ML20012A815
| ML20012A815 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 02/21/1990 |
| From: | Clay Johnson, Murphy M, Singh A, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20012A812 | List: |
| References | |
| 50-458-90-02, 50-458-90-2, NUDOCS 9003120617 | |
| Download: ML20012A815 (12) | |
See also: IR 05000458/1990002
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APPENDIX'
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4 U.S.-NUCLEAR REGULATORY COMMISSION
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REGION IV
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NRC Inspection Report:1 50-458/90-02
-_ Operating License: .NPF-47
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m Docket:: : 50-458
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L Liciensee: ;GulfStatesUtilities(GSU)
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P.O.~ Box 220-
St. Francisv111e, Louisiana 70775
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Facility.Name:' River Bend Station (RBS)
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-Inspection At: 'St. Francisville, Louisiana
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'Inspectioniconducted: : January 22-26, 1990
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IEspectors: .
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C. E. Johnson,'RedCTor Inspector, Plant .
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~ Systems Section, Division of Reactor Safety
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.A. Singh,llenctor Inspector. Test Programs
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Section, Division of Reactor. Safety
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M. E. Murphy, Reactdr ppsctor, Test Programs
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>Section, Division of, Reactor. Safety
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, Accompanying. Mr. D. P. Notley, Fire Protection Engineer
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Personnel:~ OfficeofNuclearReactorRegulation(NRR)
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, l Approved::
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'T. F. St%tka, Chief. Plant Systems Section
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Division of Reactor Safety
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9003120617 900226
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ADOCK 05000458
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Inspection Summary
Inspection Conducted January- 22-26, 1990 (Report 50-458/90-02)
Areas' Inspected: Special, announced postfire safe shutdown capability
reverification and assessment of the fire protection program's compliance-
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with the requirements of Appendix R to 10 CFR Part 50.
Results: The inspection verified that the licensee has properly' maintained the
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jbstfire safe shutdown capability that was confirmed in the initial validation
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inspection conducted during April 1-4, 1985.
Items requiring licensee action
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initial concerns resolved. The inspection also reverified that-the licensee
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has, continued to carry out an' overall effective- fire protection program.
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There appears to be.a weakness in the area of implementation of the procedures
and administrative controls that are reouired by the Fire Hazards Analysis.
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This-resulted in two potential violations, both of which were licensee identified.
One of'the violations-falls under the noncited violation (NCV) category and one'
does not. The -licensee's configuration penagement involvement as it relates to
= maintaining Appendix R' compliance, represents one of the strengths of the
-licensee's overall1 fire protection efforts.
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DETAILS
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Persons Contacted
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'GSU:
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L*R. _Backen, Quality. Systems: Supervisor.
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- K. Bullen,- Senior Engineer
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L*B. Chustz, Maintenance. Supervisor
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- J. Cook, Technical AssistantJ
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-*C.;Coones,' Lead Fire Protection' Engineer
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- T7Crouse,QualityAssurance(QA) Manager
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- W -09rran, Site Representative-
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- B. E111si Fire Protection Coordinator-
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1*L.= England; Director, Nuclear Licensing-
- *M. Feltr.er,-Licensing Engineer.
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- W.: Fountain.-Senior QA Engineer-
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- A. Fredier, Operations, Supenisor -
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- X.LGiadrosich,'QA Supervisor-
(*E. Gould, QA. Engineer;
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- J. Hamilton,' Director, Design Engineering
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-*P. Holt,. Senior Mechanical Engineer
- R. Kerar, Civil Engineer
- G.EKimell, Director, Quality Services
- D.' Lorfing.: Supervisor, Nuclear Licensing-
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?*I.,Malik, Operations, QA1 Supervisor
- D. McCarter, Director.1 Loss-Prevention
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- W. 0' Dell,; Manager, Administration
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R. Roberts,' Supervisor,, Electrical Maintenance
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t*J. Spivey, Jr.,: Senior QA Engineer / Audit. Coordinator:
- *M. ' Stein, Supervisor,' Civil / Structural ~ Design
- K. Suhrke,' Manager, Project Management
- W. Trudell, Shift Supervisor
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- R. West,- Assistant Plant Manager, Technical Services
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cNRC:
- *T. Stetka, Chief, Plant Systems- Section
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Denotes those attending the exit interview conducted on' January 26, 1990.
The:inspectorstalso interviewed other personnel during the. inspection.
c2. POSTFIRE~ SAFE SHUTDOWN: CAPABILITY REVERIFICATION (64150)
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'The purpose of-this inspection was to determine whether the-licensee had
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d developed and? implemented a configuration management program with respect to
postfire safe shutdown capability. This: inspection was also to determine
whether the licensee has maintained the postfire safe shutdown capability that
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s was verified during the:initialfvalidation inspection conducted during the
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period'of April 11L4, 1985 .
