ML19208A876
| ML19208A876 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/16/1979 |
| From: | Little W, Riden M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19208A874 | List: |
| References | |
| 50-346-79-15, NUDOCS 7909180115 | |
| Download: ML19208A876 (10) | |
See also: IR 05000346/1979015
Text
.
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
,
REGION III
Report No.:
50-346/79-15
~_
Docket No.:
50-346
License No.: NPF-3
Licensee:
Toledo Edison Company
Edison Plaza
300 Madison Avenue
Toledo, OH 43652
Facility Name: Davis-Besse 1
Inspection At: Oak Harbor, OH
Inspection Conducted: June 19-22, 1979
7///*/77
Inspector:
M.
.
.
,
/7
Date
Approved By:
W. S.
ittle, Chief
7 #
Nuclear Support Section 2
/
bate
Inspection Summary
Inspection on June 19-22, 1979
(Report No. 50-346/79-15)
Areas Inspected: Special, unannounced inspection of fire protection
commitments and acceptability of alternate hot shutdown procedures in
the event of a single fire, procedures which would provide a backup to
the service water system for fire protection, and administrative controls
established to follow the supplemental staff guidelines (Vassallo letter
dated August 29, 1977).
The inspection involved 27 inspector-hours
onsite by one NRC inspector.
Results: Of the three areas inspected, no apparent items of noncompliance
or deviations were identified in one area; one item of noncompitance was
identified in each of the remaining two areas (infraction-failure to
review and approve fire protection program implementation procedures,
Paragraph 3; and deficiency-failure to establish, implement and maintain
adequate procedures covering fire protection program implementation,
Paragraph 5).
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DETAILS
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1.
Persons Contacted
- T.
Murray, Station Superintendent
-
B. Beyer, Assistant Station Superintendent
-
G. Wells, Administrative Coordinator
R. Chesko, Operations Support Engineer (Station Fire Marshall)
- W. Nissen, Reactor Operator (Station Fire Chief)
L. Haige, Plant Process System Engineer
D. Briden, Chemist and Health Physicist
B. Geddes, Health Physics Supervisor
J. Hickey, Training Supervisor
C. Daft, QA Manager
- J.
Byrne, QA Engineer
- Denotes licensee representatives attending the management interview.
2.
Licensee Action on Previous Inspection Findings
(Closed)
Noncompliance (346/79-02-01 and 346/79-02-02): The
inspector verified that the licensee had implemented corrective
action for two previously identified deficiencies, failure to
conduct fire brigade drills quarterly and lack of control for
required reading lists.
There are no further concerns.
3.
Alternate Hot Shutdown Procedures in the Event of a Single Fire
In responsc to commitments made by letter dated November 25, 1978
as a result of a fire protection review meeting held on October 25,
1978, the licensee established a program of fire pre-plans, administrative
procedure AD 1810.03, approved on February 27, 1979.
In order to
minimize the mitigating circumstances of a fire in the safe operation
and shutdown of the plant, the pre-plans describe the actions
required to minimize the effects of a fire in the event that hot
and/or cold shutdown safety related equipment or wiring is involved
in the fire (i.e., bypass available, uneffected redundant safety
related equipment available, non-safety related equipment availabic,
fire suppression capabilities, etc.).
A method of individual room
or area fire pre-plans is being utilized, as exemplified by:
Shutdown panel room 324, " Auxiliary Shutdown Panel and CD
a.
Switchgear Room", written February 26, 1979 and
b.
Cable Spreading Room 422A, " Cable Spreading Room", written
February 28, 1979.
The licensee identified a total of sixty-five pre-plans necessary
for hot and/or cold shutdown; of which six are for cold shutdown
only, five for hot shutdown only, and fifty-four for hot and cold
shutdown. A review of fifty-nine for hot and cold shutdown, and
hot shutdown only indicated that as of June 20, 1979 thirty-nine
358031
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had been distributed for use (4 in February, 33 in March, and
2 in April) and twenty written.
.
