IR 05000317/1988006

Insp Repts 50-317/88-06 & 50-318/88-07 on 880314-18.No Violations Noted.Major Areas Inspected:Fire Protection/ Prevention Program,Including Program Administration & Organization & Administrative Control of Combustibles

ML20151X652
Person / Time
Site:	Calvert Cliffs
Issue date:	04/15/1988
From:	Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151X645	List: IR 05000317/1988006 ML20151X641
References
50-317-88-06, 50-317-88-6, 50-318-88-07, 50-318-88-7, GL-82-21, NUDOCS 8805040216
Download: ML20151X652 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No /88-06; 50-318/88-07 Docket No ; 50-318 License No. DPR-53; DPR-69 Category C Licensee: Baltimore Gas and Electric Company P. O. Box 1475 Baltimore, Maryland 21203 Facility Name: Calvert Cliffs Nuclear Generating Station Units 1 and 2 Inspection At: Lusby, Maryland Inspection Conducted: March 14-18, 1938

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t 8 Inspectors: _A. rasopoul'os, Reactor Engineer

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dat Approved by: Y' i fI ETAnderson, Chief, Plant Systems Section date Inspection Summary: Insjection on March 14-18, 1988 (Combined Report N /88-06 and 50-318/88-07)

Areas Inspected: Routine unannounced inspection of the Fire Protection / Pre- ,

vention Program including: program administration and organization; admini- !

strative control of combustibles; administrative control of ignition sources; i other administrative controls; equipment maintenance, inspection and tests; !

fire brigade training; periodic inspections and quality assurance audits; and !

facility tour '

Results: No violations were identified, however, the inspection determined that: the knowledge of the Fire Protection Program is fragmented with no one !

on site in control of the entire Fire Protection Program (Section 2.1); the i housekeeping and combustible control programs needed to be improved (Section 2.2); the use of the insurance auditors performing Fire Protection program l audits will be accepted if these audits are performed to directly address the '

Technical Specification requirements (Section 3.7); the management of the Fire Protection program needs to be centralized to avoid weakening of the fire program )

PDR ADOCK 05000317 Q DCD

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DETAILS

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1.0 Persons Contacted  :

1.1 Baltimore Gas & Electric (BG&E)  !

• R. P. Heibel, General Superintendent Operations

• D Shaw, Licensing Engineer

• J. Wood, QA Engineer

• Buffington, Fire Protection Specialist

• McVicker, Electrical Analysis

• Sebra, Principal Engineer

• Katz, Design Engineer Supervisor

• Anije, Supervisor QA .

• Freeland, Supervisor Safety & Fire Protection  :

1.2 Nuclear Regulatory Commission (NRC)  :

• 0. Trimble, SR Resident Inspector

"Denotes those present at the .txit intervie !

2.0 Fire Protection / Prevention Program The inspector reviewed several documents in the following areas of the program to verify that the licensee had developed and implemented adequate i procedures consistent with the Fire Hazard Aralysis (FHA), Final Safety Analysis Report (FSAR), and Technical Specifications (TS). The documents

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reviewed, the scope of review, and the inspection findings for each area of sne program are described in the following section .1 Program Administration and Organization The inspector reviewed the following licensee documents: !

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Technical Specification, Section 6, Administrative Controls i

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Calvert Cliffs Fire Protection Program Plan, Calvert Cliffs Instruction, CCI-133 H Section II The scope of review was to ascertain that: Personnel were designated for implementing the program at site; and Qualifications were delineated for personnel designated to implement the progra The inspector in addition to reviewing the program procedures, interviewed plant personnel responsible for the implementation of the !

program, to determine whether they are cognizant of the responsi-bilities. During the interviews, the inspector detected that l

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!' no one on site is knowledgeable in all aspects of the Fire Protection 1 Progra The determination was made when the inspector asked questions ;

concerning the operation of the Fire Protection features in the cable '

spreading and switchgear rooms. The final answer was derived from answers received from four different licensee site organizations and a field walkdown. No one on site knew how the Fire Protection systems would interact. Central knowledge of how the Fire Protection systems work is essential for efficient and effective fire fighting activities.

