ML20128L108

Insp Rept 50-213/85-15 on 850614-26.Violations Noted:Failure to Complete Design Review or Safety Evaluation,Violating Fire Detection Sys Tech Spec by Allowing Three Control Room Smoke Detectors to Be Inoperable

ML20128L108
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	07/12/1985
From:	Mccabe E, Swetland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20128L096	List: ML20128L094 ML20128L099 ML20128L108
References
50-213-85-15, NUDOCS 8507240302
Download: ML20128L108 (6)

See also: IR 05000213/1985015

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-213/85-15

Docket No. 50-213

License No. DPR-61

Licensee: Connecticut Yankte Atomic Power Company

P. O. Box 270

Hartford, CT 06101

Facility Name: Haddam Neck Plant, Haddam, Connecticut

Inspection at: Haddam, Connecticut

Inspection conducted: _ June 14-26, 1985

Inspector: A k%, b 1htlf f

Paul D. Swetland, Senior Resident Inspector Date

Approved by: f% AO 7 h2 /H

E. C. McCabe, Chief, Reactor Projects Section 3B Date

Inspection Summary: Special onsite inspection to review the licensee's design

change / modification control activities related to the plant process computer re-

placement project; and a licensee identified degradation of control room fire pro-

tection equips.ent during these modifications on May 29, 1985. The inspection in-

volved 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> by the senior resident inspector.

The inspection identified violations of licensee design review and safety evalu-

ation procedures and of onsite review committee activities (Detail 5.1). Weak-

nesses were also identified with regard to licensee implementation of prompt and

effective corrective action (Detail 5.2 and 5.3).

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DETAILS

1. Persons Contacted

• J. E. Beauchamp Quality Assurance Supervisor

• G. H. Bouchard Station Services Superintendent

• T. J. Bransfield Fire Protection Engineer

• J. L. DeLawrence Acting Engineering Supervisor

• L. S. Ferenchik Betterment Construction

• J. H. Ferguson Unit Superintendent

• R. H. Graves Station Superintendent

• G. L. Johnson Director, Generation Engineering & Design

J. Lewis Betterment Construction

• P. F. L'Heureux Assistant Engineering Supervisor (Mechanical)

• R. F. Lucas Generation Construction

J. M. Mietliki Betterment Construction

• E. M. Mroczka Vice President, Nuclear Operations

• J. J. Roncaioli Fire Protection Engineering

• G. J. Silberquit Associate Engineer

• G. H. Tylinski Assistant Engineering Supervisor (Electrical)

• G. P. VanNoordennen Licensing

• Denotes those present at exit interview.

2. Description

During the implementation of an approved plant modification on May 22-23, 1985,

the licensee identified a problem in the scope of the approved work. Three

control room smoke detectors were to be removed as part of facility modifica-

tiens supporting the plant process computer replacement project. However,

these detectors are required to remain operable by Technical Specifications

(TS), and no relief or amendment to this requirement had been sought. For-

tuitously, the detectors had not yet been removed, but their performance had

been degraded by the removal of the suspended ceiling in which the detectors

were installed. The licensee took action on May 24, 1985, to delay detector

removal until the TS change process could be completed. Action to restore

full operability to the detectors was initiated on May 29. The details of

the occurrence, its cause, and the adequacy of licensee's corrective action

are listed below.

3. Background

The plant process computer replacement project has been ongoing since 1980.

This project involves procurement and installation of hardware and software

components to support a significant upgrade in process computer capability.

The new computer hardware will be installed and tested in place prior to

swap-over, during a refueling outage, of plant computer functions from the

present hardware. In order to support the new hardware installation, facility

modifications were planned including new air-conditioning, power supplies,

input interface devices, and fire protection systems. These modifications

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were. located in the rear of the control room complex where the existing com-

puter room and operations office are located. This area is presently pro-

tected from fire.by three of ten smoke detectors from the control room fire

detection system. Plant TS 3.22 requires 8 out of 10 of these detectors to

remain operable.' Otherwise, compensatory fire patrols must be established.

The facility modifications supporting the computer replacement work were in-

itiated_and in progress during May June 1985. The approved scope of work

for.this project included the removal of the three control room smoke detec-

tors located.in the plant computer area. The project will ultimately install

a Halon fire suppression system in this area.

Licensee corrective actions for 1983-84 design change control problems in-

cluded a major review and revision of design change control procedures. Staff

retraining in this area was conducted during the period November 1984 - Feb-

ruary 1985 with particular emphasis on the licensee's " Nuclear Safety Ethic"

which stresses correct performance of jobs'the first time. An NRC crdered

independent review of the design change control process is currently underway.

4. Sequence of Events-

The project specifications and plant design change request (PDCR) for the

first phase of the computer replacement project were developed in early 1985.