Summary of Shutdown Pre-Plans
Hot And/Or Cold
Type
Cold Only
Written
Distributed
Total
5
5-
Hot
---
---
20
34
54
Hot & Cold
---
Subtotal
20
39
59
Cold
6
6
Grand Total
65
A review of pre-plan procedure content indicated some instructions
that are contrary to the intent of Appendix A to BTP 9.5-1.
The
guidelines for fire attack for room number 208, #1 mechanical
penetration room, gives instruction to "Deenergize Electrical
Equipment Prior To Attempting To Extinguish An Electrical' Fire".
The licensee identified nine pre-plans which contained unsatisf actory
instructions on how to override the radiation monitoring syLtem
connected to the exhaust ductwork upstream of the exhaust prefilter
which was designed to shutdown the purge exhaust fan and close the
fan isolation damper if the equipment sensed that smoke from a fire
was contaminated due to high airborne activity.
The only emergency procedure changed in the event of a fire was EP
1202.33, " Emergency Operation Of The NSS", prepared on June 5,1979
to reduce the possibility of the make-up tank going solid, to
provide a reliable means of maintaining RCP seal flow, and to delay
tripping of the main feedpumps until the auxiliary shutdown panel
was manned.
The inspector examined the licensee's procedures and records to
verify that administrative controls and approvals are being performed
within established commitments and technical specifications.
In
order to implement the fire protection program for fighting fires
in all safety-related areas and areas presenting a hazard to safety-
related equipment, the licensee established fire pre-plan procedures.
Paragraph 1.L.4 of AD 1810.03 states in part that fire pre-plans
will be approved by the station fire marshall and the assistant
station superintendent. Included in the fire pre-plans are operation
instructions in the event that hot and/or cold shutdown safety-
related equipment or wiring is involved in a fire and auxiliary
building ventilation system release controls.
Fire emergency
procedure EP 1202.35 needs to be changed to guide control room
personnel to the fire pre-plans in event of fire (346/79-15-03) .
It is the inspector's position that fire pre-plans should be properly
reviewed and approved prior to implementation.
This finding represents
noncompliance with the requirement that fire protection program
implementation procedures be reviewed by the SRB and approved
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35S032
.
by the station superintendent under technical specifications 6.8.1.a and 6.8.2
(346/79-15-01).
4.
Procedures Which Would Provide A Backup To The Service Water
System For Fire Protection.
In response to commitments made by letter dated January 10, 1979,
as a result of a fire protection review meeting held on October 25,
1978, the licensee revised emergency procedure EP 1202.19. " Service
Water", on April 25, 1979. Paragraph 5.5 of the aforementioned
procedure descriptively outlines how the condenser circulating
water system can be lined up to supply primary loads. A review of
the procedure content identified.that the instructions did not
include a valve line-up check sheet or return to normal
(346/79-
15-04).
The inspector reviewed the P&ID showing system intertie from the
circulating water pump discharge to the service water heater and
vital heat loads and return to the circulating pump suction.
The
licensee did not provide documentation of eagineering calculations
that would verify minimum flow and head capabilities or load requirements
showing that the necessary circulating water pump and/or valves can
be operated with only onsite power during hot shutdown.
Also, a
functional test to verify that the circulating water system can
supply minimum flow and head to vital service water heat loads has
never been performed nor does the licensee plan to test the system.
This matter is being referred to headquarters for further review
and is considered unresolved (346/79-15-05) .
An inspection was conducted to determine whether both channels of
redundant equipment or wiring used to accomplish hot shutdown would
be damaged in the event of a single fire.
The two service water
(SW) isolation valves to circulating water, MV 1399 (Loop 1) and MV
1395 (Loep 2), are located in the same area ten feet apart.
Electrical
control wiring of each travels in opposite direction to their
respective MCC cabinets (E12C and F12C) located thirty feet apart
in separate rooms.
The breckers for MV 1399 and MV 1395 are BE
1277 and BF 1277 respectively.
The two circulating water pump
discharge valve breakers and wiring for number 3 and 4 pumps are
located in the same area with a minimum of ten feet of separation.