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' 2.1=.CohfigurationManagementProgram
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~The inspectors conducted a detailed review of design change packages (DCPs) in
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order to verify that the configuration management program related to Appendix R
compliance and postfire safe' shutdown capability was adequate. Procedures were
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reviewed to determine if-provisions were included to ensure-that all DCP-
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. documents are reviewed for Appendix R-compliance and safe shutdown concerns-
that adequate guidance is provided for reviewers so that the impact on
Appendix R compliance and the postfire safe shutdown. capability-is considered;
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- and that provisions to ensure that all DCPs, which do not impact Appendix R
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compliance and postfire safe shutdown capability, are incorporated into the-
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analysis, procedures, and programs which support and implement this capability.
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In addition, to verify the implementation'of these procedures, the inspection
team selectively reviewed the DCPs to those plant systems required for postfire:
. safe shutdown.. Review and verification of the UCPs selected indicated that
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procedures for configuration control were adequately-implemented.
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2.2' Configuration Control Procedures and Implementation
The-licensee has established Procedure ENG-3-006, " River Bend Station Design
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and Modification Request Control Plan," Revision 6, dated December 20, 1989.
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This procedure establishes the instructions for initiating, controlling, and
documenting actions pertaining to design and modifications of~ permanent station
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equipment'andfacilitiesatthe'RiverBendStation-(RBS). This procedure
- contains 36 attachments for different areas of-the plant.
Design changes or modification requests-(MRs) are initiated by a design
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- engineer to satisfy the requirements of Procedure ENG-3-006. This procedure
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contains check 11ste for-the evaluation of Appendix R:and fire protection
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concerns. These checklists are Attachment 12. " Fire Protection Review
Checklist" and Attachment 27 " Design Configuration Guidelines." ~ The first
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page of Attachment 12 requires that the design engineer conduct a preliminary
fire protection evaluation and indicate by a "yes/no" answer if a proposed
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modification request m y impact certain fire protection features. A "yes"
answer requires that the Appendix R coordinator or a designated fire protection
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engineer (FPE) perform a-review of the modification request.
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The inspectors reviewed 10 modification request packages, which are listed.in
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the enclosed Attachment, to verify that the procedures for configuration-
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control were implemented. The modification request packages had been reviewed
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in accordance with the applicable RBS engineering procedure. The licensee had
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procedures in place to ensure.that the training department incorporated any MR
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resultant changes into the applicable training courses. The packages reviewed
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by the inspectors were found to be complete and acceptable.
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2.3 Postfire Safe Shutdown Procedures
2.3.1 Procedure Review
The inspectors reviewed the RBS procedure, A0P-31
" Shutdown From Outside Main
Control Room," Revision 6, dated May 8, 1989. This is the procedure that is
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applicable in case of a fire that requires evacuation of the control room and-
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which necessitates the use of the Division I remote shutdown panel. The scope
of the review was to ascertain that shutdown can be attained in a safe and-
orderly manner, to determine the level of difficulty involved in operating
Lequipment, and to verify that there is no dependence on equipment repairs to
-achieve hot shutdown.
No significant problems were identified by the review. Some editorial comments
were discussed with the licensee and a Temporary Change Notice (TCN) was issued
before the end of the inspection to incorporate these comments. The review
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determined that the actions required could be performed in a reasonable amount
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of time and in a safe and orderly manner with a minimum of difficulty. No
dependence on equipment repairs to achieve hot shutdown was identified.
2.3.2 Licensed 0)erator Requalification Program for Abnormal Operating
procedures (Fire Protection Related)
The inspectors reviewed the documentation for reactor operator requalification
training for 1989 on emergency and abnormal operating procedures. This
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t uining requires that each reactor operator (RO).and senior reactor
operator (SRO) review contents of all abnormal operating procedures (AOPs) on
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an annual basis and maintain, current training on the remote shutdown panel.
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The lesson plans were reviewed and found to be adequate. All SR0s have had
requalification training for 1989 in the performance of A0P-31 for control room
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evacuation. On the basis of this review, the inspectors found the licensed
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operator requalification. program to be adequate for the A0P-31 procedure.
