ML19305C562
| ML19305C562 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 03/03/1980 |
| From: | Widner W GEORGIA POWER CO. |
| To: | Bryant J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19305C561 | List: |
| References | |
| NUDOCS 8003310081 | |
| Download: ML19305C562 (10) | |
Text
I G;orgia Power Cornpiny 230 Psichtru Strict Post Office Box 4545 Atlanta, G;orgia 30302 Telephone 404 522-6060 A
Power Generation Department March 3, 1980 Georgia Powcr tre scyrgn enw U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement
REFERENCE:
Region II - Suite 3100 RII: WHM 101 Marietta Street, NW 50-321/80-02
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Atlanta, Georgia 30303 50-366/80-02 c.
Attention:
Mr. J. C. Bryant w
Gentlemen:
cr The inspection conducted by Mr. W. H. Miller, Jr. of the U. S.
Nuclear Regulatory Commission's Region II Office of Inspection and y
Enforcement on January 8-11, 1980, resulted in the determination that certain activities associated with the fire protection program at Plant Hatch appeared to deviate from commitments made to the NRC. Your letter of February 8, 1980, cited those deviations and requested that each be addressed by Georgia Power Company describing the corrective action taken or planned.
Submitted herein is that response.
DEVIATION:
A.
Section IV.B.7 of the EFPP states in part that the ten Quality Assurance (QA) criteria of Section C of Appendix A to NRC's Branch Technical Position APCSB.9.5-1 (BTP 9.5-1) will be applied commensurate with the controls described in the Operational QA Program and that*the QA program for fire protection will be under the management control of the QA organization.
Contrary to the above, documentation is not available or is not easily retrievable to demonstrate that the fire protection modifications required by the FPSER and the EFPP were accomplished under the following ten QA program criteria as listed in BTP 9.5-1.
RESPONSE
Georgia Power Company has in effect a Quality Assu-rance program which addresses all aspects of 10 CFR 50, Appendix B.
Currently a study is underway to insure that the 10 criteria applicable to Fire Pro-tection, as referenced in the Hatch EFPP, have been included in the design,' procurement, installation, and testing of the Fire Protection Systems.
Verifi-cation that the present installation meets the requirements of codes, standards and specifications is being conducted. Any rework, including design, O&
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Georgia Power d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Atlanta, Georgia 30303 March 3, 1980 Page Two procurement, installation and testing, will be per-formed under an approved Quality Assurance Program.
Audits by the Quality Assurance Department will verify that the QA program is met in all phases of the rework.
DEVIATION:
B.
Section IV.C.3.c of the EFPP states in part that all of the automatic sprinkler systems installed at the plant conform to the requirements of National Fire Protection Association Standard No. 13 (NFPA-13),
Sprinkler Systems.
Contrary to the above, the sprinkler system installa-tions do not fully meet the requirements of NFPA-13.
RESPONSE
This item has been discussed in detail with fire protection engineers.
It is our conclusion that several sprinkler systems within the plant could and should have been installed to comply with the National Fire Pro'tection Association Code #13 -
(Applicable during year of system design). Modifi-cations to these systems will be made as nacessary to bring them into code compliance.
Other systems, specifically those which are included as commit-ments in the Hatch EFPP, were installed to meet special hazards protection as deemed necessary by the NRC's Fire Protection Committee in license meetings during January of 1978.
Based on these special protection needs and the design intent of each systen, an evaluation of each system has been made. As a result of this evaluation, several modifications may be necessary to meet design intent and some system designs may be justified in their "As-Built" configuration.
It should be understood that the systems installed for special hazard appli-cations were not installed with the intent of meet-ing NFPA 13.
This will be clarified in a revision to the Hatch EFPP. Modifications to existing sys-tems and compliance with the Georgia Power Company QA Program for Fire Protection will prevent future occurrences. Full compliance is expected by January, 1981.
GeorgiaPower b U. S. Nuclear Regulatory Commission Office of Inspectica and Enforcement Atlanta, Georgia 30303 March 3, 1980 Page Three DEVIATION:
C.