(The breakers are MCC cabinets E31B and F31B respectively.)
The
two circulating water pumps involved (#3 and #4) are located in the
same area and fed by breaker HA 12 of "A" bus from Room 325 and
breaker HB 12 of "B" bus from Room 323 respectively.
Electrical
wiring to the two subject circulating water pumps from the "A" and
"B" bus travel under the turbine building 585 elevation floor and
are embedded in concrete.
Both cables penetrate the turbine building
floor wall of the circulating water pump room at the same point in
the area of Column HR-7.
In the event of a single fire in the
aforementioned area, both charnels of wiring used to accomplish hot
shutdown by the subject backup system would be damsged.
This
matter is being referred to headquarters for further review and is
considered unresolved (346/79-15-06).
No items of noncompliance or deviations were identified.
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5.
Administrative Controls Established To Follow The Supplemental
Staff Guidelines.
The administrative controls for nuclear plant fire protection
consist of the fire protection organization and its qualifications,
fire brigade training, the controls over combustibles and ignition
sources, methods for assuring the availability of the fire protection
systems and equipment, procedures for fighting fires, fire watch,
and quality assurance provisions for the fire protection program.
The inspector conducted a comprehensive review of the licensee's
administrative controls for fire protection, as detailed in the
following sections. The following sourcer were used as references:
Reference (1)--NRC Guidelines entitled, " Nuclear Plant Fire Protection
Functional Responsibilities, Administrative Controis,
and Quality Assurance".
Refer: ed to by the licensee
as the Vassallo letter dated August 29, 1977.
Reference (2)--NRC Memorandum of January 29, 1979, entitled, " Fire
Protection Administrative Controls Review-Fire
Brigade Size".
Reference (3)--NRC temporary instruction TI 2515/16 entitled, "IE Fire
Protection Reviews, Program Plan".
Reference (4)--Davis-Besse Nuclear Power Station Fire Hazard Analysis
Report dated January 11, 1979.
Reference (5)--Licensee response dated November 25, 1978 to a meeting
held on October 25, 1978 on the Davis-Besse fire
protection program.
Reference (6)--Licensee operating license number NPF-3 dated April 22,
1977, Paragraph 2.c(3)h.
The inspection revealed that, subject to implementation of the
following described changes, the control of nuclear plant fire
protection functional responsibilities and administrative controls
conforms to the provisions of supplemental guidance of Appendix A
to BTP 9.5-1 and is, therefore, acceptable.
a.
Fire Protection Organization
The licensee's fire protection organization contains the
organizational responsibilities and lines of communication
between the various positions through the use of functional
descriptions of each position's responsibiities. Upper level
offsite management positions (i.e., the Vice Presidents,
facilities development and energy supply) are designated which
have management responsibility for the formulation, implementation,
and assessment of the effectiveness of the nuclear plant fire
protection program.
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ObbO'Q
.
The results of these assessments are reported to the upper
level management position responsibility for fire protection
'
with recommendations for improvements or corrective atrions as
deemed necessary. The organizational responsibilities are
delineated through onsite management positions for testing,
maintenance, review of fire protection systems and for fire
brigade training. Qualification requirements have not been
established for fire brigade members and the fire protection
engineer.
It was determined that only one individual of the
station operations organization, which presently supplies all
fire brigade members, was qualified in respiratory training
(346/79-15-07).
In order to be properly qualified in respiratory
training, each fire brigade member must satisfactorily complete
a physical examination including periodic screening (spirometry
pulmonary function test) for performing strenuous activity as
required by reference (1), Attachment (1), Paragraph 2.0(b),
which was not included in the licensee's fire protection
program (346/79-15-08) . Administrative controls for a tire
protection engineer (licensee employee or consultant) as
outlined in reference (1), Attachment (1), Faragraph 2.0(a),
are not included as a part of the licensee's fire protection
functional responsibilities.
The licensee's minimum eligibility
requirements of a fire protection engineer position should be
specified (346/79-15-09).
