ML20128H802

Insp Repts 50-327/96-10 & 50-328/96-10 on 960708,10-12 & 0819-22.Non Cited Violations Noted.Major Areas Inspected: Plant FP Program & Action Taken of Insp Findings Previously Identified

ML20128H802
Person / Time
Site:	Sequoyah
Issue date:	09/27/1996
From:	Miller W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20128H783	List: ML20128H780 ML20128H802
References
50-327-96-10, 50-328-96-10, NUDOCS 9610100060
Download: ML20128H802 (24)

See also: IR 05000327/1996010

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION 11

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Docket Nos: 50-327, 50-328

License Nos: DPR-77, DPR-79

Report Nos: 50-327/96-10, 50-328/96-10

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Licensee: lennessee Valley Authority (TVA)

Facility: Sequoyah Nuclear Plant, Units 1 & 2

Location: Sequoyah Access Road

Hamilton County, TN 37379

Dates: July 8,10 through 12 and August 19 through 22,1996

Inspector: W. Miller, Jr., Reactor inspector

Approved by: P. Fredrickson, Chief l

Special Inspection Branch

Division of Reactor Safety

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ENCLOSURE

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9610100060 960927

PDR ADOCK 05000327

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EXECUTIVE SUMMARY

Sequoyah Nuclear Plant, Units 1 & 2

NRC Inspection Report 50-327/96-10,50-328/96-10

This inspection included a review of the Sequoyah fire protection program and the

action taken on previously identified inspection findings by the NRC and TVA's QA

organization. The report covers a 2-week inspection period.

Plant Support

Satisfactory compensatory measures were implemented for degraded electrical

raceway Thermo-Lag fire barrier materials. The Thermo-Lag upgrade project was not

scheduled to be completed until late 1998. This completion date appeared to indicate

that this modification project had not received a high priority when compared to the

other two TVA nuclear plants. The Thermo-Lag upgrades at the other two plants

have been completed. (Section F1.1)

For the areas reviewed, the control of combustible materials within the plant was

inadequate. Implementation of the transient fire load permit program was also

ineffective. This item is identified as an example of an apparent violation. (Section

F1.2)

Most of the 1991 Fire Protection Improvement Plan items had been completed.

Items not completed included engineering data on fire barrier penetration seals,

construction of the new water supply system, and submittal of the Fire Protection

Report. (Section F1.3)

The system engineering data on the HPFP system indicated that the available flow

and pressure from the HPFP system met the requirements of the Technical ,

Specifications (TS). However, in view of the MIC related problems, replacement of '

the existing fire protection river water system with a potable water supply system will j

result in a major fire protection program improvement. (Section F2.1)

A new Fire Protection Manager was appointed and organizational changes were

made to the fire protection program in July 1996. It is too soon to determine the

effectiveness of these changes. (Section F6).

Comprehensive audits and self assessments were performed of the Sequoyah fire

protection program. Resolution of identified discrepancies was not accomplished in a

timely manner and adequate changes were not implernented to prevent recurrence.

This is identified as an example of an apparent violation. TVA made management

and organizational changes to the fire protection organization in July 1996. It is too

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early too determint, if these changes will improve the implementation of the fire

protection program. (Section F7.1)

Fire dampers were installed in various walls and floors to provide a fire rated

separation from redundant safety related components. These fire dampers had been

inspected by the licensee a number of times during construction, pre-operational and

surveillance testing activities. However, these inspections apparently failed to identify

that the dampers were not installed in accordance with the vendor's requirements

until 1993. Furthermore, resolution of this issue is not scheduled for completion unu

1998. The failure to promptly identify and to resolve adverse conditions associated

with the fire dampers is identified as an example of an apparent violation. (Section

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F8.1)

Modifications to the HVAC system in May 1990 failed to receive the required fire

protection and 10 CFR 50 Appendix R review. This resulted in the required CO 2

system for the computer room being inoperable and is identified as an apparent

violation. (Section F8.2)

A fire hose hydrostatic test is required on the fire hose installed at the various hose

stations in the plant. TVA's surveillance procedures for the reactor building fire hose

5,tations were inadequate and did not assure that the fire hose installed in the reactor

buildings had been hydrostatically tested. This is identified as an apparent violation.

(Section F8.3)

TVA discovered that the fire barriers in the high radiation areas of the auxiliary

building had not been included in the fire barrier surveillance inspections performed in

August 1995 and March 1994 as required by the TS. This is identified as an

apparent violation. (Section F8.4)

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F1 Control of Fire Protection Activities

F1.1 Compensatory Measures for Dearaded Thermo-Lao Fire Barriers (64704)

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a. Inspection Scope

The inspector reviewed the compensatory actions implemented for degraded

Thermo-Lag fire barriers to determine if these measures were consistent with

the requirements of the TS and the modification schedule to upgrade the fire

protection features as required to eliminate the need for the compensatory

measures,

b. Observatiors and Findinas

In 1991, the NRC found that Thermo-Lag fire barrier material did not perform

to the manufacturers specifications. Specifically, the installed Thermo-Lag

barriers would actually provide approximately one half of the specified rating,

i.e., a 1-hour fire rated barrier would provide approximately 20 to 30 minutes of

protection. The NRC issued NRC Bulletin 92-01 and requested licensees with

Thermo-Lag fire barriers to take the appropriate TS compensatory measures i

for the areas where the Thermo-Lag materials were installed. TVA i

implemented the TS compensatory measures for degraded fire barriers. This

consisted of a roving fire watch for all plant areas where the Thermo-Lag was

installed. This compensatory measure had previously been reviewed and

found acceptable by the NRC.