The licensee was appraised of this concern and agreed to address i .2 Administrative Control of Combustibles ,

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The inspector reviewed the following licensee document:

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Calvert Cliffs Fire Protection Program Plan Section V ,

The scope of review was to verify that the licensee had developed administrative controls which included: Special authorization for the use of combustible, flammable or explosive hazardous material in safety-related areas; I Prohibition on the storage of combustible, flammable or explosive hazardous material in safety-related areas; l

- The removal of all wastes, debris, rags, oil spills or other combustible materials resulting from the work activity or at the end of each work shift whichever is sooner;

All wood used in safety-related areas to be treated with flame retardant;  !

f Periodic inspection for accumulation of combustibles;  ! Transient combustibles to be restricted and controlled in j safety-related areas; and I Housekeeping to be properly maintainet in areas containing i safety-related equipment and componenti.

j Observations by the inspector of housekeeping practices such as the introduction of a wooden pallet in a safety related building, despite procedures to the contrary, the observation of oil leakages around the turbine that are allowed to accumulate and the lack of procedures governing the amount of flammables allowed in safety related building l indicate that increased management attention is warranted. With !

regard to this concern, the inspector observed that a plant worker i brought in the auxiliary building a 5 gallon can containing kerosene l but marked gasoline to be used as diesel fuel. When storing or

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dispensing flammable liquids a container appropriate for the type of j liquid should be used and be clearly labele I

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If any gasoline was present in the gas can, the mixture of kerosene /

gasoline as fuel could present.an explosion hazard. .The inspector-expressed his concerns about the housekeeping.and-combustible control program and interviewed plant personnel.concerning housekeeping practices to verify whether these observations were isolated incide'nts i or.an established practice. The 1nspector after..the interviews concluded that housekeeping and combustible control practices are not strictly enforced especially when dealing with licensee' plant-personne The inspector also concluded that there was a lack of a program to verify the housekeeping status and make upgrades if required.- These concerns were presented to the licensee management during the exit'

interview. The licensee agreed to review the concern and/ investigate the.cause ,3 Administrative Control of Ignition Sources The inspector reviewed the following licensee document:

Calvert Cliffs, Fire Protection Progrrm Plan, Calvert Cliffs,- '

Instruction CCI-133H,Section VI The scope of review was to verify that the licensee had developed administrative controls which included: , Requirements for special authorization (work permit) for '

activities involving walding, cutting, grinding, open flame or :

other ignition sources and that they are properly safeguarded-in l

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areas containing safety-related equipment and components; and Prohibition on smoking in safety-related areas, except.where

"smoking permitted" areas had been specifically designated by plant managemen No unacceptable conditions were identifie .4 Other Administrative Controls The inspector ~1 viewed.the following licensee documents: )

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Technical Specifications, Section 6, Administrative Controls

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Calvart Cliffs Fire Protection Plan, CCI-133H The scope of review was to verify that.the licensee had developed administrative controls which require that: Work author' cation, construction permit or similar arrangement is provided cor review and approval of modification, construction and maintenance activities which could adversely affect the safety of the facility;

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w 5 Fire brigade organization and qualifications of brigade members are delineated: Fire reporting instructions for general plant personnel and developed; Periodic sudits are to be conducted on the entire fire

_ protection program; and Fire protection / prevention program is included in the licensee's QA Progra No unacceptable conditions were identified, 2.5 Equipment Maintenance, Inspection and Tests The inspector reviewed the following randomly selected documents to determine whether the licensee had developed adequate procedures which established maintenance, inspection, and testing requirements for the plant fire protection equipment: )

'M-76-0 Staggered Test of Electric Fire Pump ,

• M-77-0 Staggered Test of Diesel Fire Pump '

• M-592-1 Penetration Fire 3arrier Inspection

• M-694-0 Inspection & Hydrostatic Test of Fire Hoses Outside Containment M-695-0 Inspection & Rerack of Fire Hoses Outside Containment

• M-696-0 Fire Pump Flow Test

• M-697-0 Fire Suppression System Functional Test ,

• M-699-2 Simulate Actuation of Halon System

• M-491-0 Fire Detection Instruments (Heat) l l

Functional Tests  !

