ML18025B699
| ML18025B699 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/24/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8112310333 | |
| Download: ML18025B699 (34) | |
Text
TENNESSEE VALLEYAUTHORITY CHATTANOOGA TENNESSEE 374/1
~ P>Q
~ RE G(Q'g tIOO Chestnut Street Tower II
. 6!.Grc;,>>
gaye~bep 24
$ 98) 1 Mov 25 P12 2
Mr. James P. 0'eilly, Direc tor Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region II - Suite 3100 101 Marietta Street Atlanta, Georgia 30303
Dear Mr. O'Reilly:
This is in response to R. C. Lewis'arch 23, 1981 letter to H. G. Parris, Report Nos. 50-259/81-01,
-260/81-01,
-296/81-01, concerning activities at Browns Ferry Nuclear Plant which appear ed to violate NRC requirements.
Enclosed is our interim response to Un'resolved Item (259/81-01-09, 260/81-01-09, 296/81-01-09) regarding corrective actions taken in response to the 1980 Triennial Fire Protection Audit conducted by Professional Loss Control, Inc.
Me are addressing only the safety-related recommendations of this audit.
Periodic updates will be issued when appropriate.
If you have any questions, please call Jim Domer at FTS 858-2725.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Enclosure Very truly yours, I
TENNESSEE VALLEY AUTHORITY
. M. Milis,'ager Nuclear Regulation an fety
~"~w~
"~jt~)i~~
Sii23i0333 Biii24 PDR ADOCK 050002S9 I
8 PDR An Equal Opportunity Employer
hh'l
, ~
h h
Ihf hh hh 1
~
I ~
fh hhh A 'p" h'
P kg ~
~ I hh I
E g
C r '.
"I
\\
P$
E
STATUS REPORT FOR 1980 TRIENNIAL FIRE PROTECTION AUDIT Conducted By Professional Loss Control, Inc.
Dated October 2, 1980 Prepared By Nuclear Central Office Fire Protection Engineering Section November 3, 1981
~
~
~
o
~
~
V
- 4. 0 Recommenda tions--Sa fet Rel a ted Areas 4.1 Administrative Control of Fire Hazards e
4.1.1 A review should be conducted to re-identify areas where smoking should not be permitted.
Existing procedures, such as F 15 and BF 14.3, should then be rigidly enforced to control smoking in unauthorized areas.
TVA Res onse 4.1.2 The Division Procedures Manual (DPM) will be reviewed to re-identify areas where smoking should not be permitted during the next revision to the applicable procedure.
In addition, plant administrative action to be taken when personnel are smoking in unauthorized areas will be escalated and rigidly enforced.
Remove the rubber hose and untreated wood from the area near the escape hatch in the service water intake building.
In addition, the treated wood partitions in the center and east areas of the building should be replaced with partitions of noncombustible construction.
TVA Res onse 4.1. 3 The rubber hose and wood partitions have been removed.
An administrative procedure should be established to monitor installation of new electrical cables to ensure that, where required, cables are provided with fire retardant coating (see Appendix H for specific examples).
TVA Res onse Administrative Procedure Mechanical Maintenance Instruction (MMI) 75 was revised on February 1,
1981 to ensure that proper coating procedures are initiated promptly for all applicable uncoated cables.
4.1.4 Housekeeping should be improved by more rigidly enforcing existing procedures, such as BF 14.3 and BF 14.14.
Areas of specific concern include the following:
a.
Several combustible rags found in cable trays within unit 3 cable spread room.
b.
Three (3) coveralls found in cable trays EG, VE, and KG above platform in uni t 1 drywell area.
TVA Res onse 4.1.5 Existing plant procedur es provide adequate controls for housekeeping, and a strict enforcement policy will be followed by plant personnel.
A detailed study should be conducted to verify commitments r egarding fire barrier walls.
After completion of the study, all affected walls should be inspected to verify integrity of fire doors and dampers.
Unapproved doors should be replaced with doors specifically approved for use as fire barriers.
(See Appendix E for a list of existing fire door deficiencies.)
TVA Res onse 4.1.6 A study of the fire compartmentalization at Browns Ferry is being conducted by the Division of Engineering Design (EN DES) in order to complete the analysis required to comply with 10 CFR 50, Appendix R, Section III.G.
The analysis is scheduled to be completed by June 30, 1982.
When the fire compartmentalization study is available, it will be forwarded to the plant for verification of the integrity of fire doors and dampers in the affected walls.
