ML19305C566

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IE Insp Repts 50-321/80-02 & 50-366/80-02 on 800108-11. Noncompliance Noted:Inadequate Fire Protection QA Program, Subst Automatic Sprinkler Sys,Incorrect Type Fire Detectors in Control Room Kitchen & Inadequate Fire Barrier
ML19305C566
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 02/06/1980
From: Conlon T, Miller W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19305C561 List:
References
50-321-80-02, 50-321-80-2, 50-366-80-02, 50-366-80-2, NUDOCS 8003310091
Download: ML19305C566 (11)


See also: IR 05000321/1980002

Text

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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REGION 11

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101 MARIETT A ST., N.W., SUITE 3100

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ATLANTA, CEORCIA 30303

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Report Nos. 50-321/80-02 and 50-366/80-2

Licensee: Georgia Power Company

270 Peachtree Street

Atlanta, Georgia 30303

Facility Name: Hatch

Docket Nos. 50-321 and 50-366

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License Nos. DPR-57 and NPF-5

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Inspection at Hat

site near Ba ley, Ce gia

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Inspector:

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W. H. Mi'11er, Jr.

Ifate' Signed

Approved b

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T. E. Conlon, Section Chief, RC&ES Branch

Date Signed

SUMMARY

Inspection on January 8-11, 1980

Areas Inspected

This special, unannounced inspection involved 25 inspector-hours ensite in the

area of fire protection / prevention.

Results

Of the area inspected, no items of noncompliance or deviations were identified;

however,14 apparent deviations were found (Inadequate fire protection QA program;

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substandard automatic sprinkler systems; storage of combustibles in east cableway

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r I Unit 1; inadequate oil catchment facility for Unit 2 RHR pumps; signs to prohi-

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bit storage of combustible materials not provided at river water intake structure;

substandard fire doors been control room and adjacent areas; incorrect type fire

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detectors in control room kitchen; inadequate protection against sprinkler system

discharge for four safety-related cabinets - 130 foot elevation of coutrol building

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corridors; mobile fire fighting platform not provided for unit I northwest cable

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area; control valves in drain piping from reactor circulation M-G sets not locked

in closed position; inadequate fire barriers between fire pump Nos. 2 and 3; sub-

standard supervision of fire protection control valves; incorrect location of

air compressor for emergency breathing apparatus; and, substandard water supply

to sprinkler / standpipe system at river intake structure.

8003310 O C

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DETAILS

1.

Persons Contacted

Licensee Employees

  • M. Manry, Plant Manager
  • T. Green, Assistant Plant Manager
  • C.

R. Miles, Jr. . QA Field Supervisor

  • C. E. Belflower, QA Site Supervisor
  • D. A. McCusker, QC Supervisor
  • L. Summer, BOP Engineering Supervisor
  • B. E. Brown, Senior Regulatory Specialist
  • M. E. Seymour, B0P Engineer (Fire Protection)
  • J. D. Peregoy, QA Field Representative
  • C.

L. Moore, Fire Protection Specialist

  • C, M. Padgett, BOP (Co-Op)

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NRC Resident Inspector

  • R. F. Rogers
  • Attended exit interview

2.

Exit Interview

The inspection scope and findings were summarized on January 11, 1980, with

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those persons indicated in Paragraph 1 above.

3.

Licensee Action on Previous Inspection Findings

Not inspected.

4.

Unresolved Items

Unresolved items are matters about which more information is required to

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determine whether they are acceptable or may involve noncompliance or

deviations.

New unresolved items identified during this inspection are

discussed in Paragraph 7.

5.

Fire Protection / Prevention Modifications

This inspection evaluated the licensee's corrective action on the fire

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protection modification and improvement commitments made to the NRC. The

NRC Fire Protection Safety Evaluation Report (FPSER) for this facility

dated October 4, 1978 (Amendment 60 to Unit 1 Operating License No. DPR-57

and provisions of Unit 2 Operating License No. NPF-5 dated June 13, 1978)

and the licensce's document entitled Evaluation of the Hatch Nuclear Plant

Fire Protection Program dated October 1976 with Amendment Nos. I through 7

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(EFPP) were used in this evalaation. These documents describe the fire

protection modifications and improvements required and dates of implemen-

tation. The modifications and findings are as follows:

a.