TVA's schedule was to complete the necessary engineering design and

modification documents required to upgrade the existing Thermo-Lag

installations by late 1997 and to complete the installation of the Thermo-Lag

upgrade by late 1998. The Thermo-Lag upgrades at Browns Ferry and Watts

Bar have been completed, it appeared that the required Thermo-Lag upgrade

program at Sequoyah had not received as high a priority as the upgrade

programs at the other two TVA plants.

During this inspection, the inspecto. eviewed the compensatory program in

place for the degraded fire barriers. These measures included a roving fire

watch. The fire watch patrols were being performed in accordance with

Procedure FPI-0180, Revision 0, Compensatory Fire Watch Responsibilities

and Control. This procedure divided the plant into 16 fire watch zones. Each

zone was inspected by a fire watch at intervals of 60 minutes with a 15 minute

tolerance. Fire watch patrols were also provided for other degraded fire

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protection features such as inoperable suppression systems and degraded fire

dampers.

The fire watch patrols were performed by the labor shop and consisted of two

employees per shift working 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts. Their duties included walking

down each identified zone requiring a fire watch due to inoperable or degraded

fire protection system or features and to report any identified fire. The

inspector reviewed randomly selected fire watch data sheets and noted that  !

the fire watch patrols were being performed within the specified times for the )

zones requiring the fire watch patrols. A question involving storage of fire

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watch patrol records was addressed by the licensee prior to the exit.

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c. Conclusions

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Satisfactory compelsatory measures had been implemented for the degraded

electrical raceway Thermo-Lag fire barrier materials. In addition, the Thermo-

Lag upgrade project was not scheduled to be completed untillate 1998. The

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scheduled completion date indicated that this modification project had not

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received a high priority when compared to the other two TVA nuclear plants.

The Thermo-Lag upgrades at the other two plants had been completed. l

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F1.2 Control of Combustibles

a. Inspection Scope

j The inspector reviewed the implementation of the licensee fire protection

program for the control of combustible materials in the plant.

b. Observations and Findinas

Procedure SSP-12.15, Revision 14 (Effective March 29,1996), Fire Protection

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Plan, Appendix E, Control of Combustibles, is the procedure used to control

j the transient fire loads in the plant. Appendix E Section 1.0 states that the

control of transient fire loads is essential to TVA's defense-in-depth fire

protection philosophy to ensure that controls are adequate for fire prevention,

control, and suppression. This Appendix was not to be used for occupancy

changes or introduction of transient combustibles for periods greater than six

months. Transient fire load permits for greater than 6 months or storage

resulting in occupancy classification changes were to be processed in

compliance with SSP-9.3, Plant Modifications and Design Change Controls or

SSP-12.4, Temporary Alterations Control Program. Appendix E,

Section 4.J.3 required permits for high fire loads to be approved by the site

Fire Protection Engineer.

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The inspector toured the plant during the week of July 8-12 to observe the

i implementation of SSP-12.25, Appendix E for the control of transient

! combustibles. Two plant areas were identified which did not conform to the

! requirements of Appendix E. These were:

j. Auxiliary Buildina-Elevation 690: Protective Clothina Storaae

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l Transient Fire Load Permit TFL-95-0254 was issued on November 14,1995,

with an expiration date of December 31,1995, for the storage of radiation

i worker protective clothing on Elevation 690 of the auxiliary building between

i column lines A-4 and A-6. This permit listed the storage of combustibles as

! 1100 pounds of protective clothing and 400 pounds of rubber and plastic

j (boots, gloves, etc.) which were classified as having a high fire load. This

j storage area was located in a portion of the building that is equipped with

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automatic sprinkler protection; however, there were a number of safety related

electrical raceways located directly above the storage area. Some of these

i~ raceways contained safe shutdown related cables and were enclosed with

l Thermo-Lag fire barriers.

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l When the inspector questioned the location of this combustible storage area

2 and the expired transient fire load permit, the licensee informed the inspector  ;

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that this material had been in this location for several years. The inspector )

, concluded that this storage location did not conform to the requirements of

3 SSP-12.25, Appendix E in that this material had been stored in this location for ,

greater than 6-months, the transient fire load permit had expired, and l

engineering had not performed an appropriate occupancy change, design

change or temporary alteration control to address this issue.

Auxiliary Buildina Elevation 669: Former Soare Room

The former spare room on elevation 669 of the auxiliary building was used for

the storage of metal scaffolding, flammable liquids, and numerous

miscellaneous items. The general housekeeping in this area during the week

of July 8-12 was not good; however, workers were in the process of cleaning

up this room. During the week of August 19 the housekeeping was found

acceptable. This room was not provided with a fire detection or suppression

system and was not suitable for use as a combustible storage area.