Section III.C.4. (b) of the EFPP states in part that the storage of transient combustibles within the east cableway of Unit I will be controlled by admin-istrative procedures and by signs.
Contrary to the above, approximately 45 boxes of HEPA filters were stored within the Unit 1 east cableway during this inspection.
This storage was located adjacent to a sign which read: " CAUTION -
Storage of Combustibles Prohibited."
RESPONSE
Special floor markings will be utilized in the east cableways to indicate control of combustibles.
HNP-559, Control of Combustibles will be revised to reflect the use of the special floor markings.
This action is expected to prevent future occurrences.
Full compliance is expected by April 7, 1980.
DEVIATION:
D.
Section III.A. of the EFPP states in part that fire prevention at the plant will be accomplished by early identification of and elimination of fire hazards through periodic inspections of areas to identify combustible materials or other fire hazards which may develop in these areas.
Section III.B.
of the EFPP states in part that housekeeping require-ments are fulfilled by the building and grounds e
supervisor and forcman using good established house-keeping practices w'th housekeeping audited by peri-odic management insp ections.
Section III.C.4 of the EFPP states in part dult a curb will be added around each pump division to control any oil that may leak from the pumps.
Contrary to the above, on January 9, 1980, the curb area for the Unit 2 RER pumps was found approximately 25% full of a water-oil solution which constituted a fire hazard.
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GeorgiaPbwerd U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Atlanta, Georgia 30303 March 3, 1980 Page Four
RESPONSE
A Standing Order has been written to require the Plant Equipment Operator to check the oil catchment area once per shift. The SO requires reporting of any leaks (water or oil) to the Shif t Foreman on duty. HNP-1-1060, Daily Rounds Procedure, will be revised to include this check at least once per shift.
The SO will remain in effect until the procedure is revised. The inclusion of this requirement in the
" Rounds" procedure will prevent future occurrence.
Full compliance is expected by April 7, 1980.
DEVIATION:
E.
Section III.C.4 of the EFPP states in part that the storage of transient combustibles within the river intake structure will be controlled by appropriately marking the floor areas.
Contrary to the above, the floor areas are not marked and/or signs are not provided to prohibit the storage of combustibles within the river intake structure.
RESPONSE
This response will be the same as that identified under Deviation C.
The oc'.y exception is that signs have been replaced on the Intake Structure entrance doors. Full compliance is expected by April 7, 1980.
DEVIATION:
F.
Section IV.C.2.a of the EFPP states in part that the exterior (fire protection) underground yard main loop is designed in accordance with NFPA-24, Outside Protection.
Contrary to the above, the supply connection from the exterior fire protection water system to the sprinkler / standpipe system within the river intake structure is not provided with an independent out-side control valve as required by Section 3-3.1 j
of NFPA-24. The existing control valve for the
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water supply to the building also controls the water to the fire hydrant installed adjacent to j
the intake structure.
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Georgia Pbwer d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Atlanta, Georgia 30303 March 3, 1980 Page Five
RESPONSE
The exterior fire protection water system to the sprinkler / standpipe system within the Intake Struc-ture will be provided with an independent outside control valve as required by NFPA 24.
A Design Change Request (DCR) is being formulated to facili-tate this modification.
Modification of this system and compliance with the Georgia Power Company QA program for fire protec-tion will prevent future occurrence.
Full compli-ance is expected by January, 1981.
DEVIATION:
G.
Section III.C.1.2 of the EFPP states in part that all openings in the fire walls or barriers around the control room will be provided with three-hour fire doors and that the wall between the control room and peripheral rooms will have a one-hour fire rating.
Section IV.B.l.j states in part that all openings in fire rated walls will be protected by fire doors, frames and hardware that are listed by Underwriters Labora^ories (UL). UL requires all fire doors to be it stalled in accordance with the provisions of NFPA-80, Fire Doors and Windows in order for the doors to retain their UL listing.
Contrary to the above, the fire doors in the fire walls / barriers between the control room and adja-t cent areas do not fully meet the provisions of NFPA-80.