Modifications:

FPSER Commitment

Number

Location / Item

Pa ra graph

Status

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Cable Spreading Room

IV.A

(1)

Preaction Sprinkler System

  • 0 pen

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East Cableway - Unit 1

IV.B

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(2)

Sprinkler Modifications

Closed

(Fire barrier)

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(3)

Fire barrier ("Kaowool") for redun-

Closed

dant Cables

(4)

Smoke detectors / ceiling level

Closed

(5)

Signs prohibiting combustible storage

  • Closed

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(6)

Loose hanging cable removed

Closed

(7)

Improve fire barrier - south portion

Closed

(8)

Administrative procedure for control of

  • Closed

Combustibles

East Cableway - Unit 2

IV.B

(9)

Smoke detectors

  • 0 pen

(10)

Signs prohibiting combustible storage

Closed

(11)

Administrative procedure for control

Closed

of combustibles

River Intake Structure

IV.C

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(12)

Oil curbs for klfR pumps

  • Closed

(13)

Sprinkler spray system

  • 0 pen

(14)

Fire hose stations

Closed

(15)

Fire barrier (Kaowool)/ overhead cables

Closed

(16)

Signs prohibiting combustible storage

  • 0 pen

Reactor Building - Unit 1 (l!PCI & RHR)

IV.E

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(17)~

Vater Spray System

      • 0 pen

Containment Area - Unit 2

IV.D

(18)

Oil curb / recirculation pumps

  • 0 pen

(19)

Sprinkler system /beneath pumps

  • 0 pen

(20)

Fire detection system /beneath pumps

  • 0 pen

(21)

Cable tray-cover with Kaowool

  • 0 pen

.

Control Room

IV.E

_(22)

Fire barriers between control room

  • 0 pen

and peripheral rooms (1 Hr)

(23)

Smoke detectors for peripheral rooms

  • 0 pen

(24)

Smoke detectors / control cabinets

  • Closed

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FpSER Commitment

Number

Location / Item

Paragraph

Status

(Continued)

RPS Vertical Cableway - Units 1 and 2

IV.E

(25)

Fire barriers / floor

Closed

(26)

Sprinkler spray system /130' & 112'

  • 0 pen

(27)

Smoke detection

Closed

Control Building - Units 1 and 2

(28)

Sprinkler system /130' corridors

  • 0 pen

(29)

Smoke detection /112' Area

Closed

(30)

Water spray protection for safety

  • 0 pen

related cabinets

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Northwest Cable Area - Unit 1

IV.E

(31)

Additional smoke detectors

closed

(32)

Mobile platform

  • 0 pen

(33)

Cable tray protection /Kaowool

closed

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Southwest Cable Area - Unit 1

IV.E

(34)

Additional smoke detectors

Closed

(35)

Mobile platform

Closed

(36)

Cable tray protection /Kaowool

Closed

Northwest & Southwest Cable Areas -

Unit 2

IV.E

(37)

Additional smoke detectors

  • 0 pen

(38)

Mobile platform

  • 0 pen

(39)

Cable tray protection /Kaowool

  • 0 pen

Reactor Building HVAC at 158' - Unit 1

IV.E

(40)

Sprinkler System

      • 0 pen

(41)

Smoke detaction system

      • Closed

Reactor Building HVAC Area at 164' -

IV.E

Unit 2

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(42)

Sprinkler system

  • 0 pen

(43)

Smoke detection

  • 0 pen

Reactor Recirculation M-G Sets - Unit 1

(44)

Oil curbs

Closed

(45)

Oil drain piping / valve locked closed

  • 0 pen

(46)

Fire proof structural steel in fire

Closed

walls

(47)

Sprinkler system revisions

Closed

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FPSER Commitment

Number

Meation/ Item

Paragraph

Status

(Continued)

Reactor Recirculation M-G Sets - Unit 2

(48)

Oil drain piping / valve locked closed

  • 0 pen

Fire Protection Fire Pump House

II.A

(49)

Fire barriers

  • 0 pen

(50)

Sprinkler system revisions

Closed

(51)

Monitoring for electric fire pump

Closed

General Plant Areas

(52)

Supervision of fire protection

II.A

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valves

(a) Unit 1/ locked

  • 0 pen

(b) Unit 2/ electrical super"ision

  • 0 pen

(51)

Monthly test of water flow alarm circuits.

Closed

(52)

Daily inspections of fire doors in high

Closed

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traffic areas

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(53)

Administrative control procedures

  • 0 pen

(54)

Smoke removal equipment

Closed

(55)

Breathing apparatus / refilling capability

  • 0 pen

NOTES:

  • Refer to Comments in paragraph 5.b.
    • Not inspected due to high radiation.
      • Both notes applicable,

b.

