ML20153F235
| ML20153F235 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 07/22/1988 |
| From: | Conlon T, Ward D, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20153F215 | List: |
| References | |
| 50-321-88-21, 50-366-88-21, NUDOCS 8809070159 | |
| Download: ML20153F235 (13) | |
See also: IR 05000321/1988021
Text
UNITED STATES
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flVCLEAR REGULATORY COMMISSION
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REGION ll
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101 MARIETTA STREET,N.W.
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ATLANTA. GEOROf A 30323
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Peport Nos.: 50-321/88-21 and 50-366/88-21
Licensee: Georgia Power Company
P.-0. Box 4545
Atlanta, GA 30302
Docket Nos.: 50-321 and 50-366
License Nos.: OPR-57 and NPF-5
Facility Name: Hatch 1 and 2
Inspection Conducted: June 20-24, 1988
Inspectors:
k-
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G. R. Wiseman
Date Sfgned
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F. C. Ward
Date Signed
Approved by: (1/D/A
rE&A
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T. E.Agn,lsfi,' Chief
Odt'e Sig~ned
Plan ( Systems Section
Engineering Branch
Division of Reactor Safety
SUMMARY
Scope:
This routine, unannounced inspection was in the areas of fire
protection / prevention and followup on previously identified
inspection findings.
Results: Within the areas inspected, the following violation was identified:
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Failure to Conduct and Document Required Surveillance of the
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Remote Shutdown Panel Halon Suppression System.
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- J. Bennett, Superintendent, Plant Training
R. Bunt, Project Manager, Appendix R
- G. Creighton, Senior Regulatory Specialist
- D. Davis, General Support
- R. Davis, Audit Supervisor
- T. Elton, Administrative Support Supervisor
- P. Fornel, Manager, Maintenance
- G. Goode, Superintendent, General Engineering Support
- J. Lewis, Superintendent, Operations
- D. McAfee, Fire Protection, Engineering Supervisor
- H. Nix, Plant Manager
- T. Portrs, Engineering Manager
- D. Read Plant Support Manager
Other licensee employees contacted during this inspection included
craf tsmen, engineers, operators, mechanics, technicians, and administra-
tive personnel.
NRC Resident Inspector
- R. Musser
- Attended exit interview
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2.
Fire Protection / Prevention Program (64704)
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a.
Fire Prevention / Administrative Control Procedures
The inspectors reviewed the following Fire Prevention / Administrative
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Procedures.
procedure No.
Title
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20AC-ADM-002-05 Rev. 3
Plant Records Management
40AC-ENG-008-05 Rev. O
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42 FP-FPX-005-OS Ret 0
Drill Planning, Critiques, and
Drill Documentation
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Based on this review, it appears that the above procedures meet the
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NRC guidelines of the document entitled "Nuclear Plant Fire
Protection Functional Responsibilities, Administrative Controls, and
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Quality Assurance" dated June 1977.
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The inspectors verified that procedure 40AC-ENG-008-0S included
specific criteria for the establishment of fire watches during repair
and maintenance activities whenever combustible materials are stored
or moved through the non-sprinklered area of the Intake Structure.
This was a special conditional commitment identified in the Hatch
Supplemental Safety Evaluation Report dated January 2, 1987, in
support of an exemption request approval by the NRC.
b.
Fire Protection Surveillance Procedures
The inspectors reviewed the following Fire Protection System
Surveillance procedures:
Procedure No.
Ti tle
42SV-FPX-006-OS (Rev. 0)
Fire Damper Surveillance
42SV-FPX-009-25 (Rev. 1)
Inspection and Testing of the
Halon 1301
Fire
Extinguishing
System, Remote Shutdown Panel
42SV-FPX-013-0S (Rev. 1)
Automatic Fire Door Surveillance
42SV-FPX-023-05 (Rev. 1)
Fire Hose, Hydrostatic Test
Based on this review, it appears that various test outlines and
inspection instructions adequately implement the surveillance
requirements of Appendix B of the plant's Fire Hazards Analysis.
In
addition, it appears that the inspection and test instructions in
the procedures follow general industry fire protection practices, NRC
fire protection program guidelines and the guidelines of the National
Fire Protection Association (NFPA) Fire Codes.
c.
Fire Protection System Surveillance Inspections and Tests
The inspectors reviewed the following surveillance inspection and
test records for the dates indicated:
Procedure No.
Dates
42-FPX-009-25
03/28/87 - 02/10/88
42-SV-L43-001-IS (Fire Doors)
07/19/85, 08/16/85, 08/26/85,
09/14/85, 09/23/85, 12/16/85,
02/26/86
The surveillance test record data associated with the above fire
protection system surveillance test / inspections were found to be
satisfactory with regard to meeting the requirements of Appendix B of
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the plant's Fire Hazards Analysis.