In addition, door numbers 602, 606,
- 608, 612, 614,
- 615, 616,
- 617, 621, 622, and 473 have been replaced by UL labeled fire doors.
The fire protection review of plant modifications (DPM Procedure F 13) should be expanded to include a
review of all modifications which could directly or indirectly affect fire protection.
(See Appendix G
for guidance in this review.)
TVA Res onse The existing plant procedures and DPH N78S2,Section VII, F13, meet the intent of this recommendation and no further action is planned.
I, V
~
0
4.1. 7 TVA Res The damaged safety can in the central portion of the service water building and the gasoline can with the missing flame arrestor in the Power Stores flammable liquid storage room should be replaced or repaired.
onse 4.1
~ 8 This i tem has been completed.
The plastic ceiling in the 'control rooms should be demonstrated to be noncombustible or should be replaced in accordance with BTP APCSB 9. 5-1 (Dlf}.
TVA Res onse 4.1.9 Replacement of the ceiling tiles in the control rooms has begun and will be completed during the next planned outage of each affected unit or during a
forced outage of the unit lasting one week or longer, whichever occurs first.
The replacement material has been approved by NRC-NRR.
Two existing 3-inch openings in the wall from 480v electrical swi tchgear room (door 654, Elev. 621')
to rooms 3A and 3B should be closed.
In addition, install approved dampers in the ducts penetrating this wall.
TVA Res onse The 3-inch openings have been sealed.
Approved dampers were installed in the ducts penetrating the wall during the original design as shown on drawing numbers 47W920-8,9; 47A380-72, and 47A900-53.
4.2 Fire Protection E ui ment Surveillance Procedures 4.2.1 TVA Res MMI-66 should be revised to include a more appropriate reporti ng form.
In addition, the procedure should discuss the flush test in more detail and should include verification of pressure reducer settings where provided.
onse MMI 66 has been revised but the revision may not meet all the requirements of this i tem.
Plant personnel will review MMI 66 to ensure all requirements are met and implement additional revisions if necessary.
~
~
~
0
4.2.2 A surveillance instruction (SI) should be developed to require annual cycling of all valves in the water supply and distribution system.
(This is required by current model technical specifications issued by the NRC.)
TVA Res onse NFPA 13A requires regular cycling of valves, but not specifically on an annual basis.
Since there is no specific requirement for annual cycling of.
- valves, a separate YNI will not be written.
However, plant personnel will investi gate the possibility of incorporating a valve cycling program into the existing surveillance instruction conducted on the valves.
~ 4.2.3 A surveillance instruction should be developed to provide verification of operability and integrity of all required fire doors and dampers at least every 18 months.
(This is required by current model technical specifications issued by the NRC.)
TVA Res onse 4.2.4 A Hf1I has been developed for fire doors.
A technical specification change request has been submitted to the NRC.
Once the technical specification has been
- changed, a
NMI will be developed for fire dampers.
Personnel involved in implementation of surveillance procedures for fire protection systems and equipment should be given formal training, such as that available at off-site courses, to acquaint them with all necessary particulars of the equipment.
The
. existing fragmentation of procedure implementation and use of untrained personnel is undesirable.
TVA Res onse Craft personnel (electrical, mechanical, etc.) are involved in the implementation of surveillance procedures for fire protection systems and equi pment.
They perform the surveillance procedures respective to their craft and are properly trained in their craft.
There have not been any major problems associated with the procedures being implemented in this manner.
Therefore, we believe that no additional training of craft or operations personnel is r equired.
4.2.5 Procedures should be rigidly adhered to by implementation personnel.
Any deficiencies found should be recorded on the data sheets.
Deficiencies should be resolved only by issuing corrective work orders (with numbers recorded on data sheets).
The implementation personnel should not be allowed to judge which portions of the procedure should be enforced (e.g.,
NNI-64 hydrant outlets above grade).
In cases where a specific procedure is in error, a
revision should be issued.
TYA Res onse NNI-64 has been revised and procedures are in effect which require deficiencies to be corrected by the initiation of a work order.
4.2.6 Revise procedure SI 4.11.A.l.b to require a minimum run time of fifteen (15) minutes for each electric motor driven fire pump.
TVA Res onse 4,2.7 TVA Res Procedure SI 4.11.A.l.b has been revised to require a minimum run time of 15 minutes for each electric motor-driven fire pump.
