ML19256E702
| ML19256E702 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/12/1979 |
| From: | Banks H CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19256E695 | List: |
| References | |
| GD-79-2545, NUDOCS 7911150036 | |
| Download: ML19256E702 (7) | |
Text
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CP&L Carolina Power & Light Company October 12, 1979
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FILE: NG-3513 (B)
SERIAL: GD-79-2545
( " ~ I Fi 20 07 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 & 2 LICENSE NOS. DPR-71 AND DPR-62 DOCKET NOS. 50-325 AND 50-324 RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS
Dear Mr. O'Reilly:
Brunswick Steam Electric Plant has reviewed IE Inspection Report 50-324/79-28 and 50-325/79-29 and finds that it does not contain ac.7 information of a proprietary nature.
The report identifies one item that appears to be in noncompliance with NRC requirements and four items which appear to deviate from commitments to the Commission. These items and Carolina Power & Light Company's response to them are addressed in the following text:
Infraction:
As required by Provision 3.7.7.2 of the Technical Specifications, the automatic sprinkler system for the Unit 2 Reactor Building is required to be operable at all times. In the event the sprinkb r system becomes inoperable, a limiting condition for operation consisting of a fire watch with backup fire suppression equipment is required to be established within one hour.
Contrary to the above, the sprinkler systems for the 50- and 80-foot elevations in Unit 2 Reactor Building were found shutoff and thus inoperative on August 7, 1979, and the required limiting condition for operation had not been established.
Carolina Power & Light dompany's Response:
The sprinkler was immediately returned to service; a reason for its isolation could not be determined. FP-10, which requires that all valves which could interrupt the supply of water tc systems providing fire,rotection to safety-related areas or equipment be either locked or supervised,'as revised to include all such valves recently added to the fire protection systems. Full implementation of this revision will be by November 30, 1979, pending receipt of additional locks.
1337 245 411 Fayetteville Street e P. O. Box 1551 e Raleigh, N. C. 27609 911150 p r.T m n.-n r rn r. 7 - r Q
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October 12, 1979 Mr. James P. O'Reilly '
Deviation A:
A.
Sections IV.A (page 9) and IV.C.3.e.3 (page 4) of the licensee's Fire P.rotection Program Review (FPPR) state that all existing and future sprinkler systems will conform to the requirements of National Fire Protection Association (NFPA) Standard 13, " Sprinkler Systems" and NFPA-15, " Water Spray Fixed Systems".
Contrary to the above, automatic sprinkler systems had been installed for the areas specified in the FPR and FPSER, but the installations do not meet the criteria of NFPA-13 or NFPA-15 due to the following:
1.
Activation circuit to each sprinkler system deluge valve is not supervis,i as required by Sections 5-3.5.2 and 5-3.6 of NFPA-13 and Section 8-5 of NFPA-15.
2.
Sprinkler heads are installed below the ceiling / roof of structures at a greater distance than that permitted by the provision of Section 4-3 of NFPA-13 and/or are not properly located in cable tray as required by Section 4-4.1.4 of NFPA-15.
3.
Heat shields were used in some areas where sprinkler deflectors had been installed an excessive distance below ceilings, roofs, or floors. However, Section A-13-16.8 of NFPA-13 permits the use of heat shields only for sprinkler deflectors located beneath open grating.
4.
Sprinkler system deluge valves are activated by fire detection systems which have improperly located and spaced heat detectors.
Section 5-3.4 of NFPA-13 and Section 3-4 of NFPA-15 require fire detection devices to be installed in accordance with their listing by a nationally recognized testing laboratory or in accordance with the manufacturer's specifications.
5.
Sprinkler piping in some areas is not provided with sway bracing as required by Sections 3-10.3.4 and 3-15 of NFPA-13.
6.
Some sprinkler heads are obstructed by electrical and mechanical equipment and by beams and other structural supports due to heads not being located or spaced in accordance with Section 4-2.4 of NFPA-13.
7.
Many water flow alarms are installed on the supply side of the control valves in lieu of the system side of the valves as required by Section 3-9.1.2 (Figure A-3-9.1.2) of NFPA-13. Also, a number of systems are 1337 246
Mr. James P. O'Reilly October 12, 1979 not provided with test connections to properly test the water flow alarm devices.
