void prior to acceptance
of the test results.
The
test
was re-run
on August 5,
1987 and satisfactory results
were
obtained.
However, this test identified the
same deficiencies at
the procedural
steps
requiring the
use of a calibrated voltmeter and
alarm receipt in the control
room.
i
Staff Position
Partially Substantiated
- Based
on the inspectors'ollowup
activities,
the inspectors
substantiated
that one licensee
employee
was terminated for falsifying carbon dioxide fire suppression
system
functional test records,
and the licensee's fire protection staff
was not adequately
trained to perform this testing.
The inspectors
found no evidence that other individuals currently employed by the
licensee
were involved in falsification of the test records.
This
portion of the allegation was not substantiated.
Action Re uired
The licensee
has initiated a training program to upgrade
the
qualifications
and training of the fire protection staff.
This is
further discussed
in paragraph
2.D of this report.
B.
Characterization
Alle ation File RV-88-A-0057b - An allegation
was received
by the
NRC indicating that the licensee's
quality assurance
staff did not
followup on other
safety related work that was performed
by an
individual that the'icensee
terminated for falsifying test records.
Im lied Si nificance to Plant Desi
n
Construction
or 0 eration
The licensee's
guality .Assurance
Department
may not be properly
addressing
quality verification and root cause analysis
in the area
of work performed
by individuals.
Therefore,
the ability of
important to safety equipment to perform its intended safety
function may not be systematically verified by the licensee's
quality assurance
program.
Assessment
of Safet
Si nificance
The inspectors
intervewed cognizant licensee
personnel
and examined
the licensee's
guality'Assurance
Investigation Report
No.87-072.
The licensee
performed this investigation in response
to a "Hot
Line" concern that was phoned in by the employee
who was terminated
by the licensee
for 'falsifying the carbon dioxide fire suppression
system functional test discussed
in item 2.A above.
The quality assurance
investigation report was substantive
and
contained detailed information about the work performed
by the
individual who was terminated.
In an interview with the inspectors,
the quality assurance
investigator,
who was the author *of the
report, stated that the terminated individual had not performed
any
other safety related work.
He stated that the individual's work had
been limited to firefighting duties
and visual surveillance
of
firefighting equipment.
The quality assurance
investigator
also
stated,
and his report documents,
his conclusion that the terminated
individual had never performed
a carbon dioxide functional test
before.
The report further concludes that training on the test
procedure
and the
use of calibrated test equipment,
was requested
prior the individual's falsification of the test record,
but in
violation of ANSI 3.1, this training was denied
by the incumbent
fire protection supervisor.
Staff Position
Unsubstantiated
- Based
on the inspectors'nterviews
with cognizant
licensee
personnel
and examination of the licensee's
guality
Investigation
Report
No.87-072, substantial
evidence
was produced
which established
that the licensee
performed
a detailed
investigation of work that was performed
by the individual who was
terminated.
Furthermore, this evidence
showed that the licensee
performed
a comprehensive
root-cause
analysis of the circumstances
which contributed to falsification of the test record by the
terminated
employee.
On this basis,
the inspectors
could not
substantiate
the allegation.
Action Re uired
None
Characterization
Alle ation File RV-88-A-0057c - An allegation
was received
by the
NRC indicating that false information was provided to the
NRC in
Licensee
Event Report
(LER) No.84-001,
and in the Unit 1, July 6,
1988,
Transformer
Fire Post Trip Report.
Specifically, the licensee
stated
in
LER No.84-001, that the cause
of inoperable fire rated assemblies
(a violation of plant Technical
Specifications)
during the period December
1984 to June
1988,
was
cognitive personnel
error.
The alleger stated that the cause of
these conditions
was
a conscious
decision
by plant management
to
omit the subject fire rated assemblies
from Technical Specification
requirements.
Additionally, the licensee
stated in the Unit 1 transformer fire
post trip report dated July 6, 1988, that there
was
no backup power
supply to the transformer
deluge automatic sprinkler valves,
and
that the oil retention pits for the transformers
did not adequately
contain the oil and water during the fire.