The inspector reviewed the transient fire load permits for this area and noted

that the following permits were'either issued for longer than six months, did not

receive approval by the Site Fire Protection Engineer, or had not received an

engineering analysis to justify the change in occupancy: Permit TFL-95-0033

(high fire load), issued February 5,1995 and extended to December 31,1996;

Permits TLC-96-0003 (no fire load indicated) issued January 1,1996 with

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expiration date of December 31,1996; Permit TFL-96-004 (medium fire load),

issued January 1,1996 with expiration date of December 31,1996; and Permit

TFL-96-0005 (no fire load indicated) issued January 1,1996 with expiration

date of December 31,1996.  ;

Previous TVA audits of the fire protection program identified problems with the

control of combustibles and transient fire loads in the plant and in the spare

room on elevation 669.

Technical Specification 6.8.1.f requires that written procedures shall be

established, implemented and maintained covering fire protection program

implementation.

Procedure SSP-12-15, Fire Protection Plan, Appendix E, Sections 1.0 and

4.0.B, C and F state that any transient fire load request for permits greater

than 6 months, or determined to be occupancy classification changes, shall be

processed by the originator in compliance with SSP-9.3, Plant Modifications

and Design Change Controls or SSP-12.4, Temporary Alterations Control

Program. Appendix E, Section 4.0.J.3,4 and 5 requires the approval of the

Site Fire Protection Engineer prior to the introduction of any "High Fire Load" l

into any safety related area of the plant. )

For the two areas on elevations 669 and 690 of the auxiliary building, the

requirements for control of transient fire loads were not met. The failure to

promptly identify and resolve adverse conditions, specifically the storage of

combustible materials within the plant, is identified as an example of Apparent

Violation 50-327, 328/96-10-01, Inadequate Identification and Resolution of

Fire Protection Deficiencies.

During the week of August 19-22,1996, the inspector noted that all of the

combustible materials in these two areas had been removed. The radiation

worker clothing had been relocated to the cask decon collection tank room on

elevation 669 of the auxiliary building and a transient storage permit had been

issued for these materials. TVA was reviewing the location of combustible

storage in this area and other plant areas and had a schedule to identify all

permanent combustible storage areas and complete the required engineering

analysis for these areas by November 1996.

c. Conclusions

l For the areas reviewed, the control of combustible materials within the plant

and the implementation of the transient fire load permit program were

inadequate and ineffective. This item had previously been identified in TVA

l audits and is identified as an example of an apparent violation for failure to

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take appropriate corrective action. TVA had initiated corrective action to

resolve this issue.

F1.3 Fire Protection Improvement Plan

a. Inspection Scope

The inspector reviewed the status of corrective action on the 1991 TVA Fire

Protection improvement Plan for the Sequoyah plant.

b. Observations and Findinas

in late 1990, TVA identified a number of fire protection discrepancies at

Sequoyah. A fire protection improvement team was formed to evaluate these

issues and make appropriate corrective action recommendations for

management review. Following several TVA management meetings, a working

meeting was held between TVA and the NRC on August 19,1991, to discuss

TVA's identified program weaknesses and proposed corrective actions. The

commitments from this meeting were summarized in a TVA letter to the NRC

dated October 4,1991. These commitments consisted M 65 items identified

as the 1991 Sequoyah Fire Protection improvement Plan. These items were

originally scheduled to be completed by December 1,1994. Periodic status

reports were submitted to the NRC. The final completion date was changed to

August 30,1996, in the periodic status report of December 1,1995.

The inspector reviewed the completion status of these improvement items and

noted that as of August 22,1996, most of the items had been completed.

Portions of the evaluations for some items had been completed but the final

resolution had not been completed. Examples of these items include:

1. Fire barrier penetration seals: Inspections of all of the fire barrier

electrical and mechanical penetration seals had been completed and

preparation was in progress to stipulate on the engineering documents

and drawings that each fire barrier penetration was bounded by a tested

configuration. Resolution of design documentation problems remained

for approximately

1500 penetrations from the original scope of approximately 24,500

penetrations. Completion of this item is scheduled for late 1997,

2. Upgrades to the HPFP system: The design change packages to replace

the existing raw water fire protection water system with a potable water

supply system have been completed and the construction of these

upgrades were scheduled to be completed by late 1997.

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3. Fire Protection Report: The fire protection report, including revisions to

the Fire Hazards Analysis, were in progress and were scheduled to be

completed by August 30,1996. A copy of this report will be sent to the

NRC for review. In addition, TVA will request an amendment to the

operating license to remove the fire protection requirements from the

TS. This request will be sent to the NRC in late 1996.

The Fire Protection Report will place all of the TVA Sequoyah fire

protection commitments in a single document. The report will also

include the operability and surveillance requirements of the fire

protection systems and features.

c. Conclusions

The inspector's review indicated that most of the Fire Protection Improvement

Plan items had been completed. Examples of the items not yet completed

were fire barrier penetration seal engineering data, construction of the new

water supply system, and submittal of the Fire Protection Report.

The improvement plan resulted in a number of enhancements to the fire

protection program, such as:

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Development of the Fire Protection Report to include all fire protection

commitments and requirements in a single document.

