ML19323B742

Responds to NRC 800312 Ltr Re Violations Noted in IE Insp Repts 50-338/80-03 & 50-339/80-03.Corrective Actions:Record Keeping Improved to Ensure That Fire Brigade Members Attend Required Drills

ML19323B742
Person / Time
Site:	North Anna
Issue date:	04/08/1980
From:	Sylvia B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19323B737	List: ML19323B742
References
NUDOCS 8005140177
Download: ML19323B742 (8)

Text

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g 7,pq ;; April 8, 1980 pp ., 3 g Mr. James P. O'Reilly, Director Serial No. 240 Office of Inspection and Enforcement P0/RMT:baw U. S.. Nuclear Regulatory Commission Docket Nos. 50-338 Region II 50-339 101 Marietta Street, Suite 3100 License No. NPF-4 Atlanta, Georgia 30303 Permit No. CPPR-78

Dear Mr. O'Reilly:

We have reviewed your letter of March 12, 1980 in reference to the inspection conducted at North Anna Power Station on February 12-15, 1980, and reported in IE Inspection Report Nos. 50-338/80-03 and 50-339/80-03.

Our responses to the specific infractions are attached.

We have determined that no proprietary information is contained in the reports. Accordingly, the Virginia Electric and Power Company has no objection to these inspection reports being made a matter of public disclosure.

Very truly yours, j

B. R. Sflyia Manager-Nuclear Operations Attache:nts ~

cc: Mr. Albert Schwencer

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Attachment 1: '

Page 1 of 3

, Response to Notice of Violation Items Reported in IE Inspection Report 50-338/80-03 and 50-339/80-03 NRC Comment:

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i A. As required by Section 6.4.2 of the Technical Specifications, fire brigade training sessions and drills shall be held at least once per 92 days.

Contrary to the above, the last recorded fire brigade drill is September 24, 1979, which exceeds the maximum time of 115 days permitted between ,

drills by the Technical Specifications (92 days plus 25% extension l allowed by Section 4.0.2.a. of the Technical Specifications.) l This is an infraction. I

Response

The above infraction is correct as stated. Specifically, pursuant to l Section 2.201 of the NRC's " Rules of Practice" Part 2, title 10, Code of '

Federal Regulations, the following information is submitted:

1. Corrective steps taken and results achieved:

The Fire Protection Program of 12-21-79; Section 7.2.3 and 7.2.4 specifies the frequency and controls utilized to ensure that drills are conducted routinely. The lack of drills since September 1979

, was the result of personnel error and those persons have been in-

! structed in the importance of attention to detail in conducting Fire Brigade Training.

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The Fire Marshal has conducted drills during the first quarter of 1980 and has improved the record-keeping to ensure that brigade members attend the required drills.

2. Corrective steps which will be taken to avoid further non-compliance:

We believe that the above listed corrective action will be sufficient.

3. Date when full compliance will be achieved:

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( Full compliance was achieved on.3/11/80.

NRC Comment D. As required by Section 4.7.14.3 of the Technical Specifications, the cy-linders for the carbcu dioxide fire protection system for the , fuel oil pump hpqpe are required to be demonstrated operable at least once15er 6 months by verifying the carbon dioxide tank (cylinder) weight.

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Contrary to the above, the carbon dioxide. cylinders for the fuel oil pump house were weight checked on November 22, 1978, with the next weight check conducted on August 10, 1979. 'The time between the weight tests was 8 months and 18 days which exceeded the maximum time l

of 7.5 months permitted by the Technical, Specification (6 months plus

[ 25% extension allowed by Section 4.0.2.a. of the Technical Specifications.)

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Attechm:nt 1:

Page 2 of 3 This is an infraction.

Response

b The above infraction is correct as stated. Specifically, pursuant to Section 2.201 of the NRC's " Rules of Practice" Part 2, title 10, Code of Federal Regulations, the following information is submitted:

1. Corrective steps taken and results achieved:

The maximum time was exceeded as the result of personnel error.

The personnel involved have been made aware of the importance of attention to detail in the performance of scheduled tests.

2. ,

Corrective steps which will be taken to avoid further non-compliance:

We believe that the above listed corrective action will be sufficient.

3. Date when full compliance will be achieved:

Full compliance was achieved on 8/10/79.

