ML20135F927
| ML20135F927 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/04/1985 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| GL-82-21, NUDOCS 8509180020 | |
| Download: ML20135F927 (2) | |
See also: IR 05000245/1984015
Text
{{#Wiki_filter:e J 3. SEP 041985 Docket Nos. 50-245 50-336 Northeast Nuclear Energy Company ATTN: Mr. W. G. Counsil Senior Vice President - Nuclear Engineering and Operations Group P. O. Box 270 Hartford, Connecticut 06141-0270 Gentlemen: Subject: Combined Inspection Nos. 50-245/84-15 and 50-336/84-15 This refers to your letter dated August 30, 1984, in response to our letter dated August 1, 1984 which transmitted the above referenced inspection reports to you. The staff has reviewed your response to the inspection findings and has the following comments regarding the exceptions you expressed. Your response to the Notice of Deviation regarding the application of the National Fire Protection Code and the FSAR commitment is technically acceptable. Therefore, with the issuance of this letter, the Notice of Deviation is withdrawn. However, we recommend that during your annual update of the FSAR you include the specific areas of the NFPA you comply with to avoid future misunderstandings. Based on the information you supplied dealing with Item 2.7.1 of the report we concluded that your audit program satisfies your Technical Specifications. However, we will ascertain the degree of auditor independence afforded by your organizational structure, in a future inspection. We also direct your atten- tion, to the staff guidance regarding compliance with technical specification, fire protection audit requirements provided by Generic Letter No. 82-21, dated October 6,1982 (Enclosure 1). Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program. Your cooperation with us in this matter is appreciated. Sincerely, M8tal Signed By3 8509180020 850904
PDR ADOCK 05000245 ' O PDR \\ Stewart D. Ebneter, Director Division of Reactor Safety Enclosure: Generic Letter No. 82-21 0FFICIAL RECOR] COPY RL HILLSTONE 84-15 - 0001.0.0 01/16/85 i ]
, . . Northeast Nuclear Energy Company 2 cc w/ encl: J. F. Opeka, Vice President, Nuclear Operations E. J. Mroczka, Station Superintendent D. O. Nordquist, Manager of Quality Assurance R. T. Laudenat, Manager, Generation Facilities Licensing Gerald Garfield, Esquire Public Document Room (PDR) local Public Document Room (LPOR) Nuclear Safety Information Center (NSIC) NRC Resident Inspector State of Connecticut bcc w/ encl: Region I Docket Room (with concurrences) Senior Operations Officer (w/o encls) DRP Section Chief RI:0RS{ n .r. 5 RI:DRS RI:DRS peg ffy > cf of 9 A 0FFICIAL RECORD COPY RL MILLSTONE 84-15 - 0002.0.0 01/16/85 - - - - . - - - - - . - - - - - . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - J
. . APPENDIX A NOTICE OF VIOLATION Northeast Nuclear Energy Company Docket Nos. 50-245 Millstone Unit I and 2 50-336 License Nos. DPR-21 DPR-65 As a result of the inspection conducted on June 11-15, 1984 and the supplemen- tary information transmitted to us via letter No. A04244 dated August 30, 1984, Mr. W. G. Council to Dr. T. Murley, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), as revised, published in the Federal Register (49 FR 8583, March 8,1984), the following violation was identified: Technical Specification 6.5.4.7.e requires that an inspection and audit of the Fire Protection Program shall be performed annually by an outside firm experi- enced in fire protection and loss prevention. Contrary to the above, the Fire Protection Program audits for years 1982 and 1983 were performed by off-site licensee personnel, not an outside firm. This is a Severity Level V violation (Supplement I). Pursuant to the provisions of 10 CFR 2.201, Northeast Nuclear Energy Company is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending this response time, g , J 49 ' thl h f
'" iP 0FFICIAL RECORD COPY RL MILLSTONE 84-15 - 0003.0.0 v 07/19/85 J' P 9
