ML20038B636
| ML20038B636 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/20/1981 |
| From: | Ebneter S, Koltay P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20038B619 | List: |
| References | |
| 50-320-81-19, NUDOCS 8112080452 | |
| Download: ML20038B636 (7) | |
See also: IR 05000320/1981019
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
Region.I
Report No. 50-320/81-19
Docket No 50-320
License No. DPR-73
Priority
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Category
C
Licensee: Metropolitan Edison Company
P.O. Box 480
Middletown, PA 17057
Facility Name: Three Mile Island Nuclear Station, Unit 2
Inspection at: Middletown, Pennsylvania
Inspectionconducpd:
Oc ger - , 1981
Inspectors:
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P. S. Kol af,
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Approved by:
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S." D. EbnWW, Chief, IPlant Systems
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Section, DETI
Inspection Summary,:
Inspection on October 5-7, 1981 (Report No. 50-320/81-19)
Areas Inspected:
Routine unannounced inspection of the Fire Protection /-
Prevention Program including: administrative procedures, assignment of functional
responsibilities, observation of critical fire area, action on previous inspection
findings, fire barrier penetration seals, and technical specification surveillance
records. The inspection involved 13 inspector hours on site by one regional based
inspector.
Results: Of the six areas inspected, no items of noncompliance were identified
in five areas; one deviation from a commitment was identified in one area.
(Deviation
paragraph 7)
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8112080452 811123
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DETAILS
1.
Persons Contacted
S. D. Cha'plin, Licensing Engineer
E. H. Gischel, Director, Plant Engineering
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G. A. Kunder,. Technical Specification Compliance Supervisor
S. E. Lane, Fire Protection Engineer
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T. A. O'Connor, Lead Fire Protection Engineer
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J. W. Quinnette, Fire Protection Engineer
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C. D. Rowe, Modifications / Operations Quality Assurance
All the above personnel attended the exit meeting.
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2.
Licensee Action on Previous Inspection Findings
(Closed) Inspector Followup Item (320/79-19-03) and Infraction (320/78-38-01).
Poor housekeeping in the Cable Spreading Room.
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The referenced reports identified the licensee's failure to maintain the
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cable spreading room free of transient combustible materials such as
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accumulated debris, recording tape and temporary tables.
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The inspector reviewed procedure AP 1008, Good Housekeeping, dated November
12, 1980. The inspector verified that the cable spreading room was free-
of transient combustibles at the time of the inspection, and that the
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licensee conducts periodic housekeeping inspections of the area.
(Closed) Unresolved Item (320/79-15-01) Auxiliary Building Roof Charcoal
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Filter Sprinkler System.
The inspector verified that the auxiliary building roof charcoal filters
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and the associated sprinkler systems have been removed from service.
This item is no longer applicable and it is considered closed.
(Closed) Unresolved Item (320/79-15-04 and 79-19-01) Auxiliary Diesel
Generators, Fire Protection.
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The licensee stated that the auxiliary generators are no longer vital to
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the safe maintenance of existing plant conditions and tichnical specification
requirement for the equipment have been eliminated. Accordingly unresolved
items relating to the fire protection of the above equ!ncast are considered
closed.
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(Closed) Unresolved Item (320/79-26-06)- Fire Barrier Penetration Seals
Utilizing Silicone Foam.
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The referenced report discussed the licensee's use of mineral wool as a
chafing guard in electrical cable floor penetration seals. Due to the
placement of chafing guards, the required uniform depth may not have been
maintained for all penetrations.
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Through visual inspections of a random sample of the affected penetrations,
the inspector verified that the licensee removed all chafing materials
and filled the penetrations with silicone foam.
(Closed) Unresolved Item (320/79-15-05) Hose Houses, 1 1/2 inch Fire
Hose.
The referenced report discusses the licensee's failure to provide adequate
lengths of 1 1/2 inch diameter fire hose in hose houses.
The inspector verified that the licensee provided 300 feet of 1 1/2 inch
diameter hose in each of the hose houses located near building access
routes.
(Closed) Unresolved Item (320/79-19-02 and 79-29-02) Rad Waste Storage
Area, Fire Protection.