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Preparation of an up to date Fire Hazards Analysis to describe the

hazards and fire protection features in each plant area.

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Development of an engineering document to provide design

requirements and fire test data for each fire barrier electrical and

penetration seal. This had been a long-standing issue at Sequoyah.

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Generated appropriate design change modification packages for the

installation of the fire pumps and water storage tanks using potable

water to replace the existing river water fire pumps.

- Provided a number of general enhancements of the site's fire protection

procedures and program. Three examples of significant enhancements

include the provision of fire protection training to the engineering staff,

development of hydraulic data for the fire protection water system to aid

in the analysis of degraded fire protection piping systems, and the

issuance of revised Pre-fire Plans.

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F2 Status of Fire Protection Facilities and Equipment (64704)

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F2.1 Status of High Pressure Fire Protection System

a. Inspection Scope

The inspector reviewed the reliability status of the high pressure fire protection f

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(HPFP) system.

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The inspector reviewed two recent reports prepared by the system engineer

responsible for the HPFP system.

HPFP SYSTEM STATUS REPORT

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The 1996 third quarter status report for HPFP system indicated the HPFP

. system status was " Yellow" or in need of improvement, due to:

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Microbiological Induced Corrosion (MIC) problems in the HPFP system.

Three small pin hole size MIC related leaks were identified during the

third quarter. There were a total of j

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15 small leaks in the system. Correction was not scheduled until late

1997. These repairs were to be made after construction of the new fire  !

4 protection water system has been completed. I

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HPFP pumps operated most of the quarter to support chemistry water  !

processing, chlorination and system flushing. Continuing operation of

the fire pumps resulted in cavitation downstream of the fire pumps which

deteriorated the interior wall of the pipe. Recent ultrasonic examinations

revealed that a section of this piping needed to be replaced. This

section of piping was scheduled to be replaced in September 1996 by

Work Request C326772.

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Electric motor for HPFP Pump 2A-A was replaced by an electric motor

that was reworked by an unapproved vendor. This pump was

considered available but not operable until the appropriate evaluation

was completed and the pump passed the TS operability test. After the

Third Quarter report was issued, the motor rework was approved, the

pump passed the surveillance test and was considered operable.

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, SPECIAL SYSTEM ENGINEER'S REPORT ON HPFP SYSTEM STATUS

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! The HPFP System Engineer's August 22,1996, Special Report on HPFP

l System Status provided information on the history of the HPFP system,

hydraulic flow data, results of pump tests, MIC leaks, new HPFP system, and

current system status.

) A new HPFP water supply system, consisting of two fire pumps and two

L 300,000 pallon tanks, was scheduled to be constructed in 1997. This system

I will se' mate the fire protection water system from the raw service water

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] The existing HPFP system was previously perceived by TVA to have

- performance problems. However, a TVA evaluation concluded that these

problems were due to testing methodology and instrumentation inaccuracies.

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Approximately 15 MIC related piping system leaks existed in the system.

l These were small pin hole leaks and the number of new leaks were occurring

at a rate of about one new leak per two months (six per year). Major new

i leaks were being repaired but repairs to small pin hole leaks had been

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deferred until the construction of the new fire protection water system. This

schedule would result in the system being taken out of service only once for

l repair or replacement of the piping and valves with the MIC leaks in the j

j auxiliary building. These leaks did not appear to affect the operability of the 1

system. TVA's evaluation and monitoring of this system concluded that there

l was not a concern for the structural integrity of the HPFP piping system.

i TVA's report indicated that the existing HPFP water system meets the fire  !

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protection design requirements. Flow test data for the plant's automatic

j sprinkler systems, performed in January 1993, December 1993, December i

! 1994 and December 1995, exceeded the design requirements. Flow tests for

j the exterior yard mains, performed in 1993,1994 and 1995, indicated  !

l satisfactory volumes of water were available to meet the fire protection

j demands for the safety related areas of the plant. These tests also indicated i

4 that the flow capacity of the system remained constant, i.e., no significant

reduction in available flow.

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The annual surveillance flow tests performed on the four HPFP pumps during

1992 through 1996 indicated that these pumps met the requirements of the TS.

! c. Conclusions

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Based on review of the system engineer's data on the HPFP system and other

i report data, the inspector concluded that the available flow and pressure from

j the HPFP system met the requirements of the TS. However, in view of the

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MIC related problems, replacing the existing fire protection river water system l

with a potable water supply system will be a major fire protection program l

improvement.

F6 Fire Protection Organization and Administration (64704)

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A new Fire Protection Manager was appointed in July 1996. Organizational

l and responsibility changes were also made in July 1996. The Fire Protection

l Manager previously reported to the Operations Manger via an Operations

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Supervisor and Operations Support Superintendent. Currently, the Fire

Protection Manager reports directly to the Operations Manager.

Additional organizational and staffing changes have been proposed.

CURRENT PROPOSED

Fire Protection Manger Fire Protection Manager

Fire Protection Supervisor Fire Protection Engineer

Fire Protection Engineer Fire Marshall

Fire Marshall Fire System Engineer i

Fire Brigade (5 Shifts) Fire Brigade (5 Shifts) '

Foreman (Brigade Leader) Foreman (Brigade Leader)

Two Fire Operators / Fire Brigade Four Fire Operators

Two AUO Fire Brigade Members

(Assigned to Operations) l

Total assigned: 21 Total proposed: 30

TVA's schedule was to complete the staffing for the proposed organization by

late 1996.