. . . N UTILITIES . oinz,ai Orrice e s:ioin sire i. eeriin. connecticui 1 .Ys-2'U$,sYcIce .',' P O. BOX 270 we. .ciam ce- a.a HARTFORD CONNECTICUT 06141-0270 k k J $.[[*,[,C ,'c'y'**' (203) 665-5000 Augus t 30,1984 Docket Nos. 50-245 50-336 A04244 . Dr. Thomas E. Murley - Regional Administrator Region ! U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Ref erences: (1) Thomas T. Martin letter to W. G. Counsil, dated August 1, 1984 transmitting I&E Inspection Report Nos. 50-245/34-15 and 50-336/34-15. (2) Reportable Occurrence RO 50-336/34-008-00, dated July 13, 1934. Gentlemen: Millstone Nuclear Power Station, Unit Nos. I and 2 I&E Inspection Nos. 50-245/34-15 and 50-336/84-15 The NRC Staff transmitted to Northeast Nuclear Energy Company (NNECO) the subject inspection reports in Reference (1). As discussed in Ref erence (1), the Staf f cited NNECO for two violations of Technical Specifications and an apparent deviation f rom FSAR documentation. In addition, item 2.7.1 of the Inspection Report documented an unresolved item pending receipt of documentation regarding fire protection audits to satisiy Technical Specification 6. 5.4.7.e. In accordance with the Ref ererx e (1) request and pursuant to 10CFR2.201, NNECO tereby provides the attached information in response to the Notice of Violation, Notice of Deviation, and Item 2.7.1 of Ref erence (1). We trust you find the attached information satisfactory. Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY ] . fi V' S?fM ' % . G. Counsil Senior Vice President cc: V. Stello, Jr. R. H. Vollmer J. R. Miller AA A n M$(1,[]f, ,+ lPP- o q v y y 1- r J
. . 1 . . ,- l - . Docket Nos. 50-245 50-336 . . m Attachment Millstone Nuclear Power Station, Unit Nos. I and 2 Response to I&E Inspection Report 50-245/84-15 and 50-336/34-15 , , August,1984 . I _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ '_ _ . _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ . . _ _ . , _ _ _ _ _ _ _ _ . , , , _ _ . _ , _ _ _ _ _ _ _ _ _ _ _ _ , _ __. _ _ _ , _ _ , _ _ _ _ _ _ __ _ _ _ _ _ _ _ _
- _- _. ._. __- ._ . _ _ . = - .- . .. . . I Response to Notice of Violations The following information addresses the two severity Level IV violations cited on Docket No. 50-336 for Millstone Unit No. 2 during the inspection conducted on June 11-15,1984. Item A Technical Specification 4.3.3.7.1 requires that fir'e detection instruments shall be demonstrated operable at least once per 6 months by performance of a Channel Functional Test. Contrary to the above, the required ;est of the fire detection instruments was not performed in the period of March 33 - May 84. l This is a Severity Level IV violation (Supplement I). Response Following the identification of the apparently missed surveillance, NNECO ' ^ conducted an extensive review of surveillance records and the contr01 room log book to determine whether the surveillance test had, in fact, been performed. The review included interviews with shif t supervisors. The personnel interviewed recalled having performed the surveillance; however, written evidence to this effect could not be retrieved. When it became evident that the surveillance record for the period March,1983 through May,1984 could not be located, NNECO reviewed the most recent surveillance test results. These tests, performed in May,1984, were complete and did not identify any discrepancies in fire detection instrumentation operability. The results of the May,1984 surveillance tests demonstrate that for the period of concern, the fire detection instrumentation was operable and it is NNECO's position that plant fire protection was not compromised. f i The review of surveillance records which ensued as a result of this inspection ' identified the fire detection instrumentation surveillance as missing from the MODE 5 and 6 Master Surveillance list at Millstone Unit No. 2. Since the plant i- j was shutdown for an extended refueling and maintenance outage during the period from May,1983 through December,1983, it is possible that the required , surveillance was overlooked. The Master Surveillance list, for MODES 1-4 contained the fire detection instrument surveillance requirements. The master surveillance lists define what surveillances must be-performed and when they i must be performed as required by the Technical Specifications. To prevent recurrence, the master surveillance lists were updated to include the Fire Detection System surveillance for MODES 5 and 6. The lists were also verified to . reflect all other _ surveillances required by the Technical Specifications. 4 Item B 10 CFR 50, Appendix R, requires 'that 3 hour fire barriers shall be installed as necessary to protect redmdant systems and components necessary for safe shutdown. , l . .