Findings

Additional information on the "open" items and on the " closed" items

in paragraph 5.a marked by an "*" are listed below. The below listed

numbers correspond to the numbered items in paragraph 5.a.

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(1)Section IV.C.3.c of EFPP states in part that the automatic sprinkler

systems conform to the requirements of National Fire Protection

Association Standard No. 13 - (NFPA-13), Sprinkler Systems. The

automatic sprinkler systems installed as part of the plant's fire

protection modifications do not fully meet the criteria of NFPA-13.

The following are examples of where the systems do not fully meet

the provisions of hTPA-13.

(a) The sprinkler piping for pre-action systems which contain

over 20 ' heads is not supervised 'as required by Section

5-3.5.2 of NFPA-13.

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(b) The sprinkler deflectors in many areas are located up to

twice the distance beneath ceiling / roof structures than that

permitted by Section 4-3 of hTPA-13.

(c) Serious obstruction to discharge of water spray from the

systems in some areas is provided by ventilation ducts,

electrical cable trays, conduit, piping and building struc-

tural supports.

This problem is most acute in the cable

spreading room.

Sections 4-4.13 and B-4-2.3 of NFPA-13

require that additional sprinkler protection be provided in

areas where obstructions are located.

(d) Closed type nozzles for water spray type sprinkler systems

located long distances beneath ceilings or roofs arg not

provided with heat collectors to assure prompt actuation in

the event of fire as required by Section 3-16.8 of hTPA-13.

(e)

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Test pipes (main drains) arranged to properly test the water

supply to each system are not provided as required by Section

2-9 of NFPA-13.

(f) The shut off vaives to the water flow alarms on wet pipe

systems are located on the discharge side of the retarding

chamber in lieu of the supply side as required by Section

3-17.4.3 of hTPA-13.

(g) Valves to the water flow alarm devices to the sprinkler

systems are not of the type which can be sealed or locked in

position as required by Section 3-17.4.5 of hTPA-13.

(h) The flange bolts on the flange fitting in the supply piping

to the sprinkler / standpipe system at the intake structure

are too short and do not meet the provisions of Section

3-13.1 of NFPA-13.

This situation may also exist on other

flange type fittings.

This item is a failure to meet a commitment to the NRC and is iden-

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tified as Deviation Item (50-321/80-02-02 and 50-366/80-02-02),

9ubstandard Automatic Sprinkler Systems.

(5)&

(8) To control the s_torage of combustible materials signs have been

posted _throughout the east cableway of Unit I which read

" CAUTION - Storage of Combustibles Prohibited". However, during

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this inspection, approximately 45 boxes of HEPA filters were

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stored -in this area.Section III.C.4. (b) of the EFPP states in

part that the storage of transient combustibles within this area

will be controlled by procedures and signs.

The storage of

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combustibles within this area is a failure to meet a commitment

to the NRC and is identified as Deviation Item (50-321/80-02-03),

Storage of Combustibles in East Cableway of Unit 1.

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(9) Installation is not complete but is not required until after the

1980 refueling.

(12) Oil curbs have been installed around the RHR pumps for Units 1

and 2.

However, the oil curbs for the Unit 2 RHR pumps are

nonfunctional since this area is approximately 25% full of an

oil-water solution. The failure to install and adequately maintain

this oil catchment area which was required by Section III.C.4 of

the EFPP is a failure to meet a commitment to the NRC and is

identified as Deviation Item (50-366/80-02-04), Inadequate Oil

Catchment Facility for Unit 2 RHR Pumps.

(13) Refer to above item (1). Also, the connection from the exterior

fire protection water distribution system to the sprinkler / stand-

pipe system within the river intake structure is not provided

with an independent outside control valve as required by Section

3-3.1 of NFPA-24, Outside Protection.

Section IV.C.2.a of the

EFPP states ir part that the exterior fire protection water

system is designed in accordance with NFPA-24. This discrepancy

is a failure to meet a commitment to the NRC and is identified as

Deviation Item (50-321/80-02-16 and 50-366/80-02-15), substandard

Water Supply to the Sprinkler / Standpipe System Within the River

Intake Structure.

(16)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. However,

the floor areas are not marked or signs are not provided to pro-

hibit the storage of combustibles within the intake structure.

This item is a failure to meet a commitment to the NRC and is

identified as Deviation Item (50-321/80-02-05 and 50-366/80-02-05),

Signs to Prohibit Storage of Combustible Materials Not Provided

at River Water Intake Structure.

(17) Refer to above item (1).

(18) -

(21) These modifications are scheduled to be completed during the 1980

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refuelluc.

