ML19345B589
| ML19345B589 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 10/24/1980 |
| From: | Parker W DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19345B585 | List: |
| References | |
| NUDOCS 8012020127 | |
| Download: ML19345B589 (8) | |
Text
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DUKE POWER COMPANY Powrar Buswaxo i
422 Socin Cucacu Stazzr, CnAus.ortz, N. C. asa4a a pr 3 F 2: 21 wau = o. emanca,sm.
October 24, 1980 WCE Pats *0 tut Tattrao%c. Ant A 704 55ta= Paoowetion 373 4083 Mr. Jame.s P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Subj ect: McGuire Nuclear Station Docket No. 50-369, -3.0
Reference:
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50-369/80-25, 50-370/80-15
Dear Mr. O'Reilly:
In response to Mr. C. E. Murphy's letter of September 30, 1980, please find attached our response to the items of noncompliance and the notice of deviation identified in the subject inspection report.
Duk' Power Company does not consider any information contained in IE Inspec-tio.: teport No. 50-369/80-25, -370/80-15 to be proprietary.
Very truly yours, M'-
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William O. Parker, Jr.
IJB:ses Attachment 1
8012020 \\ L 0FFICIAL COPY
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I McGuire Nuclear Station Response to IE Inspection Report 50-369/80-25, -270/80-15 Violation A.
As required by Criterion V of Appendix B to 10CFR 50, and implemented by Topical Report, Duke 1A, Paragraph 17.1.5, the activities affecting quality
'shall be accomplished as required by procedures.
For fire protection during cutting and welding operations, Duke Power Company construction procedure Nos. 54, Fire Protection During Cutting and Welding Operations and 803, Protection of Machinery, Equipment, Pip'gg, etc.
Against Damage Resulting from Welding or Cutting Operations, require the following:
floors to be swept clean of combustible materials within a radius of 15 feet from the operation; all machinery, equipment, materials or other items subject to damage of possible ignition by sparks from operations to be moved or covered with flame proof shields or covers; floor openings beneath cutting and welding operations to be covered to prevent passage of sparks to lower areas; portable fire extinguishers to be provided; fire watchers to be assigned for (all) cutting and welding operations; and, fire watchers to be trained in use of fire extinguisher and facilities for sounding an alarm in the event of fire.
Contrary to the above, numerous violations to the welding and cutting procedures were noted.
Some typical examples are as follows:
1.
Welding operations were being conducted in Cable Spreading Room of Unit I directly over combustible trash on the floor.
2.
Cutting operations were being conducted in Room 807 directly over temporary cable and hose of combustible construction.
3.
Cutting operations were being conducted at the top of the lower contain-ment without covering cable trays beneath the operation.
4.
Cutting operations were being conducted in the duct shaf t next to the cable spreading room without floor opening being covered.
5.
Fire extinguishers were not provided in the vicinity of most welding operations.
6.
Fire watchers were not provided for most welding operations.
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7.
All fire watchers were apparently nor trained in the use of portable fire extinguishers and in the facilities available for sounding an alarm in the event of fire.
This is an infraction. A similar item was brought-to your attention in our letter dated March 8, 1979.
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. Response a
A.
Construction Procedure 54 shall be revised by October 24, 1980 to better clarify the fire protection requirements during cutting and welding operations.
The revision to Construction Procedure 54, " Fire Protection During Cutting and Welding Operations," makes it clear that in the areas where cutting and welding are permitted a craft foreman shall be responsible for determining if an area has been adequately protected and will assign a fire watch when required by Construction Procedure 54.
All craft supervisors involved with cutting and welding will be formally trained on the revised procedure by October 28, 1980. All craft personnel involved in cutting and welding operations will be formally trained on the revision by November 15, 1980.
All supervisors responsible for cutting and welding operations have been instructed to assure that the requirements of Construction Procedure 54 are complied with as soon as the revised procedure is issued to them.
By November 15, 1980, formal training for all craft personnel involved with cutting and welding operations will be conducted on the following:
1.
Construction Procedure 501, " Fire Watch Extinguisher Control,"
2.
Construction Procedure 802, " Protection of Machinery, Equipment, Piping, etc., Against Damage Resulting From Welding or Cutting Operations,"
3.
Steam Production Procedure " Cutting and Welding Safety Procedure," and 4.
Use of portable fire extinguishers, it is felt that the clarification of Construction Procedure 54, and the extensive training on all cutting and welding procedures will resolve all concerns identified in the noncompliance item relating to cutting and welding operations.
Note that after fuel loading on McGuire Unit 1 all cutting and welding operations in Unit I will be conducted according to Steam Production Procedure " Cutting and Welding Safety Procedures." This procedure shall be revised by November 5, 1980 to address open flame ignition sources and fire watch requirements and to require approval by a responsible member of plant management of issuance of a welding permit where a fire watch is not required.
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Violation i
B.
As required by Criterion V of Appendix B to 10CFR 50 and implemented by Topical Report, Duke IA, Paragraph 17.1.5, the activities affecting quality shall include appropriate acceptance criteria.
Contrary to the above, the acceptance criteria for the fire dampers installed in the nucicar safety related control room ventilation system does not conform to the fire damper manufacturer's installation requirements.
This is an infraction.
Response
B.