.. \\ . . . . Contrary .to the above, the 3 hour fire barrier walls installed to protect the redundant switchgear battery room A and B, necessary for safe shutdown, < - contain unsealed penetrations that do not meet the required 3 hour fire rating. This is a Severity Level IV violation (Supplement I). Response i Appendix R to 10 CFR 50 establishes fire protection features required to satisf y G D C 3. As promulgated, only Sections III.G,111.3 and 111.0 of Appendix R are unilaterally applicable to plants licensed to operate prior to January 1,1979. In addition, where open issues existed in a licensees' fire protection saf ety evaluation report, then the applicable portion of Appendix R becomes a backfit item. The Inspector referred to Section II.C.4 of Appendix R to 10CFR50 in item 2.8 of the Inspection Report 30-245/34-15 and 50-336/34-15. This reference is inappropriate as 10CFR50.48 only specifies Sections III.G, III.3, and III.O as backfit to Millstone Unit F . 2. To assess conformar ce to Section Ill.G of Appendix R to 10 CFR 50, licensees were required to reevaluate their plants to determine the systems and equipment required to achieve safe shutdown and the of fects on safe shutdown given a fire in any fire area in the plant. To the extent that redundant cables and equipment including associated non-safety circuits which could prevent safe shutdown or whose maloperation could jeopardize safe shutdown are located in the same fire area, Appendix R prescribes acceptable means of limiting fire damage to only one of the redundant trains of safe shutdown equipment. Where redundant trains of safe shutdown related equipment and/or cabling are located in separate fire areas, no f urther action is necessary. For plants licensed for construction or operation as of July 1,1976, fire areas are defined in BTP 9.5-1 and Appendix A thereto as areas sufficiently bounded to withstand the hazards associated with the fire area and, as necessary, to protect important equipment within the fire area from a fire outside the area. Appendix R does not prescribe fire areas as bounded by barriers rated at three hours. If a licensee chooses to erect a fire barrier to separate redundant safe shu'down equipment or cabling in accordance with Ill.G.2.a of Appendix R, then that barrier needs to be rated at three hours or an exemption is required. Contrary to the Inspector's citation, the barrier in question is reinforced concrete and defines fire areas which separate redundant safe shutdown components. It was not erected to conform to Section III.G.2.a of Appendix R. - The unsealed penetration cited in the violation consisted of a fiberglass pipe running between the D. C. Switchgear Room and its redundant battery room. , The pipe provided drainage from the floor drains in the fire area above the 4 Switchgear rooms. Upon confirmation of the breach, the plant was operated in accordance with Technical Specification 3.7.10a; a fire watch was posted and the fiberglass pipe was cut at each fire area penetration and sealed. The applicable fire protection procedures were revised to provide for alternate drainage for the fire area above the switchgear rooms in the event a fire alarm is received and the sprinkler system is activated. i . .