NRC Comment C. As required by Section 4.7.14.5 of the Technical Specifications, the fire hose stations within safety related areas shall be demonstrated operable at least once per 31 days by visual inspection of the station to assure that all required equipment is at the station.

Contrary to the above, the hose stations within the safety related areas were not inspected within the allowable time on two inspection

' periods between September 7, 1978 and January 31, 1980. A total of

'. 47 days existed between the September 7, 1978 and the October 24, 1978 inspections and 42 days existed between the March 8, 1979 and the April 19, 1979 inspections which exceeded the maximum time of 38.75 days permitted by the Technical Specifications (31 days plus 25% extension allowed by Sectica 4.0.2.a. of the Technical Speci-

-fications.) -

r This is an infraction.

Response

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The above infraction is correct as stated. Specifically, pursuant to Section 2.201 of the NRC's " Rules of Practice" Part 2, title 10, Code of Federal Regulations, the following information is submitted:

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1. Corrective steps taken and results schieved: -

The maximum time was exceeded as the" result of personnel error.

The personnel involved have been made aware of the importance -

, of attention to detail in the performance of scheduled tests.

[ 2. Corrective steps which will be taken to avoid further non-compliance:

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We believe that the above listed corrective action will be sufficient.

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t l} 3. Date when full compliance will'be achieved: - i

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• Full compliance was achieved on 4/19/79. '

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Attachment 2: (

Pega 1 of 4

[, , Response to Notice of Deviation Items Reported in IE Inspection Report 50-338/80-03 and 50-339/80-03 1

NRC Comment i A. " Response to Question 31 in Supplement 3 to the licensee's " Fire Protect-ion Systems Review for North Anna Power Station - Units 1 and 2" dated ,

October 1,1978, states in part that the fire protection administrative  !

procedure at North Anna comply with the Commission's supplementary l guidance contained in NRC's document entitled " Nuclear Plant Fire Pro- '

tection Functional Responsib.ilities, Administrative Controls and Quality Assu rance". -

l Contrary to the above, the administrative fire protection procedures as promulgated in the licensee's document " North Anna Power Station - Fire t

Protection Program" (FPP) dated December 21, 1979 do not fully. comply with the NRC guidelines in the following areas:  ;

1. The FPP does not require fire brigade members to pass a physical examination for performing strenuous activities and does not list the qualifications for brigade members as required by Section 2.b of Attachment 1 to the NRC's fire protection guidelines.

2. The FPP does not designate the areas within the plant in which smoking is prohibited and does not restrict smoking in safety related areas

'; to designated areas as required by Section 4 of Attachment 4 to NRC's fire protection guidelines.

3. The FPP does not require the rebponsible foreman or supervisor to physically survey the area in which welding, open flame or grinding operations are to be conducted prior to these operations to assure that adequate safety procedures will be followed as required by Section 2 of Attachment 4 to NRC's fire protection guidelines.

4. The FPP does not require all brigade members to participate in

, at least one practice se'ssion per year involving an actual fire extinguishment activity and in the use of emergency breathing

, apparatus under strenuous conditions as required by Section 2 j of Attachment 2 to NRC's fire protection guidelines.

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5. The FPP does not require that the brigade for each shift be drilled ,

during a back shift at least once per year and at least one drill for each brigade to be unannounced each year as required by Section 3.f of Attachment 2 to NRC's fire protection guidelines.

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6. The FPP does not require that fire brigade drills at three-year intervals be critiqued by qualified individuals independent of the

• utility's staff, as required by Section 3.f of Attachment 3 ~

to NRC's fire protection guidelines. -

7. The FPP does not require records of training provided to each brigade member, including site classroom training, dril,Is and practice sess-ions to be recorded in each brigade member's training record as required by Section 4 of Attachment 2 to NRC's fire protection guide-6~

lines. This data is needed to assure that each member receives train-ing in all parts of the brigade training program.

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Attcchment 2: '

Pega 2 of 4 s 8. The FPP does not ide tify the Icaders of the fire brigade (" scene Icaders") and the organizational structure of the brigade does not provide sufficient guidance to assure that a brigade leader will be on duty at the site at all times as stipulated ' yoSection 1.f of

Attachment I to the NRC's fire protection guidelines.

.c Response The above deviation is correct as stated. Specifically, pursuant to Section 2.201 of the NRC's " Rules of Practice" Part 2, title 10, Code of Federal Regulations, the following information is submitted".

