ML19323H891
| ML19323H891 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/06/1980 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19323H880 | List: |
| References | |
| REF-SSINS-6530 NUDOCS 8006170211 | |
| Download: ML19323H891 (4) | |
Text
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TENNESSEE VALLEY AUTHORITY p j CH ATTANOOGA. TENNESSEE 374ot x
400 Chestnut Street Tower II May 6, 1980 Mr. James P. O'Reilly, Director Of fice of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region II - Suite 3100 101 Marietta Street
~1 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
SEQUOYAll NUCLEAR PLANT UNITS 1 AND 2 - NRC REGION II LETTER
[q RII:WHM 50-327/80-10 AND 50-328/80 INSPECTION REPORT -
RESPONSE TO DEFICIENCIES The subject letter dated April 14, 1980, cited TVA with two deviations in accordance with 10 CFR 2.201.
Enclosed are our responses to these deviations.
If you have any questions concerning this matter, please get in touch with D. L. Lambert at FTS 854-2581.
Very truly yours, TENNESSEE VALLEY AUTHORITY
\\$.
. M. Mills, Ma ager Nuclear Regulation and Safety Enclosure cc:
Mr. Victor Stello, Jr., Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 l
I gh An Equal Opportunity Employer OeY1CIAL COPY.
- 1 ENCLOSURE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 RESPONSE TO DEFICIENCIES 50-327/80-10 AND 50-328/80-06 Deficiency 50-327/80-10-01 and 50-328/80-06-01 A.
TVA's response to NRC question No. 2 on the Fire Protection Program Reevaluation states that the administrative procedures, controls, and fire brigade programs at Sequoyah would be revised to meet the NRC fire protection guidelines contained in " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance" dated June 14, 1977.
Contrary to the above, the fire protection administrative procedures do not meet the NRC guidelines in the following areas:
1.
Fire fighting procedures are not provided for all safety-related areas as required by Paragraph a of Attachment No. 5 of the NRC fire protec-tion guidelines.
2.
Fire brigade classroom instructions and lectures are not conducted for the brigade members each quarter as required by Paragraph 1.0.d of of the NRC fire protection guidelines.
3.
The procedures do ac: reqwira a leas: ::a fire brigade drill per year per shift to be conducted on the back shift as required by Paragraph 3.0.e of Attachment 2 of the NRC fire protection guidelines.
4.
The procedures do not require all wood used within safety-related areas of the plant to be of the pressure fire retardant treated type as required by Paragraph ; cf 1.tt hm :t 2 Of the NRC fire protection guidelines.
Corrective Action Taken and Results Achieved 1.
Physical Security Instruction No. 13, Fire, is a detailed instruction which addresses fire fighting procedures in depth.
It addresses actions necessary for response to fire emergencies throughout the facility in a manner that we believe is adequate for most locations and contingencies.
For those areas which we have identified as presenting unusual hazards to safety-related equipment, because of combustible loading or susceptibility to fire damage, specific detailed instructions and procedures have been prepared. These instructions are included as supplements to Physical Security Instruction No. 13.
At present there are 18 of these prefire I
plans ~ active, cuvering such areas.us the cable opteading room, auxiliary instrument rooms, control building emergency air cleanup system, reactor coolant pumps, AERCW cooling towers, diesel generator building, CCW intake pumping acation, containment putse air and exhaust filter system, etc.
We believe that our procedures adequately identify the strategies for fighting fires in all safety-related areas and areas presenting a hazard to safety-related equipment.
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'2.
At'present, the core of our fire brigade consists of operations section e=ployees. We have determined that the combination of annual fire brigade member refresher training classes and fire protection related portions of the established operator training program provide classroom instruction and lectures on a quarterly basis such as to repeat the established classroom instruction for these fire brigade members over a two-year period. The existing fire brigade organization, however, also includes one member from the Health Physics section and Results-Rad Chem Lab.