Therefore,
the burning
oil flowed down the storm drain into the drainage ditch which
resulted in spreading
the fire outside of the controlled area.
The
alleger maintained that there is
a backup
power supply to the
transformer
deluge automatic sprinkler systems,
and the transformer
oi 1 retention pits have
enough capacity to hold the entire
transformer
lube oil inventory plus ten minutes of simultaneous
automatic sprinkler water flow from all sprinkler
systems.
The
alleger alleged that the reason
the burning oil flowed outside the
controlled area
and spread
the fire, 'is that the oil retention pits
were improperly maintained
and they were"filled with water at the
time of the fire.
The alleger cited these conditions
as
examples of
licensee
management's
inattention to detai
1 in the fire protection
area.
Im lied Si nificance to Plant Desi
n
Construction
or 0 eration
The allegation implies that the licensee
may not have
implemented
and properly maintained
a plant design that is required
by the
facility operating licenses.
Licensee
management
attention to
detail in. the area of fire protection
may not be adequate
to achieve
the relevant expectations
of the
NRC approved fire protection
program requirements
for Palo Verde Units 1, 2,
and 3.
Assessment
of Safet
Si nificance
Regarding
LER No.84-001,
the licensee
provided the inspectors with
a copy of licensee
Technical Specification Interpretation
No.
143
for Section 3/4.7.12 of plant Technical Specifications
dated
September
16,
1985.
The request for this interpretation
was
initiated as characterized
in the allegation.
The management
resolution to the requested
interpretation
reads,
"The phrase,
separating
safety-related fire areas
or separating
portions of
redundant
systems
important to safe
shutdown within a fire area,
applies to the sealing devices that are part of those fire-rated
assemblies
providing safety-related fire area separation,
or
separating
portions of redundant
systems
important to safe
shutdown.
It's these that are required for OPERABILITY to exist".
To acquire
a clear understanding
of the meaning of the management
intent represented
by the interpretation,
the inspectors
interviewed
a licensee
individual who was
an originator of the management
resolution.
This individual stated that the resolution intended
that sealing devices that are part of safety-related fire area
boundaries
and fire area
boundaries
protecting redundant
safe
shutdown
systems
be verified operable
pursuant to plant Technical
Specifications.
According to this individual,
no sealing
devices in
safety-related
fire-area
boundaries
or boundaries
separating
portions of redundant
systems
important to safe
shutdown were
identified as exceptions
to this resolution.
The bases
of Technical Specification
No. 3/4.7. 12 reads,
"The
OPERABILITY of the fire barriers
and barrier penetration
seals
ensure that fire damage will be limited.
These
design features
minimize the possibility of a single fire involving more than
one
fire area prior to detection
and extinguishment."
The licensee's
interpretation of the Technical Specification requirements
appeared
to be consistent with the Technical Specification
bases.
Therefore,
the inspectors
could not establish that the cause of the inoperable
seals
was attributed to a conscious
licensee
management
decision to omit the seals
from the Technical
Specification requirements,
as alleged.
Regarding the licensee's
July 6,
1988 Transformer Fire Post Trip
Report,
the licensee
explained that the concerns
raised
by the
licensee's
staff as
a result of the fire and which were
documented
in the report, did not represent
factual
statements
about the
facility design.
The licensee
acknowledged that the statement
in
the report concerning
a backup
power supply to the transformer
deluge
sprinkler systems
was incorrect.
In response
to this concern,
as
stated in the post trip report,
the licensee
issued
Engineering
Evaluation Report
(EER) No. 88-FP-155,
dated July 12,
1988.
The
dispositioned
the concern
by verifying that backup
power supplies to
the transformer
deluge automatic sprinkler systems
already existed
from two sources
(Uninteruptable
Power Supply E-gDN-N02 and diesel
generators).
Therefore,
manual initiation of the deluge sprinkler
systems for all the transformers
was not necessary
as described
in
the post trip report.
Regarding the capacity of the transformer oil retention pits, the
licensee is basically required to meet the requirements
of NFPA 15
and
NFPA 92M.