(22) Fire doors with a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire rating (Class B) have been instal-

led in wall openings between the control rooms and the peripheral

rooms (toilet and kitchen and administration areas). However,

these fire doors have not been provided with a door closer as

required by Section 2-8.4 of NFPA-80, Fire Doors.Section IV.B.I.j

of the EFPP states in part that all openings in fire rated walls

will be provided with doors, hardware and frames which are listed

by Underwriter's Laboratories (UL). UL requires that fire doors

be installed in accordance with the criteria of NFPA-80 to retain

their UL listing. This item is a failure to meet a commitment to

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the NRC and is identified as Deviation Item (50-321/80-02-06 and

50-366/80-02-06), Substandard Fire Door Installations Between

Control Room and Adjacent Areas.

The fire / security doors between the control room and the turbine

building are not provided with positive type latching devices as

required by Section 2-8.2 of NFPA-80.

This item is another

example of Deviation Item (50-321/80-02-06 and 50-366/80-02-06),

Substandard Fire Door Installations Between Control Room and

Adjacent Areas.

(23) Rate of rise (heat) type fire detectors have been installed in

the kitchen adjacent to the control room in lieu of the smoke

detectors specified by Section III.C.I.1 of the EFPP. Thig item

is a failure to meet a commitment to the NRC and is identified as

Deviation Item (50-321/80-02-07 and 50-366/80-02-07), Incorrect

Type Fire Detectors for the Control Room Kitchen.

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(24) The licensee advised that an evaluation of the control cabinets

within the control room indicated that all cabinets which contained

safety related cables were provided with sufficient ventilation

openings which would permit smoke to escape and activate the area

fire detection system in the event of a fire within the cabinet.

This appears to meet the intent of the FPSER.

(26) Refer to above item (1).

(28) Refer to above item (1).

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(30) The sprinkler system for the 130' control building corridor is

installed directly over four safety related electrical cabinets.

Water spray protection or prevent. ion has not been provided for

these cabinets as stated by Section III.C.I.4.(g) of the EFPP.

Also, an evaluation apparently has not been made to determine if

the construction of the cabinet will provide adequate protection in

the event of actuation of the Sprinkler System. This is a failure

to meet a commitment to the NRC and is identified as Deviation Item

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(50-321/80-02-08 and 50-366/80-02-08), Inadequate Protection Against

Sprinkler System Discharge for Four Safety Related Cabinets - 130 Foot

Elevation of Control Building Corridor.

(32) Table 3 Item No. 39 (Response No. 25.a to NRC questions of June 13,

1977) of the EFPP states in part that a mobile platform for fire

fighting operations will be provided in both the northwest and

southwest cable areas for each unit. During this inspection a

mobile platform was not located in the Unit I northwest cable

area.

The platform assigned to the northwest cable area ws

actually located in the southwest cable area of Unit 1.

This

failure to meet a commitment to the NRC is identified as Deviation

Item (50-321/80-02-09), Mobile Fire Fighting Platform Not Provided

For Unit 1 Northwest Cable Area.

(40) Refer to above item (1).

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(42) &

(43) Refer to above item (9).

(45) &

(48) The drain piping from the Unit I and Unit 2 Reactor Recirculation

M-G set rooms terminate (discharge) to the floor at the 130 foot

elevation of the reactor building. Tabic 3 Item No. 43 (Response

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to NRC question 25.e(3) of June 13, 1977) states in part that the

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valves in this drain piping system will be locked closed. During

this inspection these valves were found closed but were not locked

in the closed position. This item is a failure to meet a commitment

to the NRC and is identified as Deviation Item (50-321/80-02-10 and

50-366/80-02-10), Control valves in Drain Piping from Reactor Recir-

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culation M-G Set Rooms Not Locked in Closed Position. These, valves

were, however, locked by the licensee prior to the completion of

the inspection.

(49)Section IV.C.2.c of the EFPP states in part that a floor to

ceiling fire barrier will be provided between each fire pump. A

fire barrier has been provided between each pump; however, the

fire pump controller and battery charger for diesel engine pump

No. 2 is located within the enclosure for fire pump No. 3.

A

fire involving pump No. 3 would possibly result in pump No. 2

becoming inoperative.

The present arrangement does not fully

meet the intent of the EFPP and is failure to meet the conunitment

to the NRC. This item is identified as Deviation Item (50-321/

80-02-11 and 50-366/80-02-11), Inadequate Fire Barrier Separate

Between Fire Pump Nos. 2 and 3.