• M-494-0 Protectowire Functional Test

• M-190-0 Fire Pump 24 Volt Battery

• 0-34-0 Fuel Oil Sampling Quarterly Test

• 0-89-0 Fire Suppression System Weekly Check

• M-21-0 Fire Pump Diese~i Inspection  !

I In addition to reviewing the above documents, the inspector reviewed the maintenance / inspection / test records of the items marked with an asterisk to verify compliance with Technical Specifications and I established procedure ,

No unacceptable conditions were identifie .6 Fire Brigade Training

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6-2. Procedure Review

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The inspector reviewed the following licensee procedures:

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Fire Protectio'n Program Plan, CCI133 Section 4'.

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The scope of review was'to verify that the licensee had developed administrative procedures which included: ,

' Requirements.for' announced and unannounced drills: Requirements for fire brigade training and retraining at~

prescribed frequencies; Requirements for at least one drill p'eriyear to be -;

performed on. a "back shift" for each brigade; Requirements for maintenance of training record '

No unacceptable conditions were identifie ,

2. Records Revie The inspector reviewed training records of fire brigade members

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for calendar years 1987 and 1988 to ascertain that they had attended.the required quarterly training and participated. in a quarterly drill, and received the annual hands-on fire-extinguishment practic No unacceptable conditions were ' identifie .7 Periodic Inspections and Quality dssurance Audits '

The licensee is required to perform three types of audits of the Fire j Protection Progra ;

One audit every 24 months per T.S.6.5.2.8.1.h and one audit every 12 months per T.3.6.5.2.8.7.1. In addition, T.S.6.5.2.8.1.j requires that  !

the program be audited by'an outside consultant every 36 month .

Guidances for the performance of these audits was issued to all licensee's in Generic Letter 82-21. The licensee's QA auditors i review the Fire Protection Program annually and incorporate the requirements of the annual and biennial audits into a single audi The. inspector reviewed audit Nos. 86-06 and 87-10 and found them.

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However, in the review of the audit contained in QA Surveillance Report S-87-18 performed to satisfy T.S.6.5.2.8.1.J requiring the involvement of an outside consultant the inspector' observed that, the review of.the audit / surveillance determined, that although thr elements of regulatory importance'were examined by.the auditors, the audit was performed for insurance purposes by the licensee's insurer (American Nuclear Insurers). It was not performed to explicitl satisfy the Technical Specification requirements for' fire protection audits. The inspector also observed that some of the audit observations were not properly addressed in that the responses'were tardy. The licensee stated that the audit observations were not.in. safety related ,

area They were for insurance purpose That. is- the ~ reason for not responding to the audit findings in a timely manner. The licensee, stated that future Fire Protection Program' audits will be performed to explicitly address the. tachnical specification requirements. This '

fact will be stated in future consultants audit reports.

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2.8 Facility Tour The inspector examined fire protection water systems, including fire pumps, fire water piping and distribution systems, post indicator valves, hydrants and contents of hose houses. The inspector toured accessible vital and non-vital plaot areas and examined fire detection and alarm systems, automatic and manual fixed suppression- ,

systems, interior hose stations, fire barrier penet' tion seals, and

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fire doors. The inspector observed general plant housekeeping conditions and randomly checked tags of portable extinguishers for evidence of periodic inspections. No deterioration of equipment was noted. The inspection tags attached to extinguishers indicated that mor.thly inspections were performed. With the exception of the deficiencies identified in other sections of this report no other unacceptable conditions were identifie .0 Exit Interview 1 The inspector met with licensee management representatives (see_Section *

l 1.0 for attendees)'at the conclusion of the inspection on March 18, 198 l The inspector summarized the scope and findings of the' inspection at that time. The inspector also confirmed with the licensee that the report wil?

not contain any proprietary informatio ,

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The licen'see agreed that the '

inspection report may be placed in the Public Document Room without~ prior licensee review for proprietary information. (10 CFR 2.790).

At no time during this inspection was written material provided to the licensee by the inspectv .  ;

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