. . . . This drain pipe was changed from cast iron to fiberglass during the 1980 refueling outage because the cast iron pipe was not seismically supported and thus had the potential to fall on the plant's 125 volt D.C. batteries. At the time this change was made no fire protection review was made of the installation. Since that time, the Generation Fire Protection Engineering group has been created and is responsible for reviewing plant design changes which are identified by plant personnel as having potential fire protection concerns. All design changes are evaluated to determine if this potential exists. Current procedures are designed to prevent f uture occurrences as described above. As a permanent solution, the fiberglass drain pipe will be replaced with a seismically supported fire retardant pipe during the next ref ueling outage. The consequences of the single, six-inch diameter unsealed penetration are considered minimal. This is based on the following. Both the Switchgear Room and the Battery Room impacted by this penetration are equipped with fire detection instrumentation. The fire loading in each room is low and equates to a fire severity of 19 minutes and 3.5 minutes for the Switchgear and Battery Room, respectively. While we recognize the fact that the penetration required modification to enhance the effectiveness of the fire barrier in question, we do not agree with the finding as documented in the Inspection Report. The modification described herein was required to restore the fire barrier to a condition which conforms to the provisions to Technical Specification 3/4.7.10. The fire barrier was not installed in accordance with III.G.2.a of Appendix R nor is it required to be three hour rated. Response to Notice of Deviation The following information addresses the Notice of Deviation cited on Docket No. 50-336 for Millstone Unit No. 2 during the inspection conducted on June 11- 15,1984. Item Final Safety Analysis Report (FSAR) Section 9, Paragraph 9.10.2.1 states that the fire protection systems have been designed in accordance with the National Fire Protection Association (NFPA) codes and standards. Contrary to the above, Unit 2 fire protection piping in the Unit I and 2 turbine building corridor is embedded in the block wall without the required sleeves or clearances. Response The fire protection systems at Millstone Unit No. 2 have been designed and constructed in accordance with the National Fire Protection Association (NFPA) codes and standards as deemed applicable and appropriate to a nuclear power plant. As the NFPA codes and standards were written for general construction, _ their applicability in totality to a nuclear power plant is not appropriate. More importantly, the fire protection systems were reviewed to the Branch Technical Position 9.5-1 and Appendix A thereto, and found acceptable. . J
. . . . In conversations with representatives of NFPA, NNECO confirmed that the provision of NFPA 13 recommending sleeves be provided for fire protection piping extending through floor partitions, walls, etc. was provided to protect the piping from shear forces resulting from wall section movement due to building settlement. In addition, the NFPA representative stated that the sleeves would provide some protection from seismic motion of walls and floors. It is NNECO's position that the provision of NFPA 13 cited by the inspector is not appropriate for application to nuclear power ' plant construction, particularly at Millstone Unit No. 2. Nuclear power plants are designed and constructed in a manner to prevent building settlement. The majority of structures at Millstone Unit No. 2 are f ounded on bedrock and, as such, not subject to settlement. Furthermore, BTP 9.5-1 and its Appendix A does not require fire protection systems to be designed and installed as seismic Category I. Based on this, it is NNECO's position that the fire protection system installation at Millstone Unit No. 2 meets the intent of the applicable NFPA Codes and Standards and no deviation from the FSAR exists. ' When citing the applicability of NFPA Codes and Standards to nuclear power plant construction it is important to recognize and understand the bases on which these codes and standards were draf tea. Due to the primary purpose for which the NFPA Codes and Standards were founded, their blanket application to a nuclear power plant fire protection system design is not appropriate. NNECO has referenced the NFPA Codes and Standards to indicate that the fire protection principals and concepts embodied in the Codes and Standards have been recognized and considered in the design and installation of fire protection systems at Millstone Unit No. 2. Response to item 2.7.1 The following information is provided in response to a commitment, documented in Item 2.7.1 of Inspection Reports 50-245/84-15 and 50-336/84-15, to provide justification as to why offsite auditors are equivalent to an outside firm in fulfillment of Technical Specification 6.5.4.7.e. One result of the NRCN review of licensee's responses to BTP 9.5-1 and Appendix A to BTP 9.5-1 following the Brown's Ferry fire was Technical Specifications for plant fire protection. The Technical Specifications issued by the staff covered such items as fire detection and suppression systems, fire barrier functionability and fire brigade size. The Tecnnical Specifications promulgated by the Staff included provisions for audits by the Site Nuclear Review Board as well as personnel experienced in fire protection and loss prevention. As summarized below, NNECO and the NRC Staff went through several iterations prior to reaching agreement on the current Millstone Unit No. 2 fire + protection Technical Specifications. The NRC requested NNECO to submit proposed fire protection Technical Specifications and provided sample Technical i Specifications f or this purpose by letter dated December 1,1976. , L J