Installation of fire dampers in Control Room Ventilation System is being upgraded to include minimum one-inch welds on maximum five-inch centers
-as required by American Warming and Ventilation, Inc.
Welds vill be pro-vided on both sides of damper frame to sleeve.
The QC inspection program has been upgraded to include a complete review of fire dampers in the Auxiliary Building and Fuel Building.
Access doors or removable registers will be provided to allow visual inspection of the dampers.
In some cases duct removal will be required for complete damper service. This meets the intent of Section 2-1.4 of NFPA-90A.
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McGuire Nuclear Station Response to IE Inspection-Report 50-369/80-25, -370/80-15 l
-Deviation A.
Section A.4 of the McGuire Nuclear Station Fire Protection Review (FPR) dated September 1977 and Revised January 1979 states that a single failure in the fire suppression system will not impair both the primary and backup fire suppression capability.
Contrary to the above, a failure in the single pipe supply to the fire suppression systems in the Reactor Building will impair both the primary and backup fire protection system.
It is possible that this deficiency may exist in other areas of the plant.
B.
Section D.I.j and D.4.f c2 the FPR states that the walls separating fire areas and enclosing duct shafts have a minimum fire rating of three hours.
Contrary to the above, the walls enclosing the duct shafts next to the cable spreading rooms are not of three hour fire rated construction.
It is probable that this deficiency exist in other areas of the plant.
C.
D.2. (a)(1) of the FPR states that the day tanks for the diesel generator fuel tanks are located within three hour barriers.
Section D.2. (d) of the FPR states that the storage of flammable liquids will as a minimum comply with NFPA-30, Flammable and Combustible Liquid Code.
Contrary to the above, the fuel day tanks for the diesel generators are located in the same room as the diesel generator and are not located within three hour barriers, and the tanks are not vented to the exterior of the building as required by NFPA-30 Saction 2-4.2.
Response
A.
A failure in the single pipe supply to the fire suppression systems in the Reactor Building would impair both the primary and backup fire suppression capability.
This condition was reviewed by the NRC Staff and found to be acceptable.
The following is a chronology of events leading to this agreement.
1.
Question number 27 in Robert L. Baer's letter of June 14, 1978 stated for Fire Areas RB-1, 2, 3 (Reactor Building and Containment) " Verify that the control valve to the sprinklers and hose stations inside containment is opened when the ionization detector in the Reactor Building goes into the alarm condition.
Provide drawings showing the arrangement of fire protection piping and valves from elevation 744 of the containment to the connection inside the auxiliary building."
2.
W. O. Parker's letter of August 1, 1978, responded stating "The control valve to the sprinklers and hose stations inside containment is manually operated. Drawings for piping and valve arrangement for A xiliary Building / Reactor Building r.re attached (MC-1418-06.20-00, MC-1418-06.21-00, MC-1418-06.20-01, and MC-1418-06.-42-02)."
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-3.
Robert L. Baer's letter of September 6, 1978 asked for additional information. The staff stated'"It is our position that the control valve for the reactor cooling pump sprinkler system should be automatic or remote manual operated.from the control room. Also state the criteria and procedure to be followed by an operator to open the control valve to supply water to the sprinklers and hose stations inside containment."
4.
A meeting was held with NRC staff on September 27 and 28, 1978 to review the outstanding items related to fire protection at McGuire.
It was agrecd in this meeting that a remote manual operated control valve would be provided to the sprinklers and hose stations inside containment.
Ralph A.-Birkel, NRC/0NRR, issued a summary of this meeting on October 3, 1978 which stated " applicant will provide remote manual operated sprinkler system valve."
Other areas where this exists will be upgraded by fuel loading.
B.
Walls enclosing duct shafts identified on attached drawings MFP-3, 4 and 5 were not constructed using three layers of gypsum on each side of the wall. Attachment "A" is a typical duct shaft section showing the construc-tion of the walls.
The rationale for not providing gypsum inside the duct shaft is as follows:
The duct shaft walls need only prevent fire from entering the duct shaft from one fire area and exiting the duct shaft into another fire area.
For a fire to follow this path would require burning through six layers of a gypsum as was tested.
(See test report dated December 12, 1978.)
C.
The fuel oil day tank is located in the same room as the diesel as indicated in Section D.2. (a)(1) of the Fire Protection Review. The two redundant diesel generators are scparated by a three hour wall such that each diesel o
is contained in a sepsrate three hour rated enclosure. The fuel oil day tank capacity is 275 gallons.
Any fire resulting from this fuel oil would be contained and shutdown accomplished using the redundant diesel generator or the Standby Shutdown Facility.
Section D.2. (d) of the Fire Protection Review concerns permanent and transient storage of combustible materials and is not intended to include oil quantities associated with fixed equipment.
Also reference page C-20 of the Fire Protection Review which states that "No modifications will be made to the day tank since a fire would be con-fined to a single area and the redundant diesel would be available for shutdown.
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Supplemental Information On Previous Inspection Findings Deviation Item 369/80-11-01 and 370/80-07-01 The one-half inch piping in the annulus sprinkler syster
- l be upgraded to one-inch piping by November 10, 1980.
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McGuire Nuclear Station Additional Information on Open Item 81 The manually operated valves for the charcoal filter water spray systems will be relocated by end of first refueling outage. This relocation will allow enhanced accessibility in the event of a fire in one of the units.
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