The licensee
provided the inspectors with Bechtel
Corporation Calculation
No. 13-CC-2V-110,
Job
No. 10C07-002,
sheets
171,
172 and
173 of 228, which demonstrates
that the oil retention
pits are capable. of containing the oil from the largest transformer,
together with the water from the deluge water
spray sprinkler
systems
operating simultaneously for ten minutes.
Deluge sprinkler
flow is calculated at 1,730 gallons per minute for two systems
operating simultaneously for ten minutes,
or 17,300 gallons.
The
volume of oil from the main transformer is calculated to be 12,000
gallons.
The total storage
capacity of the oil retention pits is
calculated to be 29,300 gallons with the four bays of the pits
connected
by underground piping.
There are six deluge sprinkler
systems protecting six transformers.
Therefore, if the oil from all
six of the transformers,
and sprinkler water from all of the deluge
water spray sprinkler systems
discharged
simultaneously,
the pits
would not have the capacity to contain this volume.
However the
overflow from the retention pits would be to a safe location,
such
that
no safety related
equipment would be
damaged.
This design
satisfies
the intent of NFPA 15-1977 sprinkler water
drainage
requirements
as specified in NFPA 92M and the
NRC approved fire
protection program.
The licensee
was not certain of the condition of the retention pits
at the time of the July 6,
1988 transformer fire.
However, the
licensee
stated that the pits have
been
observed to contain water,
and they may have contained water at the time of the fire.
There
was
no maintenance
program established
for the pits at the time of
the fire.
The licensee
indicated that consider ation was being given
to increasing
the capacity of the pits and establishing
a
maintenance
and surveillance
program to ensure availability of the
retention capacity.
Staff Position
Partially Substantiated
- Based
on the inspectors'followup
activities, the inspectors
did not substantiate
that the. cause of
the inoperable fire barrier penetration
seals
discussed
in
LER No.84-001
was
a conscious
decision
by licensee
management
to omit the
seals
from Technical Specification
requirements.
The inspectors
did
not substantiate
that the transformer oil retention pits had the
capacity to hold the entire inventory of oil from all of the
transformers
and water flow from the deluge water spray sprinkler
systems
simultaneously,
however the inspectors
concluded that the
design of the retention pits meet the applicable
NRC requirements.-
The inspectors
did substantiate
that the licensee
did not have
a
maintenance/surveillance
program established
for the transformer oil
retention pits.
Because all the deluge
systems
were activated
manually during the July 6 event
and the duratibn of the water flow
was not recorded,
the inspectors
could not establish that the lack
of a maintenance/surveillance
program
was the cause of the burning
oil flowing down the storm drains
and spreading
the transformer fire
outside of the controlled area.
The inspectors
substantiated
that
the lack of an established
maintenance/surveillance
program for the
transformer oil retention pits at the time of the transformer fire
was
an example of the licensee's
inattention to detail in the fire
protection area.
Action Re uired
The licensee
indicated that
a maintenance/survei-llance
program would
be established
for the transformer oil retentiOn pits.
The
potential for the oil and fire suppression
water inventory to
overflow from the pits and expose
other. safety related
equipment
has
generic implications
and will receive further
NRC followup.
This is
considered
an open item (528/89-02-01)
pending further licensee
and
NRC action.
Charaterization
Alle ation File RV-88-A-0057d - An allegation
was received
by the
NRC indicating that the licensee's
operations fire protection staff
was not qualifi'ed through training and experience
to implement the
program requirements.
The alleger cited one example that is
contained in the licensee's
LER No.88-005.
This
LER reported to
the
NRC that the root cause of an event that led to. isolation of the
Unit 1 fire protection water supply loop, which rendered
required
fire suppression
systems
was personnel
error,
and
an
inadequate
procedure.
The alleger stated that the reason
the
licensee's fire protection staff isolated the Unit 1 fire protection
water supply was that they did not have the required expertise to
read the appropriate
P&ID's for the system.
The allegation further states
that the current Operations
Fire
Protection Supervisor did not have the required
knowledge
and
expertise
to implement the fire protection program requirements,
and
that the licensee
did not have
a technical
basis for using Bisco and
ICNS penetration
seal materials to seal fire barrier penetration
openings
in Unit 1.