2.3.3 Damage Control Measures
-Appendix R,Section III.L.5 requires fire protection features be incorporated
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in the design of structures, systems, and components important for safe
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shutdown. The design must also be capable of limiting fire damage so that
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systems necessary to achieve and maintain cold shutdown are free of fire damage
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or can be repaired such that equipment can be made operable so that cold
shutdown can be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Materials are required to be readily
available onsite and procedures are to be in effect to implement such repairs.
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Procedure AOP-31, " Shutdown From Outside Main Control Room," was reviewed to
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assess these damage control measures.
For a fire in the main control room,
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there are two components that could require repairs. The first repair is air
compressor ILSVC3A.
It may have to be powered by use of electrical jumpers at
standby motor control center 1EHSMCC2L if additional air is required for
cycling the automatic depressurization system (ADS) safety relief
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' valves (SRVs).: The.second repair entails either manually. opening valve-
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1E12F009 or. electrically jumpering the valve at motor. control center IEHSMCC26,
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in: order to permit the operation of the residual heat removal (RHR)-system in
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'the shutdown cooling made.: As stated above, Appendix R, Section-III.L.5,
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in effect to implement such repairs. Contrary to this Appendix R requirement,
the licensee had neither the materials available nor the procedures in,effect
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to implement these repairs.
Failure to meet this Appendix R requirement is
considered.to be an apparent violation. The licensee had previously identified
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this violation and had documented the finding in CR-90-26... The licensee had
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also taken corrective: actions to implement the procedures and store the
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materials at the necessary locations. Based upon these' activities, and in
accordance with the enforcement policy, 10 CFR Part 2, Appendix C,-
paragraph V.A., this violation will not be cited.
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2.4, Associated Circuits Review
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- The associated circuits ' analysis dated June 14, 1985, provided the basis of the
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modifications which were made.to comply with 10 CFR Part 50, Appendix R.
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analysis was-developed ~by Stone ~and Webster Engineering. The licensee stated
that there had been no change'in the associated circuit analysis since initial
' validation, which was documented in NRC Inspection Report 50 .458/85-27 and
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Supplement 3 to the Safety Evaluation Report (SER). The inspectors concluded
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reets the requirements of Appendix R,Section III.L.
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2.5 Fire Hazards' Analysis (FHA)
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A-review of'the FHA was conducted as a part of this fire protection; inspection.
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The FHA-at RBS had been previously approved by the NRC.
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"The inspectors initially reviewed report CR-89-1117 which stated that a n'umb~er
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of motor operated valves-(MOVs) in safety-related systems were not fin a
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condition; assumed by:the RBS FHA.
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-A detailed study of the FHA was'. initiated by the licensee following the
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discovery of improperly installed fire walls at the Division I remote shutdown
panel.in March of 1988. This- study compared FHA requirements to the valve
lineups:andstationoperating_ procedures (SOPS)andidentifiedthat19MOVsin
safety-related systems were to be administratively controlled and deenergized
during reactor operation. The licensee discovered that none of these 19 MOVs
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had been tracked by the administrative controls and that none of them had been
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deenergized. 'This' condition was documented in CR-89-1117 and had existed since
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the operating license was' issued on November 20, 1985.
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'The licensee immediately took appropriate protective measures to doenergize two
of the~ valves, which are located in high radiation areas, and initiated a
roving fire watch for the other 17 valves. During subsequent technical
evaluations, the licensee determined that these latter 17 valves were not
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required to be deenergized during p ant operations. The other two valves
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(Valves 1E12*MOVF009 and IB21*M0VF019) were determined to be a-potential
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Intersystem LOCA (ISLOCA) pathway as the result of a-fire in the main control
room or.in the remote shutdown panel.
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.In the case.of Valve 1E12*M0VF009, the concern is tc prevent a fire-induced
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- opening of the low-pressure shutdown cooling residual heat removal (RHR) system
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to the reactor vessel at operating pressure. This' high/ low pressure interface
Evalve is identified in Section 9.5 of the Updated Safety Analysis
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Report (USAR), Valve 1821*MOVF01s is the outboard isolation' valve for the' main
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! steam isolation valve (MSIV) drains. A postulated control room fire could:
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-cause this valve to.open spuriously, dumping steam to the main condenser. When
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this scenario .is considered with a loss of offsiw power, as required by the
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FHA,;this steam may be: vented to the atmosphere as main condenser vacuum'is
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lost. .These valves-have been added to the administr0tive controls and remain
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.deenergized, in accordance'with the original ~ FHA commitments.