RESPONSE
(1) A Maintenance Request (MR) will be submitted to place closers on the doors between the control room and peripheral rooms. Also a program will be established to inspect all other fire doors in the plant to insure their compliance to the applicable sections of NFPA 80-1977.
(2) The feasibility of using positive latching on the Security / Fire Doors is being researched.
The con-trol room is maintained under positive pressure to comply with habitability requirements and doors s
GeorgiaPowerb U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Atlanta, Georgia 30303 March 3, 1980 Page Six are left unlatched to comply with tornado venting requirements.
Based on the results of the research, modifications will be made as necessary, or the Hatch EFPP will be revised to take exception on these doors based on the above design requirements.
Compliance with the Georgia Power Company QA pro-gram is expected to prevent future occurrences.
Full compliance is expected by August, 1980.
DEVIATION:
H.
Section III.C.l.1 of the EFPP states in part that smoke detectors will be installed within the peri-pheral rooms adjacent to the control room.
Contrary to the above, rate of rise type (heat) fire detectors have been installed in the peripheral room kitchen in lieu of smoke detectors.
RESPONSE
Two rate-of-rise type fire detectors were placed in the kitchen adjacent to the Control Room in lieu of smoke detectors.
The Hatch EFPP references
" Smoke Detectors" for this area and does not allow for the use of rate-of-rise type fire detectors.
The Hatch EFPP will be revised to clarify the use of fire detectors.
This action is expected to pre-vent future occurrences.
Full compliance is expected by August, 1980.
DEVIATION:
I.
Section IV.C.1.4. (g) of the EFPP states in part that the automatic sprinkler system installed in the 130-foot control building corridor will be designed such that it will not spray on the safety related cabinets that are located in the corridor.
Contrary to the above, four safety related cabinets are located in the corridor directly beneath the ceiling level sprinkler systec. Protection has not been provided to prevent the sprinkler system from l
discharging water directly on to these cabinets, nor has an evaluation been made to determine if the inherent protection provided by the construction of the cabinets is adequate to prevent water damage to this equipment.
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Georgia Power d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Atlanta, Georgia 30303 March 3, 1980 Page Seven R ESPONS E:
Design work is in progress to provide shielding such that sprinkler water will be prevented from entering the safety related cabinets in the 130 foot elevation control building corridor.
Once the design package is complete, a Maintenance Request will be submitted to impicment the design change.
Completion of this design change and compliance with the Georgia Power Company QA program will prevent future occurences.
Full compliance is expected by August, 1980.
DEVIATION:
J.
Table 3 Item No. III.39 (Response no. 25(a) to NRC questions of June 13, 1977) of the EFPP states that a mobile platform for fire fighting operations will be provided in both the northwest and southwest cable areas of each unit.
Contrary to the above, a mobile platform was not located in the northwest cable area of unit 1.
RESPONSE
The mobile platforms for the northwest and southwest cable areas have been locked into position with fire protection break-away locks.
Signs have been placed on the platforms which prohibit their use except for fire emergencies.
A Management Memo has been written and routed to key plant personnell which establishes
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the policy for use of the platforms. The platform locations will be checked during the weekly fire protection inspections.
k The above actions are expected to eliminate future occurrences. Full compliance has been achieved.
DEVIATION:
K.
Table 3 Item No. III.43 (Response to NRC question 25.e. (3) of June 13, 1977) states in part that the
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control valves in the drain piping system from the Unit 1 and 2 reactor recirculation M-G set rooms which terminate at the floor of the 130-foot eleva-tion of the reactor building will be maintained closed with the valves locked in the closed position.
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Georgia Power d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Atlanta, Georgia 30303 March 3, 1980 Page Eight Contrary to the above, the control valves in the drain piping from the reactor recirculation M-G set rooms were found closed but were not locked in the closed positicn.
RESPONSE
The control valve for the drain piping from the Unit 1 Recirculation M-G Set Rooms has been locked in the closed position. Access to the key for this lock is controlled through a key control procedure. The control valve for the same area of Unit 2 has not been locked as yet.