The inspection revealed that, subject to implementation of the
above-described changes, the fire protection organization
conforms to the provisions of supplemental guidance of Appendix A
to BTP 9.5-1 and is, therefore, acceptable.
b.
Fire Brigade Training
The fire brigade training program consists of an initial
classroom instruction program followed by periodic classroom
instruction, practice in fire fighting and fire drills.
Administrative controls do not provide for the classroom
instruction program to be repeated over a two year period as
required by Reference (1), Attachment (2), Paragraph 1.0(d)
(346/79-15-10).
Although practice sessions are held for fire
brigade members as outlined in Reference (1), Attachment (2),
Paragraph 2.0, the licensee's administrative controls do not
require practice sessions under strenuous conditions (346/79-
15-11).
Contrary to Reference (1), Attachment (2), Paragraph
-
3.0(e), the licensee does not perform at least one drill aer
year on a "back shift" for each fire brigade (346/79-15-12);
nor is a sufficient number of drills, not less than one f>r
each fire brigade per year, unannounced (346/79-15-13).
Thus,
the fire readiness of the plant fire brigade leader, brigade,
fire protection system and equipment has not been determined.
The licensee's administrative controls for fire brigade training
should require that the classroom instruction program be
repeated over a two year period, practice sessions be held
under strenuous conditions, at least one drill per year be
performed on "back shift" for each fire brigade, and a sufficient
number of drills for each fire brigade per year be unannounced.
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3380%~.
.
The inspection revealed that, subj ect to implementation of the
above-described changes, the fire brigade training conforms to
the provisions of supplemental guidance of Appendix A to BTP
9.5-1 and is, therefore, acceptable.
c.
Control of Combustibles
~
_
Administrative controls have been established to minimize the
amount of combustibles that a safety-related area may be
exposed to and to assure that these items are not stored in
safety-related areas.
Station procedures have been established
to ensure that fire retardant lumber of good abrasion resistance
is used inside buildings containing safety-related systems.
Administrative controls should provide for additional portable
suppression equipment to be brought into the area when a
transient fire load causes the total fire load to exceed
existing capabilities as described in Reference (1), Attachment
(3), Paragraph (b) (346/79-15-14).
The inspection revealed that, subject to implementation of the
above-described changes, the control of combustibles conforms
to the provisions of supplemental guidance of Appendix A to
BIP 9.5-1 and is, therefore, acceptable.
d.
Control of Ignition Sources
The control of ignition sources instituted are to protect
safety-related equipment from fire damage or loss resulting
from work involving ignition sources, such as welding, cutting,
grinding, or open flame work. Administrative controls established
require review and approval by a responsible supervisor prior
to performing cutting, welding, grinding, or open flame work;
proper removal or covering of combustible material; use of
trained and equipped fire watches; signature concurrence; and
acceptable methods of leak testing.
Dow Corning RTV 3-6548
silicone foam (Parts A and B) with 732 and 793 sealant is used
as fire stop material.
The licensee has provided a description
of proposed administrative controls for AD 184'. 00 which by
July 31, 1979 will require the fire watch to remain In the
area for at least 30 minutes after the work is completed to
check for smoldering fires. Contrary to Reference (1), Attachment
(4), Paragraph 4.0, there are no procedure restrictions prohibiting
smoking in safety-related areas.
Administrative controls
should be established to prohibit smoking in safety-related
areas and identify these areas with "No Smoking" signs (346/79-
15-15).
The inspection revealed that, subj ect to implementation of the
above-described changes, the control of ignition sources
conforms to the provisions of supplemental guidance of Appendix A
to BTP 9.5-1 and is, therefore, acceptable.
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,
e.
Fire Fighting Procedures
The licensee has provided an adequate description of its
current fire fighting procedures, those under development and
those planned to be developed in the near future.
Fire fighting
proce.ures/ pre-plans are established to cover such items as
notification of a fire, fire emergency procedures, coordination
of fire fighting activities with offsite fire department,
strategies for fighting fires in all safety-related areas and
areas presenting a hazard to safety-related equipment.