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~1. Corrective steps taken and results achieved:

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A.1 * ' S6ction* 7.1.3 of the FPP dated 12-71-79 does state ths quali '-- *

• fications required in 2.b of Attachment I to NRC's fire protec-tion guidelines. The FPP will be revised to include the require-ments for a physical exam appropriate for persons engaged in strenuous activities. The tentative date for this revision is July 1, 19 80. The physical examinations will be completed by October 1, 1980.

A.2 A list of designated "No smoking areas" will be added to the FPP. This revision will be completed by July 1, 1980. In-cluded in this list will be safety related areas except where smoking is allowed.

A.3 The FPP in Section 4.6.3 presently requires that the person in l I charge of the work to conduct a thorough inspection of the work l area to ensure that it is firesafe. This will be revised )

July 1,1980 to require that a foreman or supervisor makes -

this inspection.

A.4 The FPP, Section 7.1.3 does presently recommend that fire brigade members participate in at least one drill involving actual fire and requiring use of SCBA. This will be revised prior to July 1,1980 to require all members to participate in this type cf a drill.

l A.5 The FPP Section 7.2.3 will be further clarified. It does

f. contain provisions for these unannounced and back-shift 9 drills, but does not specify that this is to be applied to each shift brigade, although, that is the intent and the interpretation understood by the fire protection staff.

This revision will be made prior to July 1,1980.

.A.) The FPP will be revised to include the requirement fo r.Ja.

-r drill evaluation by an independent group on a 3 yeaf -inre terval. This revision will be complete prior to July 1,1980.

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A.7 The FPP will be revised to include the pequirenent that all training be recorded in each individual's training record.

This revision will be completed by July 1,1980.

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. Attechment 2: s Page 3 cf 4 '

A.8 The identificatioh of scene leaders will not be included in the FPP. This identification will be made via the operations shift assignment sheet. Implementation will be prior to April 1, 1980.

2. Corrective steps which will be taken to avoid further non-compliances: ,

We believe that the bove listed corrective actions will be sufficient.

3. Date when full compliance will be achieved:

See~ dates referenced-in the above responses.

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NRC Comment B. Section IV.B.S.c of the Fire Protection Systems Review for North Anna Power Station - Units 1 and 2 (FPSR) dated April 1, 1977 states in part that "only flame-retardent wood is allowed in safety related areas of the plant.

Contrary to the above, portions of the scaffolding .in the cable tunnel and vault and emergency switchgear rooms consisted of combustible wood

. planking.

Response

The above deviation is correct ar, stated. Specifically, pursuant to Section 2.201 of the NRC's " Rules ci Practice" Part 2, Title 10, Code ^ of -

Federal Regulations, the followinF infonmation is submitted:

1. Corrective steps taken an! results achieved:

We do have a program to exclude wood from safety related arean unless it is flame retardent. This treated wood is not non-combustible, but does have a flame spread rating of <25. It is

-felt that the wood presently being used is flame-retardent.

We are presently conducting a study to find ways to improve this i.

program. ;The study results will be reflected in the FPP.

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2. Corrective steps which will be taken to avoid further'non-compliances:

We believe that the above listed corrective action will be sufficient.

3. Date-when full compliance will be achieved: ' ---

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The results of this study will be reflected in the FPP prior to July 1,1980.l ~'

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Attachment 2:

, Page 4 of 4 NRC Comment i

C.Section IV.E.3.b of the FPSR states in part that all valves in the fire

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protection system which are not electrically supervised are placed in the correct position, sealed with tamper-proof seals and inspected weekly.

Contrary to the above, many control valves in the fire protection system

,are inspected monthly in lieu of weekly. ,

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• Ihe above deviation is correct as stated. Specifically, pursuant to

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Section 2.201 of the NRC's " Rules of Practice" Part 2, title 10, Code of Federal Regulation, the following information is submitted:

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1. Corrective steps taken and results achieved:

1-PT-100.3 and 1-PT-103.1 have been revised to verify valve positions on a weekly basis.

2. Corrective steps which will be taken to avoid further non-compliances:

. We believe that the above listed corrective action will be sufficient.

k'~-4 3. Date when full compliance will be achieved: I

- The revised pts will be implemented prior to April 15, 1980.

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