This valve is a
" Butterfly" type valve and may require welding a lug in place to allow locking.
Once the Unit 2 valve is locked, key control is expected to prevent future occurrences. Full compliance is expected by April 7, 1980.
DEVIATION:
L.
Section I iC.2.c of the EFPP states in part that a floor to ceiling fire barrier will be provided between each fire pump.
Contrary to the above, a fire barrier has been pro-vided between each pump but the fire pump conroller and battery charger for diesel engine fire pump No. 2 are located within the enclosrue for fire pump No. 3.
A fire involving pump No. 3 could place pump No. 2 out of service.
RESPONSE
A Design Change Request will be written to relo-cate the controller for Diesel Fire Pump No. 3 within the enclosure for that pump. Relocation of the battery charger will be evaluated based on requirements of the code in effect at the time of installation (NFPA 20).
The implementation of this design ~ change and com-pliance with the Georgia Power Company QA program is expected to prevent future occurrences.
Full compliance is expected by August, 1980.
Georgia Power d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Atlanta, Georgia 30303 March 3, 1980 Page Nine DEVIATION:
M.
Section IV.C.3.b of the EFPP states in part that all interior fire protection control valves to the sprink-1er systems for Unit 1 are designed to give a local alarm if moved to the wrong position and the control valves for the Unit 2 systems are designed to sound an alarm in the main control room if moved to the wrong position. Furthermore, all control valves for the Unit 1 systems will be maintained locked in the proper position by a key control procedure.
Contrary to the above, the following discrepancies were noted:
(1) The following Unit 1 sprinkler system control valves were found open but not locked in the open position as required:
(a) Cable Spreading Room (b) HVAC Area - 158 Foot Elevation (c) RPS Area (2) The followin'g Unit 2 sprinkler systea control valves were found open but are not designed to sound an alarm in the main control room if moved to the wrong position:
(a) Cable Spreading Room (b) Control Room Building - 130 Foot Corridor (c) RPS Area
RESPONSE
(1) Control valves to all Unit 1 sprinkler systems have now been locked in position and are included in a revision to the survellance procedure for position checks and lock verification on a monthly frequency.
Deviations from this procedure require Shift Foreman notification and subsequent action through a Main-tenance Request.
This action will eliminate future occurrences. Full compliance has been achieved.
(2) A Design change Request (DCR) will be issued to con-nect the installed tamper alarms to annunciator alarms in the Control Room.
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k Georgia Pbwer h U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Atlanta, Georgia 30303 March 3, 1980 Page Ten This modification and compliance with the Georgia Power Company QA program is expected to eliminate future occurrences. Full compliance is expected by August, 1980.
DEVIATION:
N.
Section IV.B.4.h of the EFPP states in part that the air compressor for refilling the self-contained breathing apparatus which are provided for use in the event of fire or other emergencies will be located within a special receptacle in the diesel generator building and will be arranged for manual connection to an active power supply in the event of loss of offsite power.
Contrary to the above, the air compressor has been installed within the water treatment building in which a power source is not readily available in the event of loss of offsite power.
RESPONSE
A Design Change Request (DCR) will be issued to provide a special receptical such that the com-pressor can be portably relocated in the event of a loss of off-site power.
This action will assure operation of the compressor under emergency condi-tions. Full compliance is expected by August, 1980.
Further, an unresolved item was cited (50-321/80-02-15 and 50-366/80-02-15) concerning an evaluation of the diesel driven fire pump installation.
In response to this unresolved item an evaluation is underway by Southern Company Services to determine the date of the code applicable at the time of installation.
It is the intent of the licensee to comply with the code in effect at the time of installation.
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e GeorgiaPbwerd U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Atlanta, Georgia 30303 March 3, 1980 Page Eleven If further clarification or information is required, please contact this office.
Yours very truly, ld A '
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W. A. Widner Vice President and General Manager Nuclear Generation WEB:BB/mj xc: Director of the Office of Inspection and Enforcement Director of the Division of Operating Reactors, Office of Nuclear Reactor Regulation
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