The inspector concluded that the changes to the fire protection organization

and staffing were positive improvements.

F7 Quality Assurance in Fire Protection Activities

F7.1 Nuclear Assurance and Licensina Fire Protection Audits (64704)

a. Inspection Scope

The inspector reviewed the results of the licensee's OA audits of the fire

protection program and the corrective actions initiated in response to the audit

findings and recommendations.

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b. Observations and Findinas

During an inspection in February 1996, as documented in NRC Inspection

Report 50-327,328/96-02, the inspector noted that although comprehensive

audits of the plant's fire protection program were being performed, the

corrective actions on identified findings were not being completed in a timely

manner, as follows:

i NOTE: The inspection status evaluation for each item is contained

in the bracketed "[]" sentence at the end of each issue.

1992 Audit:

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• Inadequate emergency lighting iristallation and an inadequate

preventive maintenance program for installed lighting units. [The

installation of new lighting units had been completed with the field

testing and preventive maintenance procedure revisions in progress.]

(SQFIR920077209)

1994 Audit:

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• No restoration program for approximately 1500 degraded fire barrier

, penetration seals. [ Engineering design data input was scheduled for

early 1997. As of this inspection, no date had been proposed for

completion of required modifications.] (SQ940019PER, SQ940466PER,

and SQ961363PER)

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• Inadequate procedures for the evaluation and control of transient

cornbustibles. [ Procedures had been revised but had not been

effectively implemented. The issue associated with the storage of

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combustible materials in the plant was scheduled for resolution by

November 1996.]

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• Inadequate design control over fire barrier penetration seals.

[ Resolution of this issue is scheduled for late 1997.] (SQ940019PER,

SQ940466PER, and SO961363PER)

1995 Audit:

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• Changes were being made to the plant without following the design

change process, i.e. inadequate controls over plant changes which

affect the fire protection program. [This issue was scheduled to be

resolved by 1997.] (SEQ 950428)

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Controls were not in effect to retain the operability of the structural steel

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fireproofing supporting the floor above the cable spreading room. [TVA

l planed to maintain this fireproofing material on the structural steel

j- supporting the control room flooring. Repairs to the damaged or

i missing fire proofing materials were in process during this inspection.]

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• Testing of the backup cable spreading room fire suppression system

]. for the cable spreading room had not been performed since 1982. [TVA

j plans to install a blind flange in this system and remove it from service.

The design change package was scheduled to te issued September 15,

i 1996. No schedule date was provided for competion of this plant

j change.] (SQ950382PER and SQ960468 PERE

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Errors were noted in the Fire Hazards Analysis. [These errors were i

j scheduled to be corrected by August 1996.] (SQ950368PER)

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i 1996 Audit:

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j TVA's audit No. SSA9604 of the Sequoyah Fire Protection Program dated May

10,1996, found the program not fully adequate due to continuing

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implementation problems.and recurring program deficiencies. TVA's corrective

actions on previous audit findings had not been effective in resolving long-

standing problems. The audit report stated that immediate management

attention and improvement were required. The audit findings, adverse

conditions and recommendations included: i

Findinas

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Design requirements for inspection of fire barriers were not translated l

into plant surveillance instructions and conflicts were identified with I

visual inspection criteria. [This item was scheduled to be completed by

November 29,1996.] (SQ960886PER and SQ960888PER)

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Two implementation problems were identified related to the failure to

perform visual inspections of fire barrier penetrations as required by the  !

TS. [This item was scheduled to be resolved by September 1,1996.]  ;

(SO960796PER and SQ960854PER)

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Tracking, prioritization and resolution of long-term fire protection

problems and previous audit findings had not been fully effective.

Lessons learned from other nuclear utilities, including TVA plants, were

not adequately evaluated to prevent similar issues at Sequoyah. The

timeliness of corrective actions on previous audit findings was

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inadequate. These included: correction of Appendix R emergency

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lighting issues; continuous use of TS compensatory actions due to

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impairments to fire doors and fire barrier penetration seals; fragmented  ;

j' organizational structure with no overall responsible manager of the fire j

j protection program; and Fire Hazards Analysis and UFSAR >

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discrepancies and errors. [ Resolution of these issues were being l

discussed by TVA and no completion date had been scheduled.] '

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(SQ960928PER)

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j Outstandina Audit Adverse Conditions

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A number of fire doors separating safety related redundant divisions

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were not alarmed as required by the fire protection commitments,

i [ Correction of this issue was scheduled to be resolved by November 29,

1996.] (SQ960783PER)

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Some Appendix R emergency lighting units have batteries that exceed

the 10 year expected life and 8 year preventive maintenance

j replacement schedule. Most Appendix R lighting units were installed in

1985. [The initial 8 year change out was in process during this

l inspection.] (SQ960955PER)

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Records were not available to provide documented evidence that the fire

i brigade members had received training on protective clothing.

l [ Resolution of this item was in process.] (SO960885PER)

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Several minor fire protection related discrepancies were noted in UFSAR

j Section 8. [ Resolution of this item was in process.] (SQ960887PER)

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The original Fire Hazards Analysis used as the basis for the fire

! protection system design is referenced in the UFSAR but was not l

! retrievable from the Technical Information Center. [This item had been

! completed and was in the closure review process.] (SQ960782PER)

i

Audit Recommendations .

i

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Consider increasing visibility of fire protection impairments and other fire

j protection issues with a weekly presentation to the plan of the day

j committee as was being done at the other TVA nuclear plants.