The alleger also stated that these materials
may not be compatible,
and
as
a mixture, the fire rating of the
materials
has not been established.
The licensee
is required to use
materials
whose qualifications
have
been established
by test for
fire barrier protection of redundant
safe
shutdown trains.
Im lied Si nificance to Plant Desi
n
Construction
or
0 eration
The licensee's
operations fire protection staff may not be qualified
to implement the program requirements.
Unqualified materials
may be
used in Unit 1 as fire barrier protection for safe
shutdown trains.
Assessment
of Safet
Si nificance
Regarding
LER No.88-005, the licensee
acknowledged that the fire
protection staff had difficulty reading the PAID's for the fire
protection water supply system.
However,
the licensee
stated that-
the staff's difficulty in determining the correct method of
isolation of the system did not contribute to the system being
inoperable for more than
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
According to the licensee,
the
system
was isolated in a manner to declare it inoperable
because
of
leaking Post Indicator Valves (isolation valves).
As corrective
action for LER No.88-005,
the licensee
developed
an enlarged
composite,
one line diagram of the fire water isolation system,
implemented
new procedure
No.
and conducted training
sessions
to provide direction to the fire protection staff on the
proper methods of .isolating the system.
Regarding the qualifications of the licensee's fire protection
staff, the Licensee's guality Assurance
Investigation
Report
No.87-072 identified that the staff was not properly trained
on
seventy-three
percent of 82 procedures
that they were required to
perform.
The qualifications of the staff are governed
by the
FSAR and
ANSI
3.1-1978Property "ANSI code" (as page type) with input value "ANSI</br></br>3.1-1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
A suitable training program is required to be established
for managers,
supervisors,
professional
operators,
technicians
and
maintenance
personnel
to properly prepare
them for their
assignments.
Technicians
and maintenance
personnel
are required to
be trained on-the-job
by participation in initial calibration,
testing
and equipment
acceptance
programs.
Technicians
are required
to have three years of working experience
in their speciality of
which one year is required to be related to technical training.
In response
to Corrective Action Report
(CAR) No.
Cg87-0099 for the
training deficiencies,
the licensee initiated a training program for
the fire protection staff.
According to the licensee,
the training
program
had not completely- addressed
all of the deficiencies
identified in the guality Assurance
Investigation Report.
When this
training is completed,
the licensee
indicated that
a retraining
program would be established
and documented
to ensure that the
qualifications of the staff would be maintained.
Interviews with
fire protection staff individuals by the inspectors
disclosed that
the training has
been ongoing since January
1988,
and
has
significantly improved the staff's confidence in their ability to
perform assigned fire protection duties.
To further verify the qualifications of the licensee's
fire
protection staff, the inspectors
reviewed the licensee's
job
position descriptions
and personnel
resumes
for the positions of
Fire Protection Supervisor,
Fire Captain
and Fire System Technician.
The licensee's
job position description for the position of Fire
Protection Supervisor
requires that this individual possess
an
intimate knowledge of fire protection
systems
and firefighting
techniques;
thorough
knowledge of nuclear
power plant systems;
NRC
fire protection regulations;
National Fire Protection Association
(NFPA) codes
and standards;
and,
have
a sound understanding
of
engineering
and design principles associated
with fire protection
systems.
The Fire Protection Supervisor's
qualifications described
in the
resume of the individual filling this position does not appear
to
meet the criteria for the licensee's
job position description
and
ANSI 3. 1.
The individual's resume
indicates considerable
experience
in firefighting and emergency
medical
techniques,
but the resume
does
not indicate that this individual possesses
an intimate
knowledge of fire protection systems;
thorough
knowledge of nuclear
power plant systems;
NRC fire protection regulations;
NFPA codes
and
standards;
and
a sound understanding
of engineering
and design
principles associated
with fire protection
systems.
The licensee's
job position description for the position of Fire
Captain requires that these individuals have
a detailed
knowledge of
fire protection
systems,
and
have
a good understanding
of
firefighting and emergency
medical
techniques.