Revise procedure SI 4.11.A.l.b(a) to require a
minimum run time of thirty (30) minutes for the engine driven fire pump.
Procedure SI 4.11.A.l.b(a) has been revised to require a minimum run time of thirty (30) minutes for each diesel engine-driven fire pump.
4.2.8 Revise procedure SI 4.11.A.l.h to include a
"C factor" test of the underground piping.
This would provide information regarding the deterioration of the interior of the fire water supply piping.
TVA Res onse SI F 11.A.l.h will be revised prior to the next scheduled flow test required by the SI.
4.3 Fire Protection S stems and E ui ment 4.3.1 The existing fire water supply arrangement should be revised to discontinue providing service water supply from the fire water system.
The fire pumps and underground piping should be dedicated solely for fire protection use.
The raw service water pumps and associated roof tanks should be isolated from the fire protection system.
~
~
TVA Res onse This i.tern has been forwarded to EN DES for analysis.
The Divisi'on of Nuclear Power (NUC PR} will take appropriate action based upon the results obtained from the analysis.
4.3.2 TVA Res Each fire pump should be provided with a "fire pump controller" specifically approved for fire service use.
Each pump should be arranged to start automatically upon loss of system pressure.
This item has been forwarded to EN DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
4.3.3 The diesel fire pump enclosure should be provided with an automatic sprinkler system.
TVA Res onse 4.3.4 This i tem has been forwarded to EN DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
All key operated isolation valves in the distribution piping system should be replaced with post indicating valves (PIV) specifically approved for fire service use.
As an alternative, the existing key valves should be modified to provide positive indication of valve position.
Each exposed valve should be protected from vehicular damage by installing appropriately located guard posts around each valve.
TVA Res onse 4.3.5 This item has been forwarded to EN DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
Guard posts have been installed to protect exposed valves.
Additional measures should be instituted to provide improved control of the clam problem associated with the fire water supply and distribution system.
These measures might include increased system flushing frequency and conti nued use of a biocide (procedure SI 4.11.A.l.f).
One alternative which should be considered is to provide a separate fresh water
l
~
~
supply reservoir designated for fire protection use only.
The reservoir could be filled from the connection to the City of Athens.
If the electric and diesel fire pumps draw their supply from fresh
- water, then the problem of the clams would be eliminated.
TVA Res onse This item has been forwarded to EN DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
4.3.6 Additional sway bracing should be provided for the sprinkler piping located above the unit 1 drywell entrance and along the north wall of the 593'levation.
TVA Res onse This item has been forwarded to EN DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
C +-
4.3.7 Install smoke detection to provide for early warning of fire in electric board rooms 1, 2, and 3 (480v swi tchgear) in the control building.
TVA Res onse 4.3.8 This item has been forwarded to EN DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
Install fire detectors and/or automatic sprinklers for the laundry areas of unit 3 reactor building (Elev. 621').
TVA Res onse 4.3.9 TVA Res The laundry areas of unit 3 reactor building (elevation 621) have been removed.
Relocate thermal detectors over the unit 1
HPCI pumps to the center of the hazard.
onse This item has been forwarded to EN DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
~
~
4.3.10 Extend smoke detectors to cover. the area near R-17N of the unit 3 reactor building (Elev. 565')
where pre-action sprinklers are already installed.
TVA Res onse 4.3.11 This item has been forwarded to EN DES for analysis.
NUC PR Aill take appropriate action based upon the results obtained from the analysis.
Existing smoke detectors in auxiliary instrument rooms 1, 2, and 3 (control building, Elev. 595')
should be relocated to the ceiling as indicated below:
Room 1 - detectors 3915D and 3915E Room 2 - detector 3917D Room 3 - detector 3919D and 3919E Ij In addition, more detectors should be installed in Rooms 2 and 3 to ensure coverage of all beam pockets in accordance with NFPA 72E.
TVA Res onse 4.3.12 This i tem has been forwarded to EN DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
Replace damaged smoke detector 105DB in the communications battery room (Elev. 593').
TVA Res onse 4.3.13 This item is complete.
Install additional smoke detectors in unit 3 reactor building (Elev. 593') near column R16T-T to provide coverage of all beam pockets.
TVA Res onse 4.3.14 This item has been forwarded to EN DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
Because of the brigade access problems and fire hazard potentials associated with the reactor building corner rooms (Elev. 519'), fire detection and/or suppression should be provided for each area.