In addition, the inspectors
reviewed the surveillance results associated with procedure
F2SV-FPX-009-25 to ensure the 62 day surveillance of the Unit 2
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remote shutdown panel halon suppression system was conducted within
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the required interval.
This onsite review identified that the
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required documentation was not available in Document Control, to
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indicate the performance of the required surveillance between
03/28/77 and 07/17/87 tests and between 08/19/87 and 11/20/87 tests.
This interval exceeds the maximum interval of 62 days plus 25% of the
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interval or 77.5 days.
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During a subsequent telephone conversation on June 28, 1988, the
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licensee stated that the documentation package for the surveillance
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performed on May 13, 1987, had not been transmitted to Document
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Control but was found in the possession of the Engineering Fire
Protection Group.
The licensee also stated that their review
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indicated no evidence that the required surveillance was performed
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between 08/19/87 and 11/20/87.
Failure to perform this surveillance
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and failure to transmit the May 13, 1987 surveillance package to
Document Control is identified as Violation Item 50-366/88-21-01,
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Failure to Conduct and Document Required Surveillance of the Remote
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Shutdown Panel Halon System,
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d.
Fire Brigade
(1) The total station fire brigade is composed of approximately 73
members from the operations staff.
The on duty shift fire
brigade leader is normally one of the shift supervisors and the
remaining four fire brigade members are composed of plant
equipment operators. The inspectors reviewed the on duty shif ts
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for the following dates and verified that sufficient qualified
fire brigade personnel were on duty to meet the provisions of
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the plant's Technical Specifications:
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06/18/88
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06/19/88
06/20/88
06/21/88
06/22/88
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In addition, the inspectors verified that sufficient personnel
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were assigned to each shift to meet the minimum operating and
fire brigede staff requirements of the Technical Specifications,
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The licensee has recently initiated an informal shift roster
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which is used to designate the-personnel assigned to the fire
brigade and to the minimum shutdown crew.
In reviewing these
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rosters for the day shif ts on 06/18/88, 06/19/88, and 06/20/88,
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the inspectors found that two individuals who were not fire
brigade qualified had signed in on the roster as fire brigade
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members.
These two individuals are Auxiliary Plant
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Operators (AP0s).
AP0s are not presently trained for fire
brigade duty.
Further review of the rosters for the dates
above, identified that additional fire brigade qualified
personnel had also signed in on the roster and that a five man
brigade was available exclusive of the unqualified AP0s.
In
addition, the inspectors found that there is no method of
verifying that only trained individuals sign in as fire brigade
members.
At the beginning of each shift, the fire brigade and
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minimum shutdown crew members sign in on the roster maintained
by the shift supervisor; however, the shif t supervisor does not
have a list of qualified brigade members to compare with the
roster to ensure only qualified personnel are assigned to the
brigade.
For the dates reviewed by the inspectors, the assignment of
unqualified personnel to the brigade is not considered a
violation of plant Technical Specifications since additional
qualified personnel were assigned brigade duty to meet the five
man minimum.
However, the lack of a method of positive
verification that only qualified personnel are assigned brigade
duty is considered a weakness in the implementation of the Fire
Protection Program.
This weakness had been previously
identified as part of Unresolved Item 50-321,366/88-15-02 in
Inspection Report No. 88-15. Based on the inspectors' review of
this unresolved item, it was determined that the licensee was
taking adequate corrective action to eliminate all weaknesses
identified in the item except in the area of controlling fire
brigade assignments. Since none of the weaknesses identified in
the Unresolved item constitute a violation of the licensee's
Technical Specifications or Fire Protection License Condition,
the Unresolved Item 88-15-02 will be closed in this report and a
new Inspector Followup Item, 50-321,366/88-21-02, Failure to
Provide Control of Assignment of Fire Brigade Members, is
identified here to track the weakness in assigning personnel to
the fire brigade.
Based on the review of the duty rosters associated with the
above dates, there was sufficient manpower on duty to meet both
the operational and the fire brigade requirements of the plant's
Technical Specifications.
(2) Training
The inspectors attended a one hour session of the initial 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />
fire brigade training dealing with the use of firefighting foams
on flammable / combustible liquids fires and a two hour session
for fire brigade leaders in which fire ground command and
management were discussed.
The session on the uses of fire fighting foams included a video
tape and a classroom discussion of plant specific foam use. The
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session was well organized and provided adequate information on
the use of fire fighting foams at Plant Hatch.
The training session for fire brigade leaders is the licensee's
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initial implementation of a new fire brigade leadership training
program.
The program was developed in response to an internal
QA audit finding which identified a weakness in the area of fire
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brigade training program.