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Consider improving the public address system so that it can be heard in

j all plant areas, such as 500kv switchyard and elevation 669 of the

] control building.

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Ensure management expectations are fully understood concerning the

evaluation and incorporation of the existing commitments into the fire

protection report.

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Evaluate long term non-conformance issues for unresolved safety

question determination. ,

TVA had assigned a Problem Event Report number to address the concerns

for resolving fire protection related issues. Corrective action on most of the

May 1996 audit items were in the initial implementation stages. It was too

early to evaluate the effectiveness of this corrective action.

The Sequoyah TS for Units 1 and 2, Section 6.8.1.f, requires that written

procedures shall be established, implemented and maintained covering the fire l

protection program implementation. I

TVA's Nuclear Quality Assurance Plan (NAQP), TVA-NOA-PL89-A provides a

complete description of the quality assurance program for operation of the

Sequoyah Nuclear Plant. NAQP TVA-NOA-PL89-A, Section 5.0 identifies the '

programs and features to which the NAQP applies. Section 5.0.B.6 lists fire

protection as one of these programs.

NAOP, TVA-NOA-PL89-A, Section 10.2.2.B Corrective Action for Adverse

Conditions, states: TVA nuclear organizations and onsite non-TVA nuclear

service organizations performing quality-related activities at nuclear facilities

shall promptly identify and resolve adverse conditions.

The failure to promptly identify and resolve adverse conditions identified during

quality assurance audits of the fire protection program, specifically six specific

findings from the audits of October 9,1992, August 1,1994, and July 14,

1995, is identified as an example of Apparent Violation 50-327, 328/96-10-01,

inadequate Identification and Resolution of Fire Protection Deficiencies. Note

that the six specific findings are annotiated by an "*" in the report text.

c. Conclusions

Comprehensive audits and self assessments of the Sequoyah fire protection

program were performed. However, resolution of identified discrepancies was

not accomplished in a timely manner and adequate changes were not

implemented to prevent recurrence. This was identified as a violation.

TVA initiated fire protection program management and organizational

responsibility changes in July 1996. It was too soon to determine the

l effectiveness of these changes.

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F8 Miscellaneous Fire Protection Issues

)' F8.1 (Closed) LER 327/93-027, Degraded Fire Dampers as a Result of a Failure to

Install the Dampers in accordance with Design Drawings.

, TVA identified approximately 326 fire dampers which failed to meet the

vendor's design and installation requirements. These fire dampers had been in

a degraded condition since initial licensing. The principal discrepancy was the

installation of the dampers in concrete walls and floor penetrations without the

required clearance to permit thermal expansion in the event of fire.

4

j TVA performed detailed evaluations and determined that the installation of 318

dampers was adequate and no additional modifications were required. This

,

decision was based on the installation location of the dampers, low

3

combustible loading in the areas on each side of the fire barrier where the

damper was installed, and the fire detection and suppression systems

i

provided. A total of 8 fire dampers were required to be modified to meet the

design requirements. This work is scheduled to be completed in FY 1998. A

. roving fire watch was provided for all of these degraded fire dampers as

j required by TS Section 3.7.12.

! The inspector reviewed the locations of the eight fire dampers to be replaced

. and noted that six of these dampers were located in the walls separating the

'

auxiliary control room from the four auxiliary control instrument rooms. One

damper was in the wall separating 125v battery room ll from 6.9kv board room

A and the remaining damper to be replaced was in the wall separating 125v

battery room 111 from 6.9kv board room B. These dampers were to be replaced

i to assure separation from the two redundant safe shutdown trains.

The inspector reviewed the following calculations and found that these

i calculations were satisfactory:

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SON-26-DO53 EPM-VTI-101994 86-10 Evaluation of Diesel

l Generator Building Fire Dampers

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SON-26-DO53 EPM-VTI-113094 86-10 Evaluation of Control

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Building Fire Dampers

,

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SON-26-DO53 EPM-VTI-120894 86-10 Evaluation of Auxiliary

Building Fire Dampers

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SON-26-DO53 EPM-VTI-082895 86-10 Evaluation of Remaining

i Fire Dampers

.

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DCN S-11786-A 86-10 Evaluation of Seven Fire

l Dampers

l

NRC Inspection Report 50-327,328/94-09, Paragraph 7.a, contains additional

l information on this LER and an assessment of TVA corrective action.

i

j WA's evaluation determined that the root cause of this event was construction

personnel not following design drawings during the initial installation of the fire

i dampers.

i The corrective actions included establishing fire watches in the safety related

. areas where the fire dampers were installed and performing engineering

evaluations to determine which dampers were required to be replaced.

l

TS 3.7.12 requires all fire barrier penetrations (including fire dampers) to be l

l functional at all times in fire zone boundaries protecting safety related areas.