The referenced reports discuss the lack of fire protection for the radwaste
storage building (Paint Shed).
The inspector verified that the licensee installed automatic sprinklers
and fire detection devices inside the storage area.
In addition, a
hydrant was installed in the vicinity of the building. The licensee also
developed a fire fighting plan for the area. HP monitoring equipment is
located in the fire brigade van, which is used to respond in case of a
fire emergency.
(Closed) Inspector Followup Item (320/79-19-04) Fire Extinguisher Inspections.
The referenced report discussed the licensee's failure to conduct monthly
portable fire extinguisher inspections in several plant areas.
The inspector randomly checked portable extinguisher stickers in all
accessable plant areas.
The inspector verified that monthly fire extinguisher
inspections are conducted by the licensee.
(Closed) Unresolved Item (320/79-19-06) Fire Brigade Training _
The referenced report discussed the inadequacies of certain segments
(hands on equipment) of the licensee's fire brigade training program.
Since the issuance of the referenced report, the licensee has established
a fire brigade training program, wnich satisfies 10CFR50, Apper. dix R
requirements, including classroom training of brigade members and brigade
leaders, regular drills with offsite fire department participation and
hands on equipment training at the York County Fire School. Various
segments of the training have been reviewed by the inspector during this
and previous inspections and found to be acceptable.
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(Closed) Deficiency (320/78-38-02) Fire Pump Monthly Surveillance Test
3303-MI.
The referenced report discussed the licensee's failure to perform certain
steps prescribed in the procedure for the monthly functional fire pump
test.
The inspector reviewed the results of each monthly fire pump test performed
during 1981 to date. The inspector verified that the monthly tests were
performed in accordance with procedure.SP3303MI, revision 9.
The inspector
noted that the requirements of the procedure were satisfied during each
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test.
No item of noncompliance was identified.
3.
Fire Protection / Prevention Program
a.
Administrative Controls
The inspector reviewed the following procedures and documents:
AP-1038, revision 2, Administrative Controls, Fire Protection
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Program;
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AP-1034, revision 4, Control of Combustible Materials;
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AP-2101-1.2, Transient Combustible List;
-- 'AP-1008, revision 9, Geod Housekeeping;
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1410-4-26, revision 5, Welding, Cutting, Grinding and Open
Flame Work Procedure for Fire Safety;
The inspector verified that the licensee has established an adequate
fire protection organization and has implemented an adequate fire
protection / prevention program which includes:
delineation'of responsi-
bility for personnel participating in the program, implementation of
administrative procedures, training for fire brigade members and
leaders, coordination and communication with offsite fire departments,
fire fighting strategies for vital areas and maintenance and surveillance
of fire protection equipment.
4.
Reactor Building Fire Protection
The inspector, during the course of the inspection and at the exit interview,
discussed with the licensee the status of the fire protection equipment
located inside the reactor containment building. The licensee stated
that to date the phy:.ical condition of fire protection equipment inside
containment has not been_ examined. However, during the course of discussions
the following was agreed to by the licensee:
a.
Fire detection devices and annunciated circuits are no longer
functional.
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b.
The rubber fire hoses attached to the containment standpipe connections,
and the rubber discharge hoses of the portable CO2 extinguishers are
probably no longer functional.
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The inspector expressed concerns regarding the introduction of
combustible materials in the containment building as part of a
decontamination program.
The licensee agreed that prior to initation of any type of prolonged
activity, inside containment, a complete review of existing and
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newly introduced combustible materials will be conducted and adequate
fire protection measures will be taken.
The results of such reviews will be submitted to the NRC for review.
This item is considered unresolved.
(320/81-19-01).
5.
Review of Surveillance Test Rc;ords Associated with Technical
Specification Requirements
The inspector selected and reviewed the following records to' verify that
the associated required fire protection surveillances had been performed
and that the acceptance criteria had been met:
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SP 4333 SAI, Fire System Detectors Instrument Functional Test, rev.
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The inspector reviewed the results of the test performed on
October 15, 1980.