The training program is set up to be
conducted quarterly and will include the following
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covered over a two year period:
Critical Factor Analysis
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Fire Fighting Systems Model
Time Constraints
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Fire IP,cident Comand
Tactics for Fire Control
General Tactical Principles
Special Hazards Tactics
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The training in the two hour session, in which fire ground
command and management were discussed, provided a good
background in the subject areas; however, the training lacked
plant specific information necessary for an effective leadership
training program for Plant Hatch.
The fire brigade leader
perfomance during the fire drill witnessed during this
inspection and during a previous inspection indicated that
adequate training was not being conducted for brigade leaders.
Therefore, an Inspector Followup Item, 50-321,366/88-21-03,
Followup on the Implementation of Fire Brigade Leadership
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Training, is identified to ensure the implementation of this
training is reviewed in future inspections.
(3)
Fire Brigade Firefighting Strategies
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The inspectors reviewed the following plant firefighting
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strategies:
Pre-Plan No.
Description
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SR-2407
Diesel Generator Room 2C
SR-2404
Diesel Generator Switchgear Room 2E
SR-2402
Diesel Generator Battery Room 2A
SR-2401
Diesel Generator Oil Storage Room 2A
SR-2203F
Unit 2 Reactor Building North CRD Area
SR-2205F
Unit 2 Reactor Building South CRD Area
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SR-0501-IS
River Intake Structure
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Based on this review, the inspectors detemined that the above
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firefighting strategies adequately addressed the fire hazards in
the area, the type of fire extinguishants to be utilized, the
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direction of attack, systems in the room / area to be managed in
order to reduce fire damage, heat sensitive equipment in the
room / area, and specific fire brigade duties with regard to smoke
control and salvage.
(4) Fire Brigade Drill
During this inspection, the inspectors witnessed an unannounced
fire brigade drill.
The drill fire scenario was a fire in a
temporary tent setup on the 130' elevation of the Unit 2 Reactor
Building.
Ten fire brigade members responded to the pending fire emergency
in full protective clothing and self contained breathing
apparatus. The fire brigade advanced two 1-1/2 inch fire attack
hose lines into the area. The hose lines were placed in service
on the fire and the tent fire was placed under control in
approximately 40 minutes.
Fire brigade performance was identified as steadily deteriora-
ting in Inspection Report No. 87-30, Inspector Followup Item
50-321,366/87-30-04.
This trend appeared to have improved only
minimally in the drill witnessed.
The following weaknesses
identified in Inspection Report No. 87-30 still exist:
The brigade leader failed to establish a command post with
adequate comunication.
The brigade leader did not perform a proper sizeup of the
fire situation prior to initiating firefighting activities.
Health Physics personnel did not promptly respond to assist
the fire brigade.
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The primary problem identified was the lack of leadeaship
provided by the fire brigade leader in the drill.
The licensee
has recently initiated a leadership training program for all
fire brigade leaders.
The inspectors feel the successful
implementation of such a training program will eliminate the
deficiencies identified during the two drills previously
witnessed.
The Inspector Followup Item 50-321,366/87-30-04
will remain open pending the NRC witnessing a satisfactory fire
brigade drill.
e.
Review of Appendix R Nonconformances
Through discussions with plant personnel, the inspectors found that
the licensee had recently identified a number of nonconformances from
the requirements of 10 CFR 50 Appendix R for the protection of
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circuits required for plant shutdown.
These nonconformances were
identified through the licensee's review of a number of backlogged
Unit 1 As-Built Notices (ABNs) associated with
the Analog
Transmitter Trip System (ATTS) design change which was completed in
the Spring of 1986.
The nonconformances are identified in a letter
dated June 10,1988 (Log No. REA-8-6-809) from William F. Garner of
Southern Company Services to D. R. Madison of Georgia Power Company.
Included in this letter are recommended actions for eliminating the
nonconformances which include the revision of plant Emergency
Operating Procedures (EOPs) to include additional operator actions or
the installation of fire rated barriers to protect electrical cable.
The inspectors reviewed each of the nonconformances with the site
Fire Protection Engineering Supervisor and the Appendix R Project
Manager from Southern Company Services. This review established that
the licensee had evaluated each of the nonconformances for its effect
on the ability to reach and maintain Unit 1 plant shutdown.
The
licensee's representatives stated that in all cases the consequences
of a fire damaging the unprotected circuits could have L'een mitigated
by:
Corrective actions which would have been implemented through the
plant symptom based E0Ps; or
Availability of redundant systems.
For example, a loss of High
Pressure Core Injection (HPCI) could have been supplemented by
the use of safety relief valves, which are protected, to
depressurize to the point where Low Pressure Core Injection
(LPCI)couldinitiate.
Therefore, the existence of these nonconfermances would not have
prevented Unit 1 from achieving plant shutdown.
The licensee is required by Appendix B of their Fire Hazards Analysis
to submit a special report within 30 days to document the failure to
provide protection for these circuits.