. . . . The sample Technical Specifications for Section 6 provided by the NRC Staff included provisions for three audits / inspections and are listed below: (a) The Facility Fire Protection Program and implementing procedures at least once per 24 months. (b) An independent fire protection and loss prevention inspection and audit shall be performed annually utilizing either qualified off-site licensee personnel, or an outside fire protection firm. (c) An inspection and audit by an outside qualified fire consultant shall be performed at intervals no greater than three (3) years. NNECO originally proposed to include only item (a) in the Technical Specifications; however, we subsequently proposed item (a) and a combined item (b) and (c) as listed below: (a) 6.5.4.3.d The Site Fire Protection Program and implementing procedures at least once per 24 months. (b) 6.5.4.3.e An inspection and audit of the fire protection and loss prevention program shall be performed annually by an outside firm experienced in fire protection and loss prevention. Inspection / audit item (b) was the result of a compromise solution to consolidate the Staff's two (2) remaining inspection / audit requirements. This consolidation was carefully worded to take full credit for inspections and audits already being performed and to specifically avoid having to initiate yet another audit to fulfill NRC-proposed Technical Specification requirements. NNECO documented to the Staff the fact that the wording proposed in Item b, above, was intended to ensure that no additional audits would be required to fulfill Technical Specifications. These provisions were proposed by letter dated July 11, 1977. The NRC accepted these technical specification provisions for Millstone Unit No. 2 by letter dated March 3,1973. Although the Staff promulgated technical specifications requiring inspections of fire protection and loss prevention programs, no guidance was ever issued outlining the contents of an acceptable audit / inspection deemed to satisfy the technical specification. To fill this void, NNECO developed a comprehensive audit and inspection program to satisfy Technical Specification 6.5.4.7.e wherein several audits / inspections are performed and consolidated. Included is the annual inspection performed by American Nuclear Insurers (ANI), the Site Nuclear Review Board (SNRB) audit, the fire brigade training audit and an audit / inspection performed by Generation Fire Protection Engineering (GFPE). The combination of these audits and inspections is considered as fulfilling license requirements and was deemed appropriate due to the lack of explicit direction from the NRC as to how Technical Specification 6.5.4.7.e should be satisfied. At the time the Technical Specification provisions were proposed, it was determined that these audits / inspections would satisfy the provisions of Technical Specification 6.5.4.7.e. . L -
. .. . . % Although inspections performed by ANI are credited towards compliance with Technical Specification 6.5.4.7.e, it is NNECO's position that the GFPE group maintains the appropriate expertise and capability to perform this inspection if necessary and could fulfill the provisions of the -Technical Specifications. NNECO's position on this item was summarized to the NRC in a December 15, 1977 letter to G. Lear from D. C. Switzer wherein proposed Technical Specification 6.5.4.7.e was addressed as follows: '_'The requirements of Section (e) and Section (f) were combined to reflect the intent of your proposed specifications. The proposed wording more clearly indicates that personnel who have previously conducted inspections and audits at the Millstone facility will satisfy specification requirements. The term " qualified" in this context is unclear." The NRC did not take exception to this position. It is NNECO's intention to continue to have audits / inspections perfortred by ANI and to credit these audits / inspections towards the satisfaction of Technical Specification 6.5.4.7.e. In addition, the Generation Fire Protection Engineering . group within Northeast Utilities Service Company will perform independent audits and inspections utilizing qualified personnel. The nature of the GFPE group within Northeast Utilities, and in particular the organizational relationship l and definition of responsibilities between it and the plants qualifies GFPE as an outside firm in the context and intent of the Technical Specifications. In the absence of any further NRC communication on this issue, we will consider it resolved. If additional clarity in the language of the Technical Specifications is judged to be appropriate by the NRC, please advise accordingly. <
, 7- _ . . . . References A. Schwencer to D. C. Switzer, dated December 1,1976. D. C. Switzer to G. Lear, dated July 11,1977 G. Lear to D. C. Switzer, dated March 3,1973. .. O ' -- }}