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The inspectors were informed by the licensee that during the final days of
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-constructionandinitialoperationlicense(OL) review,thelicensee's
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~ Architect / Engineer (AE),' Stone and Webster, made a number of cocinitments in the
FHA that may have_ been unnecessarily conservative, but that were deemed
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reasonable and timely in-lieu of more extensive engineering evalu'ation and
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~. analysis. The_ FHA.was never-incorporated into operations procedure:, The
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reason for this lack of incorporation into procedures could not be explained by
the licensee.' This is an apparent violation of Gulf States Utilities (GSU)
ifacility operating licensee No. NPF-47, Attachment 4iwhich states that GSU
shall comply;with the requirements of'the fire protection program.
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The licensee's review to determine compliance with its FHA commitments >was in
progress;but'not-yet complete at'the end of this inspection. Because the
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licensee:has not completed its final reevaluation ci the: FHA, the inspectors.
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could.not determine-if the review of.the RBS FHA was adequate. This issue will
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be-co'nsidered as an unresolved item until'the licensee has completed its final
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review.
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Unresolved Item (458/9002-01):
Reevaluation of River Bend Station Fire Hazards
Analysis has not been completed by the-licensee.
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FIRE PROTECTION / PREVENTION PROGRAM (64704)
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- Program Review and Implementation
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The inspectors reviewed the licensee's procedures, which constitute the
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approved fire protection program. These procedures are listed in the enclosed
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Attachment. This review-verified that the licensee had technically accectable
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procedures to implement the fire protection program. Procedural guidance was
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provided to control, combustible material and reduce fire hazards.
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Administrative procedures also provided for maintenance and surveillances on
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1 fire suppression, detection, and support equipment. Personnel training,
qualifications, and responsibilities were satisfactorily provided. Maintenance
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. evolutions that significantly increase fire risk were properly controlled.
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The~ inspectors toured accessible areas of the plant site to observe general
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area conditions, work activities in progress, and visual condition of ~ fire
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protection systems and. equipment. Combustible materials and flammable and
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combustible liquid and-gas usage were restricted or properly controlled in
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areas containing safety-related equipment and components.
Items checked
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included positions of selected valves, fire barrier condition, hose stations,
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- hose houses, fire lockers, and fire extinguishers for type, location,-and-
condition.
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. There was no welding, cutting,.or use of open flame ignition sources:found in
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- the areas- toured. General housekeeping conditions were found. to be. very good.
- Fire brigade equipment including emergency breathing apparatus, was found to
' be properly stored and maintained. Fire protection systems and equipment
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installed for protection of safety-related areas were found to be functional
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and tested in accordance with the requirements specified in the-Technical
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Specifications.-
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The inspectors also reviewed fire brigade training and drill records. Thex
records.were.in order and confirmed that training and drills were being
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. conducted at the specified intervals.
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The last two QA audits in the area of fire protection were reviewed by the
inspectors. Audit-88-03-I-PFPP, dated April 21, 1988, e s an annual audit.
. Audit-89-03-I-PFPP, dated May 17, 1989 was the triennial audit and included an
- outside independent fire protection consultant. The audits were comprehensive
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and in-depth.~ System / equipment alterations,-tests, surveillances, maintenance,
records, and overall program procedures were addressed. -Discrepancies
identified were' formally presented to the affected organization. Responses
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were tracked to closecut and actions taken were' reviewed for adequacy.
3.2 Fire Barrier' Penetration
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The licensee'_s tracking-system for fire barrier penetration seals were reviewed-
to ensure that the seals:have been maintained to provide separation between.
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redundant trains of safe shutdown equipment as required by Section III.G. of
Append h R.; A number of penetrations were selected for field verification to
.' verify that the penetrations were sealed as specif.ied on plant drawings and
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- that adequate documentation was available to confirm the fire rating of:the
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iseals. The inspectors found that the licensee has developed a fire barrier
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tracking system which ensures that required fire barrier penetration seals- are
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adequately maintained. Additionally, for all penetration seals reviewed during
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'the field walkdown, sufficient documentation was available to confirm the
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- required fire rating.
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The inspectors, reviewed the adequacy of the installed emergency lighting'that
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. is required by Section III.J of Appendix R.
The emergency lighting was
reviewed.to ensure that it was adequate to provide the necessary illumination
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sof)ingressandl egress'pathsforfshutdownpersonnelandthattherewouldbe
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shutdown.: Inl addition, lights were inspected in-the field to; ensure that:they
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have been adequately'surveilled and maintained. -The inspector;also reviewed
several completed procedures-to confirm that the procedures were being
implemented as required..
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LThere-were no violations'or deviations identified-in thisfarea of the
inspection..
ll . EXIT MEETlHG.
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An exit * meeti'ig was held January: 26,1990, with the personnel-indicated in.
