IR 05000327/1985037
| ML20137E413 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/15/1985 |
| From: | Conlon T, Madden P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20137E369 | List: |
| References | |
| 50-327-85-37, 50-328-85-37, NUDOCS 8511270252 | |
| Download: ML20137E413 (9) | |
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p nt:g UNITED ST ATES D
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_j 101 MARIETTA STRE ET, N.W.
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Report Nos.:
50-327/85-37 and 50-328/85-37 3 v.
Licensee:
Tennessee Valley Authority 6N118 Missionary Ridge Place 1101 Market Street Chattanooga, TN 37402-2801 Dccket Nos.:
50-327 and 50-128 License Nos.:
DPR-77 and OPR-79 Facility Name:
Sequoyah 1 and 2 Inspection ConductedL0ctober 28 - November 1, 1985 Ins ectoT,
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Date Signer 1 A proved by: MM m su/
//- /S~~ ff T. E. Conlon, Section Chief Date Signed Plant Systems Section Division of Reactor Safety SUMMARY Scope:
This special, announced inspection involved 38 inspector-hours on site in the areas of the licensee's implementation of their corrective actions associated with the (ppendix R fire protection discrepancies, the review of corrective actions on previously identified NRC items, and inspector followup items.
Results:
No violations or deviations were identified.
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REPORT DETAILS l
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1.
Persons Contacted Licensee Employees
- R. Birchell, Mechanical Engineer
- C. Brimer, Manager, Site Services
- C. Chmielewski, Nuclear Engineer
- D. Cowart, Quality Surveillance Supervisor E. Craig, Mechanical Engineer
- E. Crafgge, Safety Staff Supervisor
- J. Harkleroad, Supervisor, Loss Prevention
- G. Kirk, Compliance Supervisor D. Maxwell, Electrical Engineer
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- J. McCamy, Nuclear Engineer
- L. Nobles, Superintendent (0&E)
- M. Purcell, Mechanical Engineer
- J. Sullivan, Supervisor, Regulatory Engineering
- P. Wallace, Plant Manager
- C Wilson, Nuclear Engineer Other licensee employees contacted included construction craf tsmen, engineers, technicians, operators, mechanics, security force members, and office personnel.
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on November 1,1985, with those persons indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters a.
(Closed) Deviation Item (327/80-10-01), Substandard Fire Protection Administrative Control Procedures NRC guidelines require that fire fighting proplans be established for plant areas where unusual fire fighting conditions exists.
The licensee has established preplans for the following plant areas:
(1) Diesel Generator Building (2) Fuel Oil Storage Tanks (3) Cooling Towers
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(4) Intake Pumping Station (5) Reactor Coolant Pump Motors (6) Main Turbine Oil Tank Unit 1 (7) Main Turbine Oil Tank Unit 2 (8) Cable Spreading Room (9) Unit 1 Auxiliary Instrument Room (10) Unit 2 Auxiliary Instrument Room
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(11) Units 1 and 2 Computer Room i
(12) Emergency Gas Treatment Room (13) Unit 1 Containment Purge Air and Exhaust Filters and fans (14) Unit 2 Containment Purge Air and Exhaust Filters and Fans (15) Train A Auxiliary Building Gas Treatment System (16) Train B Auxiliary Building Gas Treatment System I
(17) Control Building Emergency Cleanup Filters ERCW Pumping Station
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The licensee, by January 1,1986, intends to issue two additional fire fighting preplans, one for the diesel generator building housing, the fif th station diesel and the second preplan will address fire fighting strategies in safety-related pump rooras Based on our review of the unusual fire fighting conditions associated with safety-related plant areas, it appears that the existing preplans along with the proposed additional preplans meets the intent of NRC's guidelines.
However, as plant conditions change, changes to the subject preplans or additional preplans may be required.
This item is closed.
b.
(Closed) Violation Item (327, 328/84-31-03), All Fire Brigade Members Are Not Respirator Qualified The radl* logical hygiene program at Sequoyah Nuclear Plant requires that any employee who plans on entering a bloassay area is required to have successfully completed respirator training, a respirator fit, and to receive a whole body count annually.
Therefore, to maintain
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respirator qualification, an employee must receive a medical reevalua-tion on an annual basis.
PHYSI-13 which governs the qualifications for fire brigade members requires each member to receive a medical examination on an annual basis.
The fire brigade annual medical examination appears to be more extensive than the medical reevaluation required for respirator fit.
However, in order to preclude any additional confusion, the Ilcensee has revised PHYSI-13 to require fire brigade personnel to have their annual medical examination and their respirator fit medical reevalua-tion done simultaneously.
This procedure change should ensure that the l
l fire brigade personnel meet both the health physics criteria identified i
by RCI-11 "Bloassay Program" and the fire brigado medical criteria.
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l Therefore, this item is closed.
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c.
(Closed) Violation Item (327, 328/84-31-04), No Maintenance Program Provided for Fire Protection System Strainers The licensee established an interim strainer maintenance program.
This program was initiated and completed in November 1984.
The interim program inspected and cleaned six strainer assemblies.
According to the licensee, some of the strainer assemblies have been in operation for approximately seven years.