Both documents clearly specified the removal of the three smoke detectors in

the rear of the control room as part of the approved work scope. During the

design change review process in March-April 1985, the PDCR package was inde-

perdently reviewed by several individuals in the corporate engineering or-

ganization. These reviews were conducted in accordance with approved quality

assurance procedures, and certified the acceptability of the project with re-

gard to the provisions of 10 CFR 50.59. On May 1-8, 1985, the PDCR received

further review by the site engineering staff. PDCR 713 was reviewed by the

Plant Operations Review Committee (PORC) and approved for implementation.by

the Station Superintendent on May 9, 1985. None of the review processes cited

above identified that the removal of control room fire detectors would require

NRC approval of a TS change prior to implementation of this work item.

A work order initiating the facility changes (air conditioning and structural

modifications only) was approved on May 13, 1985. During the removal of the

suspended ceiling structure holding the 3 smoke detectors, the need to remove.

the interfering detectors was identified by the betterment construction or-

ganization on May 22, 1985. Upon-requests to the plant and corporate engi-

neering staffs as to the appropriate means for removal of the detectors, the

fact that the detectors could not be removed without TS action was identified.

On May 23, the plant engineering supervisor issued a memorandum to construc-

tion indicating that the detectors would not be removed. The detectors re-

mained energized and suspended at their normal location, however the ceiling

was no longer there to act as a collector for the detectors. The overhead

ceiling was 6-8 feet above the detectors. A memorandum from fire prote: tion

engineering to construction on May 24, 1985 proposed alternatives regarding

-the TS requirements for these detectors. These alternatives included sta-

tioning a permanent fire watch or relocating the detectors. Another memoran-

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dum from plant engineering to the corporate project engineer on May 24 indi-

cated that the original design change package was inadequate because the TS

change required to remove the existing smoke detectors was not identified in

PDCR 713. A revision to the PDCR was recommended.

On May 28, 1985 a fire protection engineer observed the condition of the

modified smoke detector arrangement in the work area. He concluded that the

removal of the ceiling around the detectors degraded the effectiveness of the

detectors and notified construction that the detectors were not fully operable

in the present configuration.

Construction personnel notified plant engineering of the degraded condition

of the 3 smoke detectors on May 29, 1985. The plant declared the detectors

inoperable and initiated a roving fire patrol in accordance with TS 3.22.E.1.

The licensee used a conservative criterion to verify detector operability.

The detectors were required to be within 12 inches of the ceiling to be oper-

able. On May 29, the detectors were moved closer to the ceiling, however the

12 inch criteria was not clearly specified or achieved. A plant engineering

memorandum to Operations dated May 29, 1985 lifted the requirement for the

compensatory fire watch because the detectors had been relocated to within

12 inches of the ceiling. No physical verificat. ion was pe? formed to justify

this conclusion, but the fire watch was terminated on May .9, 1985.

The plant engineering department initiated a Plant Informatlon Report (PIR

85-81) on May 29, describing the violation of TS 3.22 which existed from May

22 - 29 because the 3 smoke detectors had been rendered inoperable without

establishing a compensatory fire watch. Immediate corrective actions based

on this PIR were limited to the engineering memoranda documented above, re-

stricting the removal of the detectors and requesting action to initiate a

TS change request.

On June 13, 1985 during routine followup of PIR 85-81, the inspector identi-

fied that the smoke detectors were not actually located within 12 inches of

the ceiling. This condition was brought to the licensee's attention and the

detectors were raised from their positions about 18 - 30 inches below the

ceiling to within the 12 inch specification.

During a meeting with plant management on June 14, 1985, the inspector related

NRC concerns regarding this event including continued design change review

failures, potential violations of TS 3.22 and 10 CFR 50.59, and ineffective

corrective action to prevent recurrence of such failures. The licensee indi-

cated that that the problems had been self-identified, that action had been

taken to correct the inoperable detectors and prevent their removal, and that

any further corrective action would result from later reviews of the incident.

.On June 18, 1985, the Senior Vice President, Nuclear Engineering and Opera-

tions, issued a summary of the problems related to PDCR 713 to all supervisory

personnel and reminded them that increased diligence and attention to detail

is necessary to insure that jobs are done correctly. Assignments to review

the event and develop corrective action were initiated at the corporate level.

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During a subsequent PORC review of this event, the committee adopted guide-

lines to improve their PDCR review process. These included review of.PDCRs

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'at special meetings exclusive of routine business and with enhanced quorum /

attendance rules. Consideration of " walk-in" PDCR review requests was limited

to abnormal / emergency situations.