8.
Corrosion resistant type sprinkler heads are not installed in areas where sprinklers are exposed to corrosion conditions as required by Section 3-16.3 of NFPA-13 and Section 2-2 of NFPA-15.
9.
Records were not provided to indicate that the underground water connections to each sprinkler system were flushed in accordance with the provisions of Sections 1-11-2.1 and 1-11.2.2 of NFPA-13 and Section 5-1 of NFPA-15.
Carolina Power & Light Company's Response:
A.1 A means of providing supervision of each sprinkler system deluge valve has been investigated and detail design work is in progress.
A.2 The installation of the sprinkler systems is being carefullv reviewed by plant engineers and the fire protection consultant for code compliance. Design changes are being made to assure that all heads are properly located per code requirements insofar as local conditions and type of hazard permit.
A.3 The system review described in A.2 above also includes heat shield locations.
Where shields are not needed for satisfactory sprinkler performance, they are not being installed, and where they currently exist but are not required, they are being removed.
In many applications, the sprinkler heads have to be installed well below the ceiling to prevent excessive disruption of the sprinkler's water distribution pattern by various interferences in accordance with NFPA-13, Appendix B,
Article B-4-2.3.
Where such head locations are necessary, heat shields must be installed to ensure head operation in a timely manner.
In addition, as agreed upon in the August 30, 1979 meeting, considering the overhead construction details of the diesel generator rooms, the location of existing heads relative to the ceiling and that the design basis fire is an oil fire, the use of heater collectors is acceptable.
A.4 A complete review of detector types, locations, and spacing has been made by the fire protection consultant.
The results of this review have been the issuance of design changes necessary to assure that the detectors are located to meet the requirements of NFPA-72E and the manufacturer's application guidelines.
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Mr. James P. O'Reilly October 12, 1979 A.5 The review of sprinkler systems described in A.2 above includes a review of pipe support subsystems.
Design changes, as necessary, will be made to provide pipe support, including sway bracing, to meet the provisions of ANSI B-31.1.
This will meet or exceed the intent of NFPA-13.
A.6 The review of sprinkler systems described in A.2 above includes the review of sprinkler head location with respect to interferences. Where problems are noted, design changes are being written to correct them.
A.7 The review of sprinkler systems described in A.2 above includes a review of the system flow alarms.
Where required, modifications are being written to place the ala nn location on the downstream side of the control valves.
A.8 All sprinkler heads in the Service Water Building will be changed to corrosion resistant-type heads when the other required design changes are incorporated.
A.9 All systems concerned are being flushed again in accordance with detailed, documented procedures to assure that a proper flush has been done and that proper documentation is available for review.
A revision in the plant modification procedure now requires ' hat each modification be reviewed by the plant fire protection engineer.
This review should assure that all items similar to those discussed in A.1 through A.9 are detected and corrected before installation.
Since the design work on Items A.1, A.3, A.5, A.6, A.7 and A.8 has not been completed, the date for development of the necessary modifi cations, ordering of materials, and completion of these proj ects cannot be established at this time.
Realistic compliance dates for these items will be provided when adequate information is available on the scope of the required modifications.
Brunswick Steam Electric Plant, in analyzing the existing design in view of the Sandia Test of September 1978, c'etermined tuat a philosophy change regarding three of the system', would result in a greater degree of protection than that provided by the original policy established in concert with the NRR fire protection review team.
Pending concurrence from NRR regarding the new design philosophy, no design work in these areas has been undertaken and thus no completion date can be established for Item A.2.
Items A.4 and A.9 will be completed by November 30, 1979.
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Mr. James P. O'Reilly October 12, 1979 Deviation B:
Sections IV.A (page 9) IV.C.3.e.2 (page 1) and IV.C.3.e.2 (page
- 3) of the FPPR state that the underground fire main loop was designed and installed to meet the requirements of NFPA-24, "Outside Protection". Section 3-1.1 of NFPA-24 states that all control valves in the fire protection water system shall be of the indicating type.
Contrary to the above, the sectional control valve provided in the fire protection water system at the turbine building (valve number
- 31) is located in a pit and is not an indicating type valve.