! Fire dampers were installed in the various walls and floors to provide a fire

! rated separation from redundant safety related components. The fire dampers

! at Sequoyah had been inspected by the licensee a number of times during

construction and pre-operational and surveillance testing activities. These

l inspections failed to identify that the dampers were not installed in accordance

j with the vendor's requirements. The failure to promptly identify and the

i resolve adverse conditions associated with the fire dampers is identified as l

l another example of Violation 50-327, 328/96-10-01, inadequate Program for l

4

ldentification and Resolution of Fire Protection Deficiencies.

i

l This LER is closed. The corrective action will be reviewed as part of the  ;

j resolution for this violation. l

!

! F8.2 (Closed) LER 327/95-018, Inoperability of the Carbon Dioxide System for the

Computer Room Resulting from an inadequate Design Change.

On December 18,1995, during a review of plant HVAC systems, TVA

identified that HVAC ducts passing through the computer room on elevation

685 of the control building had been provided with new outlets. These outlets

!

were not equipped with dampers to close upon actuation of the computer room

i CO2 system. This resultod in the CO 2system being inoperable since the l

supply'and exhaust eir riow from these openings would exhaust the CO2 from

! the room if the fire protection extinguishing system activated. The system was

removed from service on December 18,1995 and the room added to the

roving fire watch detail. Current plans are to install the appropriate dampers in

j 1997.

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The modifications to the HVAC system were performed in May 1990. The

NRC inspector noted that surveillance functional ard operability testing had  ;

been performed on the computer room CO 2 systa in April 1991, August 1992, 1

June 1994 and December 1995. These tests did not identify that the system l

did not meet the design requirements.

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TVA identified the root cause of this event to be personnel error by the

designers during the design phase. The designers failed to recognize that the

HVAC system changes affected the isolation of the computer room and had an

adverse effect on the fire suppression system for this room. Also, the design

change failed to receive the required fire protection and 10 CFR 50 Appendix

R reviews.

TS 3.7.11.3 requires the CO2 system for the computer room to be operable

L

whenever the equipment protected by the system is required to be operable.

The failure to maintain the CO2 for the computer system operable is identified

as Apparent Violation 50-327, 328/96-10-02, Inoperable CO2 System.

This LER is closed. The corrective action will be reviewed as part of the

l resolution for this violation.

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F8.3. (Closed) LER 327/96-002, Surveillance Requirements Associated with Fire

l Protection Hose Station Were Not Performed as Required by Technical

Specifications.

,

On February 15,1996, TVA discovered that the surveillance requirements for

the fire hose inside containment was not hydrostatically tested as specified by

TS Sectiori 4.7.11.4. On November 10,1990, the survoillance instructions

contained in Procedures 1/2-SI-FPU-026-191.R, Fire Hose Inspection, for the

fire hose stations inside containment were revised by removing the

requirement to verify that fire hose installed inside containment had been

hydrostatically tested within three years of the conclusion of a fuel cycle. The

fire hose inside containment was replaced with new fire hose every three years

during a refueling outage. Subsequent investigation by TVA found that the fire

hose for 9 of the 24 hose stations for the Unit 1 annulus had not been tested

within three years. The fire hose on these 9 stations was replaced with new

fire hose on February 29,1996. The fire hose in the Unit i lower containment

had been replaced with new hose in September 21,1995 which had been

tested by the manufacturer in January 1995.

The fire hose for the Unit 2 annulus was replaced May 7,1996, by a fire hose

which had been tested on May 6,1996. The fire hose for the Unit 2 lower

containment was replaced April 30,1996, with new fire hose which had been

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l hydrostatically tested on April 30,1996. TVA's corrective action of replacing

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this hose with properly tested hose was satisfactory.

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TVA determined that the root cause of this event was an improper procedure

revision and inadequate procedure review of procedures 1/2-SI-FPU- 026-

191.R during the performance of the revision. Specifically, the procedures did

not require that the date of the hydrostat!c test of the replacement fire hose be

verified prior to installation. This permitted fire hoses to be installed which did

not meet the test requirements of the TS.

TS Section 4.7.11.4.c.2 requires that each of the fire hose stations shown in

Table 3.7-5 shall be demonstrated opersble at least once per 3 years by

conducting a hose hydrostatic test at a pressure of 150 psig or at least 50 psig j

above maximum fire main operating pressure, whichever is greater. The hose  ;

stations installed in the Reactor Buildings are listed in Table 3.7-5. 1

Between November 10,1990 and February 15,1996, TVA's surveillance

instructions for Procedures 1/2-SI-FPU-026-191.R for the reactor building fire

hose stations were inadequate in that these procedures did not assure that the

fire hose for these locations would be hydrostatically tested as required by TS Section 4.7.11.4.c.2. This issue, is identified as Apparent Violation 50-327,

328/96-10-03, Inadequate Surveillance Procedures for the Fire Hose Stations

inside the Reactor Buildings.