The strainers inspected under this program consisted of the following:
The strainers assemblies for the four headers' entering the reactor building.
- The strainer assembly for the header supplying the Train B ABGTSD charcoal filter housing.
The strainer assembly for the header supplying the Unit 2 contain-ment purge charcoal filter housing.
The total quantity of foreign materials removed from the above strainers was approximately 78 grams.
The licensee has established a fire protection system strainer maintcnance program under Maintenance Instruction MI-6.24.
This program will inspect, maintain, and test the high pressure fire protection system strainers located in the flow paths between the fire pumps and the flow control valves for various sprinkler and water spray system supplying safety related areas.
The strainer program according to the licensee will be performed on an annual basis with the following exceptions:
(1) Those strainers installed immediately upstream of the flow control valves supplying the reactor building water fire suppression systems will be inspected every 18 months or during each refueling outage.
(2) Where fire protection system strainers are provided with either differential pressure switches or gauges, allowing determination of the dif ferential pressure across the strainers, the differen-tial pressure will be determined once every six months in conjunction with sufficient water flow through the strainer to provide an indication of restriction.
Tho licensee's fire protection system strainer inspection program will be in place and the strainers inspected by startup of Unit 1 Cycle 3 refueli ng.
This item is closed.
d.
(Closed) Deviation Item (327, 328/84-31-02), Fire Protection Contain-ment Isolation Valves Are Not Provided With Status Lights in the Main Control Room.
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The licensee considers that high pressure fire protection valves26-240 and 26-243 as primary containment isolation valves.
The licensee contends that valves26-241, 2421, 244, and 245 are secondary containment isolation valves providing isolation for lines which penetrate the shield building into the annulus.
These valves are ASME Section XI, Category A or 8, active valves, and, as such, are stroked-tested on a quarterly basis or after maintenance and/or repair work by performance of Surveillance Instruction-166.1 (SI) or SI-166.6.
This surveillance also verifies the operability of the valve position indication lights on the local control panel.
SI-167 verifies that the valves are in their correct position once every 31 days in accordance with Technical Specification surveillance requirement SR 4.7.11.1.B.
The licensee as a part of their Regulatory Guide 1.97 modifications will provide remote position indication in the main control room for fire protection system valves26-240 and 26-243.
Therefore, this item is closed.
4.
Unresolved Items Unresolved items were not identified during the inspection.
5.
Review of Appendix R Modifications (92703)
Following the NRC Region II July 16-20, 1984, 10 CFR 50, Appendix R inspection of Watts Bar, NRC Region II issued a Confirmation of Action Letter to TVA on August 10, 1984, identifying the actions to be taken by TVA to implement a complete review of the Appendix R program at Sequoyah.
TVA on December 21, 1984, submitted the results of their Sequoyah Appendix R reevaluation to the NRC thus, completing the licensee's Confirmatory Actions Required by the August 10, 1984 Confirmation of Action Letter.
Enclosure 8 to the licensee's December 21, 1984 submi;tal identified the
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scheduler guideline for the implementation of the proposed Appendix R modifications.
In addition, the licensee's Appendix R reevaluation committed to have all Appendix R modifications, except for those modifica-tions associated with the licensee's Appendix R deviation requests, completed by June 30, 1986.
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Therefore, based on the implementation scheduler milestones identified in
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Enclosure 8 to the licensee's December 21, 1984 Appendix R submittal, the scope of this inspection evaluated the licensee performance with regard to i
l implementing the proposed Appendix R modifications.
The following l
Engineering Change Notices (ECN) and their associated Work Plans (WP) were l
reviewed:
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ECN 6311-WP11714 installs the manual remote valve operators for the main steam power separated relief valves.
This modification will be completed prior to start up from the current refueling outage.
b.
ECN 6305-WP11603 installs one hour partial length fire barrier wall on auxiliary building elevation 714'-0" along column line A-8.
This modification will be completed by November 25, 1985.
The inspector, as a part of the review, evaluated the design of the wall and the penetration seals associated with the wall.
Drawing 48W1314-6, Revision 0, stipulates that the wall design will follow the one-hour fire resistive design criteria of Underwriter's Laboratories, Design No. 425.
In addition, Drawing 48W1314-6 specifies that for penetration 1, 2, 3, and 4.
A flexible boot seal configuration (Type XIII) will be utilized as detailed on Drawing 47W472-4, Revision 4.
However, the boot seal detail did not duplicate the design conditions of the fire tested configuration as documented by the vendors January 22, 1982, Fire Test Report.
In addition, the annular area between the wall opening and pipe penetrating the wall for the subject penetrations exceeded the maximum annular area documented by the test report.
The licensee indicated that they would reevaluate the subject penetration seals prior to completing the wall installation and that the subject wall penetration seals would be appropriately fire rated following the design criteria documented by a fire test report.
This will be reviewed during a subsequent NRC inspection, c.
ECN 6311-WP11716 extends the sprinkler protection on Auxiliary Building elevation 669'-0" to add sprinklers inside the assistant operator unit station.
The sprinkler modifications will be completed prior to startup from the current refueling outage, d.