Carolina Power & Light Company's Response NFPA does allow inside screw-type gate valves when required by special conditions and approved by the authority having local jurisdiction. Due to the usage of the area, a post indicator could not be used. Installing an OS&Y valve would be difficult in that the pit would have to be rebuilt to accommodate the new valve. Since the position of the existing valve can be easily verified with a reach rod and since there is a normally open eight-inch loop around the valve, it is our position that the existing installation is satisfactory for the service involved.
Deviation C:
Sections IV.C.3.b (page 1) through IV.C.3.b (page 13) of the FPPR state that adequate administrative procedures for maintaining the perfo rmance of the fire protection system and plant personnel are provided to assure implementation of the fire protection / prevention program.
Contrary to the above, administrative control procedures for the fire protection / prevention program are provided, but have not been fully implemented. The following are examples of this deviation:
1.
The periodic test procedures for the fire protection systems do not list or include the recently installed fire protection systems. The inspection and tests on these new systems as required by the Technical Specifications are presently not being recorded. Two valves to the Unit 2 reactor building sprinkler system were found shutoff during this inspection.
2.
Administrative control procedures for the fire brigade have not been revised as stipulated by Section B.3.4 of FPSER to require an annual medical examination for each brigade member, quarterly training for the brigade, work requests to be reviewed to assure inclusion of proper fire protection provisions, and to include off-site fire fighting organizations in at least one fire brigade drill 1337 24
Mr. James P. O'Reilly October 10, 1979 3.
Procedures covering prefire plans have not been developed as stipulated by Sections B.2.1.3 and 3.2.4 of FPSER.
4.
Procedures for the control of combustible materials have not been revit2d to specifically prohibit the use of combustible scaffolding within the plant. Combustible wood scaffolding is being used throughout the plant whereasSection IV.C.3.b (page 5) of the FPPR states that only fire retardant wood will be used within the plant.
5.
Procedures for the control of open flame ignition sources are inadequate. The procedures do not include all types of open flame work. The roofing kettle (tar pot) provided for use at the plant is not construe.ed nor located in accordance with the provisions of Section 3-6 of NFPA-1, NFPA Fire Prevention Code due to the following:
The cover provided for the kettle is plywood in lieu of a.
a gravity operated steel lid as required.
b.
The unit uses gasoline for fuel whereas the use of a Class 1 flammable liquid is not permitted.
The kettle was located on the roof of the plant which c.
is not permitted.
6.
Procedures have not been revised or new prctVures prepared for the proper storage of flammable and combustible materials in the plant, such as the following:
a.
Combustible water treatment materials are not stored within the designated storage rooms on the 80-foot elevation of Units 1 and 2 reactor buildings as stipulated by Ser Lion IV.C.2.f (page 25) of the FPPR and Section 3.2.18 of the FPSER.
b.
A storage cabinet ta flammable and combustible materials is not provided for the 117-foot elevation of the Unit 2 reactor building as stipulated by Section IV.C.2.f (page 28) of the FPPR and Section 3.1.18 of FPSER.
Carolina Power & Light Compary's Response:
Due to the continuous state of change which has existed in the fire protection systems over the past year, it has been difficult to revise the administrative control procedures for the fire protection / prevention program at the rate the modifications are being completed. Additional manpower resources have been applied to the effort of updating the various procedures, establishing required new procedures, and maintaining them current.
1337 250
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Mr. James P. 0'Reiily October 12, 1979 Full compliance with Item C.1 will be af ter the completion of all the plant modifications; however, the procedures 'ill be continually up6ated as each modification is complete.
Full compliance of Item C.2 will be completed by December 1, 1979.
Full compliance of Item C.3 was achieved S.,
mber 30,1979.
Full compliance with Items C.4, C.5 and C.6 will be completed by December 1,1979.
Deviation D:
Section IV.C.3.d.4 (page 12) of the FPPR and Section 3.1.23 of the FPSER state that an air compressor to refill the self-contained breathing apparatus was to be orovided by July 15, 1979.
Contrary to the above, the air compressor has not been provided.
Carolina Power & Light Company's Response:
The date for delivery from the supplier has slipped due to TMI priority work. Delivery is now expected by October 31, 1979.
Very truly ours,
s H. R. Banks Manager Nuclear Gneration REP /RMP/jga*
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