F8.4. (Closed) LER 327/96-03, Failure to Perform Surveillance Requirements for

Penetration Fire Barrier Inspections as required by the TS.

On March 25,1996, TVA discovered that the fire barriers in the high radiation ,

areas of the auxiliary building had not been includedin the fire barrier

surveillance inspections performed in August 1995 and

March 1994.

The root cause of this event was personnel error. The surveillance

performer and reviewer incorrectly believed that fire barrier inspections

were not required if access to a plant area was restricted by radiological

conditions such as high radiation.

All of these fire barriers were inspected and requirements were discussed with

the appropriate personnel. This corrective action was satisfactory.

TS 3.7.12 Section 3.7.12 requires all fire barrier penetrations to be functional

at all times in fire zone boundaries protecting safety related areas. TS 4.7.12

requires each fire barrier penetration to be verified to be functional at least

once per 18 months. The failure to verify that all of the fire barrier

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penetrations were functional is identifiec as Apparent Violation 50-327,328/96-

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10-04, Failure to Perform Fire Barrier Penetration Seal Inspections.

F8.5 (Closed) Violation 50-327, 328/96-02-07, Inadequate Storage and Maintenance

of Fire Pumps and Components in Long Term Storage. l

TVA responded to this violation by letter dated May 22,1996. The inspector

, reviewed the corrective action and verified that this action wac, appropriate and

satisfactorily implemented.

Manaaement Meetinas

l X1 Exit Meeting Summary

) The inspectors presented the inspection results to members of licensee management

at the conclusion of the inspection on August 22,1996. The licensee acknowledged

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the findings presented, j

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The inspectars asked the licensee whether any materials would be considered j

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proprietary. No proprietary information was identified. I

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PARTIAL LIST CF PERSONS CONTACTED

,

Licensee

,

5 *Adney, R., Site Vice President

• Baron, R., General Manager Nuclear Assurance and Licensing

• Casey, J., Fire Protection Manager

• Edwards, W., Engineering Task Manager

, *Fecht, M., Nuclear Assurance & Licensing Manager

• Flippo, T., Site Support Manager

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• Heatherly, I., Nuclear Engineering-Mechanical / Nuclear

*Jutice, W. Nuclear Engineering Safety Analysis Supervisor

! * Kent, C., Radcon/ Chemistry Manager

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• Lagergren, B., Acting Operations Manager

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• Meade, K., Compliance Manager

• Rupert, J., Engineering and Support Services Manager

• Salley, M., Corporate Engineer, Fire Protection

Shell, R., Site Licensing Manager

i

• Smith, J., Regulatory Licensing Manager

• Summy, J., Assistant Plant Manager

• Zerinque, O., Senior Vice President, Nuclear Operations

• Attended exit interview

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INSPECTION PROCEDURES USED

4

IP 64704: Fire Protection Program

IP 92901: Followup-Plant Operations

J IP 92904: Followup-Plant Support

ITEMS OPENED AND CLOSED

f Opened

Tvoe item Number Status Description and References

i eel 50-327, 328/96-10-01 OPEN Inadequate Identification and

Resolution of Fire Protection

Deficiencies. (Sections F1.2,

F7.1, and F8.1)

eel 50-327, 328/96-10-02 OPEN Inoperable CO2 System.

(Section F8.2)

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eel 50-327, 328/96-10-03 OPEN Inadequate Surveillance

Procedures for Fire Hose

Stations inside Reactor

Buildings. (Section F8.3)

eel 50-327, 328/96-10-04 OPEN Failure to Perform Surveillance  !

Inspections of Fire Barrier

Penetration Seals. (Section

F8.4)

Closed

Tvoe Jtem Num'oer Status Description and References

LER 327/93-027 CLOSED Degraded Fire Dampers as a

Result of a Failure to Install the

Dampers in accordance with

Design Drawings. (Section

F8.1)

LER 327/95-018 CLOSED inoperability of the Carbon

Dioxide System for the

Computer Room Resulting from

an Inadequate Design Change. l

(Section F8.2)

LER 327/96-002 CLOSED Surveillance Requirements

Associated with Fire Protection

Hose Stations Were Not

Performed as Required by  ;

Technical Specifications. )

(Section F8.3)

LER 327/96-003 CLOSED Failure to Perform Surveillance

Requirements for Penetration  !

Fire Barrier Inspections as l

required by the TS.

(Section F8.4)

VIO 50-327, 328/96-02-07 CLOSED Inadequate Storage and

Maintenance of Fire Pumps and

Components in Long Term

Storage. (Section F8.5)

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LIST OF ACRONYMS USED

CFR -

Code of Federal Regulations

eel -

Escalated Enforcement item

kV -

Kilo-Volt

LER -

License Event Report

NQAP -

Nuclear Quality Assurance Plan

NRC -

Nuclear Regulatory Commission

PER -

Problem Evaluation Report

PSIG -

Pounds per Squars Inch Gage

SI -

Surveillance Instruction

SSP -

Site Standard Practices

TS -

Technical Specification

TVA -

Tennessee Valley Authority

UFSAR -

Updated Final Safety Analysis Report  !

URI -

Unresolved item i

VIO -

Violation

WO -

Work Order l

WR -

Work Request  !

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