ECN 6308 installed the centrifugal charging pump auxiliary lube oil pump bypass start switches.
This modification was completed July 1, 1985.
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ECN 6209 - WP 11192 has installed one-hour raceway fire barriers on auxiliary building elevations 734'-0" and 690'-0".
In addition, this work plan applied fireproofing material to the 12' by 10' steel floor hatch separating the 2A 480V board room and the B Train 6900V shutdown board room.
The modifications associated with this WP has been completed.
As a part of the WP inspection, a walkdown of the following raceway and hatchway fire barrier assemblies was performed:
(1) On elevation 734-0" in the B Train 6900V shutdown board room conduits 2PP750A, 2PP756A, and 2PP759A are protected by a one-hour fire barrier enclosure from columns A8 to A13.
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(2) On elevation 734'-0" in the A Train 6900V shutdown board room conduits IPP753, IPP762?B, and IPP765B are protected by a one-hour fire barrier enclosure from columns A3 to A8.
(3) On elevation 690'-0" near the component cooling system (CCS) pump area conduits 1PLC4725A and IPL4726A from CCS pump 1A to elevation 714'-0" floor and conduit 1PL4731A from CCS pump 1A to 20 feet west of CCS pump 18 are enclosed in a one-hour fire barrier enclosure.
In addition, conduits 2PL4725A, 2PL4726A, and 2PL4731A are protected by a one-hour fire rated enclosure trom CCS pump 2A to 20 feet west of CCS pump 28.
The fire barrier enclosure for these conduits started three feet below the fire barrier wall separating the A and B CCS pumps.
(4) The 12 floor by 10 foot steel floor hatch separating the 2A 480V board room from the B Train 6900V shutdown board room has been protected with two inches of pyrocrete-241 fireproofing material.
Thus, based on our evaluation, it appears that this thickness of fireproofing material should afford the hatch assembly with a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire rating.
The above fire barrier installations associated with ECN 6209-WP11192 appear to be satisfactory with respect to meeting the one hour fire barrier criteria of Appendix R.
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ECN 6235-WP11520 has installed one hour fire rated raceway fire barrier enclosures on conduits IPP700B, IPP7128, IPP785B, 2PP7008, 2PP7858, 2PP7128, and 2PP50188 on auxiliary building elevation 690'-0" near the CCS pump area.
These conduits are protected from 7 feet west of the Column U wall to 10 feet - one inch north of column A4, then these conduits are protected again starting 14 feet north of Column A5 and continuing to four feet south of column A6.
The above fire barrier installations associated with ECN 6235-WP11520 were field inspected and appear to be satisfactory with respect to meeting the one-hour fire barrier criteria of Appendix R.
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ECN 6235-WP11553 has installed a one-hour fire barrier enclosure on cable trays PO-A, PN-A, and PM-A inside the auxiliary control room on elevation 734'-0".
The cable tray one-hour fire barrier enclosures associated with the subject trays were field inspected and appeared to be satisfactory with respect to meeting the one-hour fire barrier,of Appendix.
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ECN 6319-WP11472 has modified the sprinkler systems associated with the following plant areas:
(1) Auxiliary Building Elevation 734'-0"
A Train 6900V Shutdown Board Room
Personnel and Equipment Access Room Steam Generator Blowdown Room 480V Shutdown Board Room 2A1 (2) Auxiliary Building Elevation 749'-0" 480V Transformer Room 1A 480V Transformer Room 2B Reactor M0V Board Room 2A (3) Auxiliary Building Elevation 759'-0" Unit 1 Control Rod Drive Mechanism Room The inspector performed a walkdown of the sprinkler modifications associated with the above rooms.
Based on this walkdown, it appeared that the modified sprinkler systems compensated for the significant overhead obstructions and that the redesign of these sprinkler system followed the recommended design guidance of NFPA-13.
Within the areas examined, no violations or deviations were identified.
6.
Inspector Followup Items a.
(Closed) Inspector Followup Item (327, 328/84-31-01), Fire Detectors Over The ERCW Pumps Not Included in the Technical Specifications.
As a result of the failure to include the fire detection instruments installed over the ERCW pumps, the licensee, on September 9,1985, has proposed Technical Specification Change No. 119 to the plant operations review committee for approval.
This Technical Specification change will incorporate the fire detection instruments installed over the ERCW pumps into Table 3.3-11.
In addition, this Technical Specification change will delete Table 3.3-11 from Technical Specification Limiting Condition for Operation 3.3.3.8.
Table 3.3-11 which identifies the detector types and their locations will be incorporated into the Final Safety Analysis Report (FSAR).
The licensee indicated that the purpose of this Technical Specification change is to simplify the fire detection Technical Specification and to incorporate additional flexibility in plant design while removing the administrative burden of m
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requiring a Technical Specification change for each design change.
In addition, by incorporating Table 3.3-11 into the FSAR, any change to the table would be subject to 10 CFR 50.59 review.
Therefore, it appears that this change will reduce the potential high level of fire protection / detection system Technical Specification changes and should allow the licensee the flexibility to maintain Table 3.3-11 current with plant conditions.
This item is closed.
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