The position
description also requires that these individuals
be skilled in the
operation of firefighting and emergency
medical
equipment.
The Fire Captain's qualifications described
in the resumes
of the
individuals filling these positions indicate that the individuals
have considerable
training and experience
in firefighting, emergency
medical
techniques,
and the operation of firefighting equipment.
Their qualifications
appear to meet
or
exceed
the licensee's
job
position description for Fire Captains,
but these qualifications
do
not appear
to meet the criteria for maintenance
technicians
as
specified
by ANSI 3: l.
The licensee's
job position description for the position of Fire
Technician requires that these individuals have
a good understanding
of fire protection
systems,
and
be knowl edgeabl e concerning plant
safety related
systems
and the effects of fire on these
systems.
The position description requires that these individuals
be
knowledgeable
of plant fire protection maintenance
procedures
and
the system's
operations
procedures,
in additon to posessing
basic
firefighting and emergency
medical technician skills.
These
individuals are required to perform maintenance,
engineering,
and
testing
and update
required engineering
drawings to reflect the
actual condition of fire protection
systems.
,1
10
The Fire Technician's qualifications described
in the
resumes
of the
individuals filling these positions indicate the the individuals
have considerable firefighting and emergency
medical technician
training and experience.
None of the
resumes
reviewed by the
inspectors
indicated that these individuals were qualified by
training or. experience
to perform maintenance,
engineering,
or
testing of fire protection
systems
as specified
by the criteria of
Regarding the incompatibility of penetration
seal materials
used in
Unit 1, the licensee
provided the inspectors with a licensee
vendor
evaluation (Impell Corporation
No. 1658-045-005,
dated August 4,
1987) of Bisco and
ICMS penetration
seal materials.
The evaluation
co'ncludes that both materials
are formulated from Dow Corning
Sylgard 170,
and can
be mixed together to provide equivalent fire
resistance.
Staff Position
Substantiated
Based
on the inspectors'ollowup activities,
the
inspectors
substantiated
that the licensee's
fire protectioh staff
is not qualified by training and experience
to implement all the
program requirements,
particularly regarding maintenance activities.
The licensee's
guality Assurance
Investigation Report
No.87-072
documented training deficiencies that were in violation of the
.and
ANSI 3. 1.
The inspectors
determined that the staff's
qualifications apparently
do not meet the criteria of the licensee's
job position description for the position of Fire Protection
'upervisor
and the maintenance
engineering
work experience
and
training criteria of ANSI 3. 1 for Technicians
and maintenance
personnel.
The licensee initiated corrective action for this concern
in response
to Corrective Action Report
(CAR) No.
Cg87-0099 prior to
the inspector's
followup
activities'he
inspectors
further substantiated
that the licensee
used Bisco
and
ICMS penetration
seal materials to seal penetration
openings
in
fire barriers in Unit 1 without having
a technical
basis for the
compatibility of the materials
and their fire endurance
as
a
mixture.
However, the licensee's
vendor evaluation (Impell
Corporation
No. 1658-045-005)
subsequently
determined that the
materials
are compatible
and as
a mixture, they provide appropriate
fire endurance.
Action Re uired
This is considered
an unresolved
item (528/89"02-02)
pending
completion of the licensee's
corrective actions for the training and
qualifications deficiencies
and verification by Region V.
11
Characterization
Allegation File RV-88-A-0057e - An allegation
was received
by the
NRC indicating that the licensee's
training, coordination
and
offsite fire department
assistance
from the Phoenix Fire Department
is not adequate.
The alleger stated that such training and
coordination is rarely, if ever performed.
Im lied Si nificance to Plant Desi
n
Construction
or
0 eration
Training, coordination
and drills by the licensee with offsite fire
department
assistance
is essential
to the site's
emergency
readiness
capability to combat major fire occurrences.
The allegation implies
that this aspect of the licensee's fire protection program
may not
meet the program requirements
as specified in Sections
B.5(b) and
8.5(c) of Table 9B.3-1 of the
FSAR.