Provisions
have been made for including offsite fire fighting organizations
in fire brigade drills and training as required. As described
in Section 3 of this report, some procedure changes will have
to be made to EP 1202.35, AD 1810.03 and the pre-plans due to
isolated incomplete instructions.
The inspection revealed that, subject to implementation of the
above-described changes, the fire fighting procedures conform
to the provisions of supplemental guidance of Appendix A to
BTP 9.5-1 and is, therefore, acceptable.
f.
Quality Assurance
The design, procurement, installation, testing and administrative
control activities for the fire prote ion quality assurance
program criteria of Appendix A to B7' 9.5-1 will be controlled
in accordance with an approved QA program under 10 CFR Part 50, Appendix B.
Audits are performed at least annually to
provide an overall assessment of conformance to fire protection
requirements. An inspection and audit of the fire protection
program will be performed by a qualified outside fire consultant
at least once per 36 months.
The inspection revealed that the control of quality assurance
for fire protection conforms to the provisions of supplemental
guidance of Appendix A to BTP 9.5-1 and is, therefore, acceptable.
g.
General
As discussed in the previous sections, based on Reference (3),
the licensee established inadequate written procedures in
implementing the fire protection program, which are classified
in the following categories:
(1) Those provisions which the licensee is required by Reference
(6) to implement prior to startup following the first
regularly-scheduled refueling outage, but has established
incomplete administrative controls for the fire protection
organization:
--
Physical examination for each fire brigade member
(346/79-15-08).
Fire Protection Engineer Qualifications (346/79-15-09)
--
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.
(2) Those provisions which the license actually meets, but
without administrative controls:
Practice sessions under strenuous conditions (346/79-
--
15-11).
_
-
Restrictions prohibiting smoking in safety-related
--
areas (346/79-15-15) .
(3) Ths se provisions which the licensee is committed by
refcrences (4 and 5) to implement by February,1979, but
has not established administrative controls and is delinquent
in:
--
Performing at least one drill per year on a "back
shift" for each fire brigade (346/79-15-12).
--
Safficient number of unannounced drills (346/79-15-
13).
(4) Those provisions which the licensee is committed by
references (4 and 5) to implement by February,1979,
which is not controlled by administrative procedures but
is not yet delinquent in providing:
--
Classroom instruction program to be repeated over a
two year period (346/79-15-10).
--
Additional portable suppression equipment for transient
fire loads (346/79-15-14).
These findings represent an item of noncompliance with
the requirement of technical specification 3.8.1 which
requires in part that written procedures be established
covering the fire protection program implementation
(346/79-15-02).
6.
Unresolved Items
Unresolved items are matters about which more information is required
in order to ascertain whether they are acceptable items, items of
noncompliance, or deviations. Unresolved items disclosed during
the inspection are discussed in Paragraph 4.
7.
Exit Interview
The inspector met with licensee representatives (denoted in
Paragraph 1) at the conclusion of the inspection on June 22,
1979.
The inspector summarized the scope and findings of the
inspection and provided an explanation of Reference (2).
The
licensee showed good faith in wanting to take appropriate
corrective action immediately and promised to give implementation
dates of the near future on identified outstanding items by
phone. A licensee representative made the following commitments
in response to certain of the items discussed on June 28, 1979
and July 5, 1979:
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95SO38
o
&
That previously distributed pre-plans will be reviewed by SRB
a.
and approved by the station superintendent by October 25, 1979
(Paragrcph 3).
.
b.
That EP 1202.35 will be changed to guide control room personnel
to the pre-plans by July 31, 1979 (Paragraph 3).
c.
That EP 1202.19 will be changed to include a valve line-up
check sheet and return to normal for using the circulating
water system as a backup to the service water by July 15, 1979
(Paragraph 4).
d.
That all fire brigade members will be qualified on respiratory
training by October 25, 1979 (Paragraph 5.AS.
e.
That the eight examples of noncompliance concerning procedure
changes te administrative controls will be completed by October 25,
1979 (Paragraph 5,G).
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