5. Findings-

5.1 PDCR'713 was generated, reviewed and approved authorizing the removal

of TS required fire detectors. Personnel involved with the design re-

view, safety evaluation and PORC review of this modification all missed

the TS relationship.of_these detectors and the interface aspect of the

.specified work' scope to existing. plant requirements. The omission was

identified _ prior to removal of the detectors, and final operations de-

.partment. release of the detectors had not yet been requested or granted.

Nevertheless, the ongoing project work resulted in an unreviewed degrad-

ation of the performance of the 3. smoke detectors when the ceiling was

removed around them. TS 6.8 and 10 CFR 50, Appendix B, Criterion V re-

quire. quality-related activities including design change control to be

conducted in accordance with approved procedures. The generation, review

and safety. evaluation of-proposed design changes are prescribed by Ad-

ministrative Control Procedures ACP 1.0-3.1 (NEO 3.03), Preparation, Re-

view and Disposition of Plant Design Change Requests, and NEO 3.12,

-Safety Evaluations. These p'rocedures require in Steps 6.5 and 6.2.4,

respectively, that the impact of proposed design changes on plant TS be

determined. The licensee's failure to correctly identify the TS re-

quirement.for the 3 control room smoke detectors during the required

reviews constitutes a violation of these procedural requirements (213/

85-15-01).

TS 6.5.1 requires the PORC to advise the Station Superintendent on all

proposed changes or modifications to plant systems that affect nuclear

safety. The PORC review of PDCR 713 on May 9, 1985 failed to identify

that the removal of 3 smoke detectors detailed in the work scope would

exceed the Limiting Conditions for Operation for the control room fire

detection system specified in TS 3.22, Fire Protection. This is a vio-

lation (213/85-15-02).

5.2 The TS problem with the approved work scope of PDCR 713 was identified

.on May 22-23 1985. The licensee took action to stop the removal of the

required smoke detectors and to start administrative action to change

the TS requirements and to revise the PDCR package. The purpose of lic- . '

ensee procedure NE0 2.18, Corrective Action, is to identify and correct

quality-related problems efficiently. NE0 2.18 provides one of several

means by which corrective actions are identified and followed. None of

the corrective action procedures cited in NEO 2.18 were initiated for

the PDCR_713 design review problems. Although action to prevent removal

of the detectors was taken, as was some action that increased detector

system sensitivity, no formal recognition, documentation or initiation

of action to prevent recurrence of these design review errors was iden-

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tified until the June 18, 1985 initiation of action by the Senior Vice

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President. -The timeliness and effectiveness of corrective actions for

the design change review inadequacies which caused this will remain un-

resolved pending completion of the licensee's corrective action program

(UNR 213/85-15-03).

5.3 On May 29, 1985, the licensee documented a violation of TS 3.22.E.1, in

that 3 out of 10 control room fire detectors had been rendered inoperable

(8 of 10 detectors must be operable) because.the ceiling above the de-

tectors had been removed; A detailed evaluation of the control room fire

detection system would later reveal that the detectors had been degraded

-by the removal of the ceiling, but the detectors and the system remained

operable. During the period May 28 - June 14, 1985, however, the licen-

see conducted corrective actions using a conservative criterion which

assumed that the detectors must be within 12 inches of the ceiling to

be operable. The inspector reviewed the implementation of licensee cor-

rective actions for the reported TS violation which was first identified

onsite by a fire protection engineer on May 28, 1985;

The licensee's corrective actions in this case were not timely because

a delay in reporting the identified degradation in control room fire

protection to plant personnel resulted in extending the period of ap-

parent violation of a TS Limiting Condition for Operation for several

hours. Neither were the corrective actions effective because the iden-

tified discrepancy (detectors not within 12 inches of the ceiling) was-

not corrected, in that the detectors'were only raised to within about

18 - 30 inches of the ceiling. This failure resulted in a further ap-

parent violation of TS 3.22 from May 29 when the compensatory fire watch

was terminated without verification of the actual location of the detec-

tors until June 13, 1985 when the NRC inspector identified the discre-

pancy in detector location. Since NRC review of:the subsequent re-

evaluation of the smoke detector operability criterion has confirmed that-

the detectors remained operable throughout this period, no actual TS

violation occurred. Nevertheless, the implementation of the licensee's

corrective action program based on the apparent violation was flawed.

The timeliness and effectiveness of corrective actions for the reported

TS violation will remain unresolved pending NRC review of the licensee

evaluation and response to these discrepancies (UNR 213/85-15-04).

6 .~ Unresolved Items

Unresolved items are matters.about which more information is required in order

to determine whether they are acceptable items or violations. Unresolved

items identified during this inspection are discussed in Paragraph 5.

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7. Exit Interview

The inspector met with-licensee representatives (listed in Paragraph 1) on

June 26, 1985. The scope of the inspection and the findings were summarized.

No proprietary information related to this inspection was identified.

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