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SP 4333 SA2, Fire Detection Circuit Operational Check, rev. O. The
i'prector reviewed the results of tests performed on August 20,
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33 43331 R3 Fire Barrier Penetration Fire Seal Inspection, rev. 1.
The inspector reviewed the results of inspections conducted since
September 12, 1981. The inspection process is still underway by the
licensee.
No item of noncompliance was identified.
6.
Critical Fire Areas
The inspector verified that the cable spreading room is free of: transient
combustible materials.
No item of noncompliance was identified.
7.
Fire Barrier Penetration Seals
The inspector reviewed temporary corrective measures taken by the licensee
to maintain electrical cable penetration fire seals functional. The
progressive dcterioration of fire barriers using Firewall 50 sealant, a
trade name for the Chemtrol Corporation, was previously described in the
following reference documents:
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a.
Nonconformance Report (NCR) No.78-132, dated June 15: 1978;
b.
Licensee Event Report LER No. 79-12/3L, dated September 11, 1979;
c.
IE Inspection Report 50-320/79-26
d.
Licensee's letter GQL 1583 to Mr. B. H. Grier, Director, NRC Region
I, dated December 31, 1980.
e.
Licensee letter LL2-81-0028 to B. H. Grier, Director, NRC, Region I,
dated February 4,1981.
f.
Licensee Event Report LER LL2-81-0062, dated March 3, 1981.
The licensee developed a methodical program for conducting temocrary
repairs on the defective penetration seals.
The program consi ns of
yearly inspections of the penetrations in accordance with procedure
SP4331-R3 and repair of cracks and separation openings in accordance
with procedure MP-1410-43.
During the course of this inspection, the inspector noted that the
deterioration of Firewall 50 sealant has increased.
Several penetra-
tions developed bulges, indicating that layers of the materials are
separating from the core of the penetration.
The inspector also
brought to the attention of the licensee, that two penetrations in
the cable spreading room have developed 1/4 to 1/2 inch wide and
10-15 inch long cracks which penetrate the depth of the material.
The licensee, following the requirements of Technical Specification 3.11.7, posted a fire watch in the area while temporary repairs were
initiated and completed by the licensee.
Fire barrier penetration seals were designed and installed to meet
the requirements of Appendix A to Branch Technical Position APCSB
9.5-1 " Guidelines for Fire Protection for Nuclear Power Plants",
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section D3, which states in part, " Cable and cable tray penetrations
of fire barriers should be sealed to give protection at least equivalent
to that fire barrier. The design of the fire barriers ... should as
a minimum, meet the requirements of ASTME-119, Fire Test of Building
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Construction and Materials .
Licensee's document NY0-77-002, rev. O, Fire Protection Program
Evaluation, Three Mile Island Nuclear Station, Unit 2, page 4.1-61,
states in part:
"All vertical cable trays and conduits passing
through fire rated floors and all horizontal cable trays and conduits
passing through fire rated walls have penetration seals installed to
prevent flame and smoke passage or propagation through the penetration.
The penetration seals have the same fire rating as the 5all or floor
they penetrate." The penetration seals used on TMI-2 have been
tested in accordance with the requirements of ASTM E-119-73, " Standard
Methods of Fire Tests of Building Construction and Materials"."
Ccstrary to the above, due to the extensive deterioration of Firewall
50 ealant material, the penetration seals do not have the same fire
rat,1g as the wall or floor they penetrate. Also contrary to licensee
commitments indicated in references b, d and f, a permanent repair
program has not been initiated.
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The licensee's failure to satisfy the above guidelines is considered
to be a deviation from the licensee's commitment to Appendix A to
the BTP 9.5-1.
(320/81-19-02)
8.
Unresolved Item
Unresolved items are matters about which more information is required to
determine whether they are acceptable, items of noncompliance or deviations.
Unresolved items are discussed in paragraph 3b.
9.
Exit Interview
The inspector met with the licensee representatives listed in paragraph 1
at the conclusion of the inspection on October 7, 1981 to discuss the
scope and findir.gs of the inspection. On October 16, 1981, a telephone
call between Mr. P. Koltay of this office and Mr. J. Larson, Licensing
Supervisor, the scope and findings of this inspection, as documented in
this report, also were presented.
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