0
TVA Res onse 4.3.15 This item has been forwarded to EH DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
A determination should be made by management as to whether or not standpipe nozzle pressures should be limited to 125 psi as required by OSHA. If this is the desire, each standpipe should be evaluated and d
i
~1h needed.
The pressure reducer should be calibrated, sealed and verified as being in the proper setting as a part of the HNI-66.
Standpipes which now have two pressure reducers should have at least one removed.
TVA Res onse a r Standpipe nozzle pressures will be reduced to 75 psi.
Plant personnel are conducting a survey to identify any standpipes which require additional pressure reducers or have redundant pressure reducers.
tNI 66 will be revised appropriately based upon the survey results.
4.3.16 Access to standpipes Rl-19 in uni t 1 reactor building (Elev. 565') adjacent to stair, R3-51 unit 3 reactor building (Elev. 621')
near the laundry, and R3-19 in unit 2 drywell access (Elev. 565') are obstructed and should be corrected.
TVA Res onse The present access to standpipe Rl-19 in unit 1
reactor building (Elev. 565')
has been evaluated and the existing access provided is adequate to allow access during normal and emergency conditions.
The access to the standpipe at R3-51 unit 3 reactor building (Elev. 621') near the laundry, and R3-19 in unit 2 drywell access (Elev. 565')
have been cleared.
4.3.17 All sprinkler, water spray and pre-action'system control valves should be locked or sealed in the normally open position to ensure correct orientation at the time of a fire.
Similar controls should be provided for isolation valves on the yard loop.
~
~
~
~
\\
TVA Res onse Operation of all sprinkler, water spray, and preaction system control valves along with isolation valves on
'he yard loop are strictly controlled by existing administrative procedures.
These existing procedures ensure the correct orientation of the valves at-the time of a fire.
The pFovision of locks or seals would not provide a si gnificant increase in the control of the valves.
4.3.18 Identification signs should be provided for all water suppression system control valves and manual actuation stations presently lacking such signs.
Specific attention should be directed to the manual actuation station for unit 3 south lube oil tank and the four sprinkler systems in unit 3 reactor building (Elev. 565') near column R-17 U.
TVA Res onse 4.3.19 Plant personnel have evaluated each area and have installed identification signs where needed.
Waterflow alarm devices should be provided for all water suppression systems which supply more than 20 sprinkler heads in accordance with provisions of
'VA Res onse 4.3.20 This item has been forwarded to EN DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
All pre-action sprinkler systems supplying more than 20 heads should be provided with air supervision in accordance with paragraph 5-3.5.2 of NFPA 13.
TVA Res onse This item has been forwarded to EN,DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
P
4.3.21 A curb should be provided around HPCI to confine the oil hazard to the area protected by water spray or.
the spray system should be expanded to protect the probable oil spill area.
TVA Res 4.3.22 This item has been forwarded to EN DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
All adjustable spray nozzles should be replaced with fixed water spray nozzles which are listed or approved for use in fire protection systems.
TVA Res onse
-This item has been forwarded to EN DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
4.3.23 Existing sprinkler heads presently installed an excessive distance below the ceiling (see Appendix C) should be relocated in accordance with the requirements of NFPA 13 or tests should be conducted to verify the validity of the existing design.
TVA Res onse 4.3.24 TVA Res This item has been forwarded to EN DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
Pendent sprinkler heads installed in the upright positi on should be replaced with appropriate directional water spray nozzles or upright heads or tests should be conducted to verify the water distribution achieved by the present system.
(See Appendix C, page 2.)
onse This item has been forwarded to EN DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
4.3.25 The sprinkler design philosophy for areas containing cables should be re-evaluated to determine the validity of present installations in light of the tests conducted by Sandia 'Labs.
TVA Res onse This item has been forwarded to EN DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
4.3.26 TVA Res To reduce the probability of heads becoming clogged by debris during use, small orifice sprinkler heads and spray nozzles should not be used on new systems or when modifying existing pre-action systems.
onse This item has been forwarded to EN DES for analysis.
NUC PR will take appropriate action based upon the results obtained from the analysis.
ade 4.4.1 One individual should be assigned the responsibility of coordinating all fire brigade activities to ensure uniform training of all shifts.
He should determine that appropriate fire brigade equipment is provided and maintained.
This person should critique all fire drills and provide documentation of the drills.
Finally, he should see that sufficient pre-fire plans are developed and kept current with changing plant conditions.
