ML19256E717
| ML19256E717 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 09/18/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19256E695 | List: |
| References | |
| 50-324-79-28, 50-325-79-29, NUDOCS 7911150055 | |
| Download: ML19256E717 (4) | |
Text
.
APPENDIX B NOTICE OF DEVIATION Carolina Power and Light Company License Nos. DPR-71 Brunswick DPR-62 Based on the results of the NRC inspection conducted on August 6-10 and 30, 1979, certain of your activities appear to deviate from your commit-ments to the Commission and have safety significance.
The fire protection modifications as listed in the licensee's Fire Protection Program Review dated January 1, 1977 and in NRC's Fire Protec-tion Evaluation Report (FPSER) for the facility dated November 22, 1977 and supplements thereto were scheduled to be completed during the 1979 refueling outage. However, the following items were found incomplete after the stated completion date or the modifications failed to meet the provisions of applicable guides, codes or standards which are approved by the Commission:
A.
Sections IV.A (page 9) and IV.C.3.e.3 (page 4) of the licensee's Fire Protection 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 abcve, 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 supervised 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 struc-tures 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 dcflectors had been installed an excessive distance below ceilings, roofs or floors. Howuer Section A-13-16.8 of NFPA-13 permits the use of heat shields only for sprinkler deflectors located beneath open grating.
1337 255 7911150 hb5
Carolina Power and Light Company Appendix B Brunswick Notice of Deviation 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 laborattry 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 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 corrosive condiuons 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.
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.
C.
Sections IV.C.3.b (page 1) through IV.C.3.b,(page 13) of the FPPR state that adequate administrative procedures for naintaining the performance of the fire protection system and plant personnel are provided to assure implementation of the fire protection / prevention program.
M ontrary to the above, administrative control procedures for lh'e fire protection / prevention program are provided, but have not been 1337 256
Carolina Power and Light Company Appendix B Brunswick Notice of Deviation revised to meet the variour commitments to the NRC and to include the recently installed fire protection systems. Also, the existing procedures have not been fully implemented. The following are examples of this deviation:
1.
The periodic test proceaures 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 where found shut off 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 organizriions in at least one fire brigade drill per year.
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 revised 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 constructed 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 a.
lieu of a gravity operated steel lid as required.
b.
The unit uses gasoline for fuel vhereas the use of a Class 1 flammable liquid is not permitted.
/
The kettle was located on the roof of the plant which is c.
not permitted.
1337 257
Carolina Power and Light Company Appendix B Brunswick Notice of Deviation 6.
Procedures have not been revised or new procedures 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'eleva-tion of Units 1 and 2 reactor buildings as stipulated by Section IV.C.2.f (page 25) of the FPPR and Section 3.1.18 of the FPSER.
b.
A storage cabinet for 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.
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 provided by July 15, 1979.
Contrary to the above, the air compressor has not been provided.
/
1337 258
-