The latter two members of the fire brigade do not receive the instruction accomplished by the operator training programs.
We will restructure our plant fire brigade to consist solely of operations section employees and delete the representatives from Health Physics and the Rad Chem Lab as members, b*e will further review the established train-ing programs for the fire brigade members, based upon its reorganization, to ensure that each member receives classroom instruction and lectures on at least a quarterly basis to repeat the required training every two years.
3.
We have, for at least the last 13 =cnths, been holding at least one fire drill per year on a back shif t for each shift.
Our procedures do not, however, state this to be a requirement.
We will revise our Physical Security Instruction No. 13 to include this requirement.
4.
Paragraph e of Attachment 3 of the NRC fire protection guidelines states that all wood used in safety-related areas is to be treated with flame retardant.
It does not specify thzt this fire retardant treatment be of the pressure-treated typ.e as stated in the notice of aeviation.
Our existing procedures require that all wood introduced into safety-related areas must be coated with a fire-retardant paint as listed in U.S. 's Building Materials Directory. Cur contention is that this fire-retardant paint coating is, in fact, a fire retardant treatment and complies fully with the referenced requirement.
This positi n is substantiated by performance data available on the two types of fire-retardent paint which we use compared to U.L. listed pressure-treated wood.
The two types of paint we use have ratings of 25-15-5 and 10-10-0 respectively for flame spread, fuel contribution, and smoke developed for a single coat application to a Douglas fir surface. The preponderance of cor-responding ratings for pressure-treated wood is 25-25-25 or higher numerically.
The treating procedure we now use, therefore, meets the requirements of paragraph e of Attachment 3 and will meet or exceed the performance of pressure-treated need.
Date of Full Compliance 1.
We are now in full compliance.
2.
Full compliance will achieved by June 1, 1980.
3.
Full compliance will be achiered by Mc-; 15, 1980.
4.
We are now 0 full compliance.
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Deviation 50-327/80-10-02 and 50-328/80-06-02 3.
Section A.3(b) of TVA's Fire Protection Program Reevaluation states that all valves in the fire protection system will be mechanically locked in their normal position.
Contrary to the above, none of the interior fire protection control valves were mechanically locked in their normal position.
Corrective Action Taken and Results Achieved All exterior lockable valves in the high-pressure fire protection system flow path between the fire pumps and various sprinkler / water spray system isolation valves are presently locked in their proper position.
All interior sectionalizing valves are also being locked in their proper position. The various isolation valves to the individual sprinkler and water spray systems are not all locked.
ke are opposed to locking the individual sprinkler and water spray system isolation valves in the open positi: s.
We are in total agreement that it is essential to maintain these valves in their proper position; however, we also recognize the necessity of prompt isolation in the event of inadvertent system actuation or meenanical a mage to minimize water damage.
We, therefore, propose the followitg actions to resolve this deviation:
1.
We will lock all lockable valves between the water supply (fire pump discharge) and the individual sprinkler or water spray system isolation valves. This is to include all yard isolation and section-ization valves and all isolation valves to water spray systems which are located in the yard areas (including valves in valve pits).
We will continue to verify that these valves are in their proper lineup and locked by means of our existing surveillance instruction (on a monthly basis).
2.
We will seal all interior sprinkler and water spray system isolation valves in the open position.
We will either revise our existing surveillance instruction on valve lineup inspections, or prepare a new instruction, to require that these sealed valves be inspected for proper lineup and seal integrity on a weekly basis.
i 3.
At present, we will neither lock nor seal the containment isolation A valves for the systems protecting the unit 1 reactor building.
- Disposition of these valves will require a determination of action on unresolved item 50-327/80-10-07.
This proposal is not identical to our original commitment: however, it is totally consistent with NFPA 26-1976, " Recommended Practices for the
'. Supervision of Valves Controlling Water Supplies for Fire Protection."
Date of Full Compliance Full compliance will be achieved by June 1, 1980.
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