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Jparagraphzl uf this. report. At this meeting, the scope of-the inspection.and
the findings were. summarized. :The licensee did not identify as proprietary any
of the information provided to or reviewed by the inspectors.
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ATTACHMENT
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Administrative Procedures-
Procedure No.
Title
Date
STP-000-2001,: Revision 5
Daily Fire Door Position Check
110/05/89
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STP-000-3602, Revision 7A'
Fire Barrier Visual Inspection
01/15/90
STP-000-3200,- Revision 5
Fire Door Operability
02/17/89
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Functional Test
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- STP-000-3401, Revision 3
Semiannual Fire Door
01/17/89
Operability Check
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and Mechanism-Inspection-
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STP-250-3202, Revision;4
Inaccessible Fire Detector
03/07/89
. Instrumentation Test
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STP-000-3604, Revision 5
Fire Barrier 18 Month Visual
06/02/89
Inspection Scaled Penetrations
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STP-000-3605, Revision 5-
Fire Door Release Mechanism
02/03/89
Functional Test
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STP-000-3603, Revision 5
Fire Damper 18-Muh Visual
02/03/89.
Inspection
STP-250-3501, Revision 8
Six Month Fire Detector
03/07/89
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Instrumentation Functional
Test
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ENG-3-006. Revision 6
- River Bend Station Design
12/20/89
and Modification Request
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ADM-0003, Revision 17A
Development, Control and Use of
11/03/89
Procedures
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ADM-0028, Revision =10
Maintenance Work Order
12/13/88
AB-070-500, Revision 1
Pre-Fire Strategy ECCS Piping
06/24/85
Penetration Room
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AB-070-502, Revision.1
Pre-Fire Strategy RHR Pump
06/24/85
2A Room
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AB-095-517 Revision 1
Pre-Fire Strategy HPCS Piping
06/24/85
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Area
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. AB-095-516 ~, Revision 1
Pre-Fire Strategy Shield
06/17/85'
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Building Access Area
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~ AB-Or5-510,; Revision 1
Pre-Fire Strategy CCP Heat
06/24/85
Exchanger Room
FPP-0010,; Revision.5
Fire Fighting Procedures'
08/21/89
FPP-0020, Revision 7-
Guidelines for Preparation of
11/15/89
I'W
Pre-Fire Strategies and
'
~ Pre-Fire Flans.
'
- FPP-0030, Revision 5-
Storage of Combustible's'
01/06/89-
FPP-0040, Revision 6-
Control of Transient-
12/05/89-
Combustibles
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FPP-0050, Revision 2
Handling..of Flammable Liquids
04/07/86
Lq
and Gases
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FPP-0060 Revision 6
Hot Work Permit
11/06/89-
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FPP-0070, Revision 6
Duties of Fire Watch -
08/21/89
-
FPP-0090, Revision 6
Fire Fighting Equipmenti
12/05/89
Inventory, Inspection,
'
and Maintenance
FPP-0095, Revision 3
Fire Extinguisher Inspection
12/05/89
'
and Maintenance
FPP-0100, Revision.5
Fire Protection System
05/19/88
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Impairment
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Modification Requests:
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a.
,
. Number-
Title
Date
f',
MR'85-0433
Fire Detection Panel Wiring
08/31/85
!
Change
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MR 86-1584
Change Open Head Water Deluge
'10/08/86
y
"
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Fire Protection System to
1
closed Head Preaction System
,
-
- MR 85-0525
Document Change to Correct
09/26/85
Error of Multiple Valves
R
with Same ID Number
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MR 86-0313
Correct Editorial Errors
02/19/86
L,
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MR~85-0306
Drawing Change to Correct
03/08/86
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Fire Detection System
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MR~B6-0239
Document Change'to Delete
62/14/86
i4
Automatic Sprinkler.~
.
'
Correcticns'to Fire Prctection.
'
Water Supply Due to Removal.Lof
Temporary Buildings
,
(MRL86-1162
Document Change to Remove
-04/15/88
^
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Tamper Switch SWn on
-
Fire Alarm Cab 1. net--but Noti
-1
,
On Automatic. Sprinkler System
.
-Design.
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MR-86-0472-
Document'Changeito Correct-
03/17/86
J
,
. Error-in Original Wiring
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.
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-Design for Fire' Detection
' System Cabinet
,
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MR 88 ')209
Document' Change to Reflect'-
08/03/88~
,
"As Built" Changes to
1
Various Fire. Suppression
<
Systems
s
,
MR 86-1511
Change Pre-Alarm and Alarm
O')/17/86
M
Set Points for.Line Type
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. Thermal Fire Detector
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System
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