(52)Section IV.C.3.b of the EFPP states in part that all interior

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fire protection control valves to the sprinkler systems for

Unit I are designed with electrical valve supervision which will

ring a local alarm when the valve moved to the wrong position.

Also, these valves will be locked in the correct position.

In

addition, the control valves for the unit 2 systems will be

electrically supervised and arranged to sound an alarm in the

control room if the control valves are moved to the wrong position.

The following Unit I sprinkler cystem control valves were provided

with local electrical valve supervision and were found open but not

locked open as required:

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(a) Cable spreading room

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(b) HVAC Area at 158' elevation

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(c) RPS Area

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The following Unit 2 sprinkler system control valves are provided

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with local electrical supervisor but. do not sound an alarm in the

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control room as required by the EFPP:

(a) Cable Spreading Room

(b) Corridor at 130' elevation

(c) RPS Area

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The above discrepancies are failures to meet a commitment to the

NRC and are identified as Deviation Item (50-321/80-02-12 and

50-366/80-02-12), Substandard Supervision of Fire Protection

Control Valves.

(53) - The licensee's audit of the fire protection administrative control

procedures, Southern Company Services - Fire Protection and Loss

Prevention Audit of Hatch Plant - August 15, 1979, recommended a

number of changes to the existing procedures. These recommendations

are currently .Seing reviewed and existing procedures reevaluated

by the licensee to determine the appropriate corrective action

required. The licensee advised that all required changes will be

completed prior to August 1,

1980. This item is identified as

Inspection Followup Item (50-321/80-02-13 and 50-366/80-02-13),

Licensee's Reevaluation and Revisions to Fire Protection Admin-

istrative Procedures, and will be reviewed during a subsequent

NRC inspection.

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(55) An air compressor has been provided to refill the self-contained

breathing apparatus which are provided for emergency use. Section

IV.B.4.h of the EFPP states in part that this air compressor will

be located within a special receptacle in the diesel generator

building and arranged for manual connection to an emergency power

supply in the event of loss of offsite power. However, the air

compressor has actually been installed within the water treatment

building in which a power source is apparently not available in

the event of loss of offsite power. This is a failure to meet a

commitment to the NRC and is identified as Deviation Item (50-321/

80-02-14 and 50-366/80-02-14), Incorrect Location of Air Compressor

for Emergency Breathing Apparatus.

6.

Fire Protection QA Program

Documentation is not provided or is not easily retrievable to demonstrate

that the fire protection modifications required by the FPSER and the EFPP

were accomplished under the management control of a Quality Assurance (QA)

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organization.Section IV.B.7 of the EFPP states in part that the ten QA

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criteria of Section C of Appendix A to NRC's Branch Technical Position

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APCSB.9.5-1 (BTP 9.5-1) will be applied commensurate with the controls

described in the operational QA Program and the QA Program for fire protec-

tion will be under the management control of the QA organization. Detail

functional test reports were provided for the fire detection systems, but

inspection procedures, test results, etc. , were not available for the other

modifications.

Also, the fire suppression systems were installed by a

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contractor and it appears that very limited inspections and controls were

provided by the licensee over these installations. The apparent lack of a

fire protection QA program in the following areas listed by BTP 9.5-1:

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(a) Design Control and Procurement Control

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(b) Instructions, Procedures and Drawings

(c) Control of Purchase Materials Equipment and Services

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(d) Inspection

(e) Test and Test control

(f) Inspection, Test and Operating Status

(g) Non-Conforming Items

(h) Corrective Action

(i) Records

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(j) Audits

is a failure to meet a commitment to the NRC and is identified as Deviation

Item (50-321/80-02-01 and 50-366/80-02-01), Inadequate Fire Protection QA

Program.

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Fire Pumps (Diesel Pumps)

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The two diesel driven fire pumps are electrically started with starting

current taken from two banks of storage batteries which are shared by each

engine.Section IV.C.2.c of the EFPP states that the fire pump installation

is consistent with hTPA-20, Centrifugal Fire Pumps. Section 8-2.6.1 of the

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current edition of NFPA-20 states that each fire pump engine shall be

provided with two storage battery units. This section also states that

this provision is not applicable to installations made prior to adoption of

NFPA-20. The licensee is to evaluate the fire pump installation and deter-

mine if the installation should meet the applicable provisions of the

current edition of NFPA-20. This item is identified as Unresolved Item

(50-321/80-02-15 and 50-366/80-02-15), Substandard Diesel Driven Fire Pump

Installation, and will be reviewed during a subsequent NRC inspection.

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