TYA Res onse The existing plant procedures ensure that all the duties specified in the recommendation are charged to specific inviduals.
The procedures presently established provide supervision equivalent to that which is recommended.
4
~
4.4.2 The existing off-site brigade training course should be suppl emented at the plant.
Plant fire hazards, fire equipment locations, pre-fire plan familiarity, proper use of available equipment, operation of the fire truck, etc., should be included in this training.
(See Attachment No.
2 of the NRC Supplementary Guidance on Nuclear Plant Fire Protection Functional Responsibilities, Admiriistrative Controls and guality Assurance for additional details.)
TVA Res onse 4.4.3 Plant fire hazards, fire equipment locations, pre-fire plan'amiliarity, proper use of available equipment, operation of the fire truck, etc.,
are currently included in the fire brigade member training sessions held at the plant.
Classroom instruction for the fire brigade members should be conducted quarterly and scheduled such that all subjects are repeated over a two-year period.
The length of time allowed for the refresher traini ng should be expanded to allow for more complete coverage of the necessary subject matter.
TVA Res onse 444 Classroom instruction for the fire brigade members is currently being conducted quarterly and scheduled such that all subjects are repeated over a 2-year period.
The length of time allowed for the refresher training 'has been expanded to allow for more complete coverage of the necessary subject matter.
Additional quarterly training should be provided for bri gade leaders in the direction and coordination of firefighting activities.
TVA Res 4.4. 5 onse quarterly drills are being conducted to provide brigade leaders training in the direction and coordinati on of firefighting acti vities.
Improved physical firefighting facilities should be provided at the plant so that typical plant fire hazards can be simulated during the annual firefighting practice session.
As a part of this practice, SCBA should be worn during all firefighting exercises rather than during the specific SCBA training only.
~
P
~
a TVA Res onse 1
The central training facility provides simulation of plant fire hazards and additional training is given at the plant site..
Sel f-contained breathing apparatus (SCBA) is worn during firefighting exercises in which it is deemed necessary by simulated conditions.
4.4.6 The annual physical exam currently given to each AUO should verify that he is capable of performing
, necessary firefighting tasks under physical stress.
Similar physicals should be given to all brigade support personnel as well, if they are to be involved in actual firefighting.
TVA Res onse 447 All Level I fire brigade members are given annual phys'ical examinations to verify that they are capable of performing necessary firefighting tasks under physical stress, Cri tiques of quarterly fire drills should be improved and expanded to describe the brigade response (list specific names),
problems that were encountered, and actions taken by the brigade.
The drills should be carefully pre-planned and made as realistic as possible.
SCBA and firefighting equipment, such as charged hose lines, should be utilized to simulate actual fire conditions.
The use and evaluation of existing procedures should be stressed.
(See Appendix F for additional suggestions on fire drills.)
TVA Res onse Critiques of quarterly fire drills list the brigade members who responded, problems that were encountered, and actions taken by the brigade.
The drills are carefully pre-planned using existing procedures and made as realistic as possible.
4.4.8 Specific trai ning should be provided to brigade personnel on the proper use of the fire department type pumper which is provided at the plant.
TVA Res onse Training on the proper use of the fire department type pumper has been provided to approximately 75 percent of the fire brigade members.
The remaining members will be trained as scheduling will permit.
."c'f<}
4.4.9 The annual Athens Fire Department training program should include a joint drill for brigade and fire department personnel.
This will improve awareness of each group's capabilities.
TVA Res onse 4.4.10 Presently, no offsite agreement exists.
Brigade personnel should wear full protective equipment for their safety during all firefighting operations.
Turnout coats, SCBA, gloves, and helmets should be worn as an absolute minimum for all interior fire incidents.
TVA Res onse 4.4.11 Present procedures requiring brigade personnel to wear appropriate protective equipment for the particular si tuation simulated are considered adequate.
Brigade communications should be improved through
.the purchase and proper use of new portable radios (now on order).
TVA Res onse 4.4.12 This item is complete.
Pre-fire plans should be developed for all important areas of the plant but with special emphasis on safety-related areas or areas which expose safety-related areas (e.g., refuel floor, control rooms).
TVA Res onse Plant personnel are currently reviewing and updating the existing pre-fire plans in conjunction with the quarterly drills.
New pre-fire plans will be developed where necessary.
4.4.13 Brigade members should be cautioned about the use of fog nozzles on the refueling floor when the new fuel vault is open.
TVA Res onse This item is complete.
P'