Assessment
of Safet
Si nificance
Offsite fire department
assistance
is required to be provided by the
NRC approved fire protection program
as
implemented
by license
condition, to supplement
the fire brigade in the suppression
of a
fire so that safe
shutdown
can
be achieved
and maintained in the
event of a major fire occurrence.
Staff Position
Substantiated
The inspectors'ollowup activities
and interview with the Phoenix
Fire Department
on January
9,
1989 disclosed
the. following:
Agi cement with the licensee
to provide offsite fire department
assistance
was
made
between the licensee
and the City of
Phoenix Fire Department
on July 19,
1984, prior to the Unit 1
initial startup.
The Phoenix Fire Deparment's
understanding
of
this agreement
is that they are to provide firefighting and
hazardous
material
assistance
for major fire events
involving
non-nuclear
materials,
but they are not required to provide
firefighting assistance
in safety related
areas
in support of
safe
shutdown.
The licensee
has
no other offsite fire
department
assistance
agreement.
(2)
At the time the agreement
was
made
on July 19, 1984,
the
Phoen'ix Fire 'Department's
Hazardous
Material
Team
(3-.5 man
shifts) were given
a familiarization tour of Unit l. It took 2
or 3 days for the three shifts of Hazardous
Material
Team
members to complete the familiarization tour.
Other
than the
familiarization tour, the Phoenix Fire Department
has not
received additional training at the Palo Verde site.
(3)
The Phoenix Fire Department
does not participate in annual
drills at the site and has
neve'r received
any type of
radiological training from the site.
12,
(4)
The licensee
did notify the Phoenix Fire Department to be on
the alert during the July 6, 1988 transformer fire, however,
this was
an unusual
request.
The licensee
does not normally
notify the department of fire occurrences.
(5)
The licensee's
only method of requesting
assistance
from the
Phoenix Fire Department is via commercial
telephone.
(6)
The Phoenix Fire Department's
response
time to the site by
ground transportation
or by helicopter is l-hour.
(7)
The Phoenix Fire Department
does not have
a helicopter
designated
for emergency
response
to the site.
The
department's,helicopter
is shared with another state
department
and
may not be available for this purpose.
According to the
department's
spokesman,
by agreement,
the licensee is required
to provide helicopter transportation for the department if
assistance
is needed.
The licensee
indicated that their
corporate helicopter
may not be available for this purpose
during day shift hours
due to other corporate
needs.
The
helicopter pilot is only available during normal
day shift
hours.
Therefore,
the helicopter is not available during
backshift hours.
(8)
Other than
by agreement with the licensee,
the Phoenix Fire
Department
has
no jurisdiction at the site because
the site is
located in an unincorporated
area.
Therefore,
the department
is not required to respond to fire occurrences
at the site.
(9) If required through agreement,
the Phoenix Fire Department
could dispatch
the following equipment
and manpower to the
site:
60 firefighters
10 fire engines
3 ladder trucks
1500 to 2000 gallons of chemical
foam
1-2000 gallon tanker
2-1000 gallon tanker s
(10) The Phoenix Fire Department
has
no record of training or drills
with the site because
these activities
have not been performed.
(11) The Phoenix Fire Department
has
no preplanned
emergency
strategies
for the site because
such planning with the licensee
has not been performed.
13
'0
Action Re uired
This is considered
a violation of License Condition Nos. 2.c(7),
2.c(6)
and 2.f of Facility Operating
License
Nos.
NPF-51 and
NPF-74, respectively,
which indicates that Palo Verde has entered
into an agreement with the local offsite fire department for mutual
support,
and will provide appropriate training (528/89-02-03).
The licensee
has since indicated that action
has
been initiated to
correct the above deficiencies.
3.
~Oen Items
Open items are matters that have
been discussed
with the licensee,
that
will be reviewed further by the inspector,
and that involve some action
on the part of the
NRC, the licensee,
or both.
Open items disclosed
during the inspection
are discussed
in paragraph
2.D of the report.
4.
Exit Meetin
30703
An exit meeting
was held with the licensee's
staff on January
13,
1989.
The items of concern in this report were discussed
at that time.
The
licensee
acknowledged
the scope
and content of the inspection findings.
'