This special report will
include the licensee's evaluation of why failing to protect these
circuits would not have prevented them for achieving safe plant
shutdown.
Upon discovery of the nonconformances the licensee
implemented roving fire watches in the affected fire areas which will
remain in effect until corrective actions have been implemented,
f.
Plant Tour and Inspection of Fire Protection Equipment
(1) Permanent Plant Fire Protection Features
The inspectors conducted a tour of the Diesel Generator Building
and Cable Spreading Room.
The fire / smoke detection systems,
manual fire fighting equipment (i.e., portable extinguishers,
hose stations, etc.) and the fire area boundary walls, floors
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and ceiling were inspected and found to be in service or
functional.
The CO2 system installed in each of the Diesel Generator Rooms
and the Pre-Action sprinkler system protection in the Cable
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Spreading Room were inspected and found to be in service.
The tours of these areas also verified the licensee's
implementation of the fire prevention administrative procedures.
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The control of combustibles and flammable materials, liquids and
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gases, and the general housekeeping were found to be
sa tisfactory,
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(2) Appendix R Fire protection Features
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The inspectors visually inspected the fire rated raceway barrier
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on conduit 2E21601 in Fire Area 0014.
This fire barrier was
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found intact and it appeared that the one hour fire barrier
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integrity has been maintained.
In addition, the inspectors
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visually inspected the three-hour rated raceway fire barriers
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applied to the conduit / raceway bank located in Fire Area 1412
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(Diesel Generator Switchgear Room 1E) which contained the
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following safe shutdown circuits:
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ESA-4
ESA-26
ESA-6
ESA-28
ESA-8
ESA-84
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ESA-10
ESA-86
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ESA-12
ESA-90
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ESA-14
ESA-91
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This fire barrier was found intact and it appeared that the
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three hour barrier integrity was maintained.
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The following eight-hour emergency lighting units were
inspected:
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1A Diesel Generator Room
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1A Diesel Generator Room
1A Diesel Generator Room
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1A Diesel Generator Room
2A Diesel Generator Room
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2A Diesel Generator Room
These units were in service, lamps properly aligned and appeared
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to be properly maintained.
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g.
Response to NRC Information Notice 88-04
On Feburary 5,
1988, the NRC issued Information Notice 88-04,
Inadequate Qualification and Documentation of Fire Barrier
Penetration Seals.
The purpose of the notice was to make licensees
aware that some installed fire barrier penetration seal designs may
not be adequately qualified for the design rating of the penetrated
The licensee's proposed response to the Notice was
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reviewed during this inspection.
The licensee has completed a preliminary evaluation of the concerns
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outlined in the Information Notice and has proposed the following
action to evaluate these concerns as they apply to Plant Hatch.
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Evaluate Plant Hatch's test qualification documentation with
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respect to adequacy and completeness. This evaluation will also
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consider the method of installation or repair used for the fire
barrier penetration seals.
Cross reference the test qualification documentation to each
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specific fire barrier penetration seal (or repairs to that
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specificseal).
Offer resolutions to any problems encountered.
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The licensee has a preliminary completion date of March 1989 for the
cross referencing process.
If the licensee implements the proposed
plan of action described above, the concerns outlined in Infonnation
Notice 88-04 should be adequately evaluated.
In addition, the inspectors attempted to verify that the following
four penetration seals located in the cable spreading room could be
tracked to specific test data which demonstrated the seal was a
qualified three hoitr fire barrier:
H033F
H034F
H068F
H072F
However, the lack of a cross reference between the seal and test data
made the task very cumbersome and the inspectors were unable to
verify the seals were installed in a tested configuration.
The
inspectors noted during this review that at least one of the seals,
H033F, had been modified from the original design detail.
The licensee's implementation of their action plan in response to the
Information Notice will be followed up in a future inspection.
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3.
Action on Previous Inspection Findings
a.
(Closed) IFI 321,366/86-27-02, Proposed Firefighting Strategies /
Preplans Lack Fire Brigade Guidance. The inspectors reviewed the plant
Preplans (Revision 1)datedApril 23, 1987, for the Diesel Generator
Building and Reactor Buildings.
This review determined that
Revision 1 preplans adequately gives the locations of portable
extinguishers for brigade use, addresses management of plant systems
with references to appropriate E0Ps and Abnormal Operating Procedures
(ACPs) located in the control room, gives locations of telephones and
communications systems, and provides guidelines for fire attack
access and command post locations.
These revised preplans appear
adequate to meet NRC guidelines; therefore, this item is closed,
b.
(Closed) Violation 321,366/87-30-02, Failure to Implement Fire
Protection Program Procedures for Documentation of Fire Protection
Activities.
This violation involved two examples of the licensee's
failure to document fire protection activities in accordance with
plant procedures.
Example 1 resulted from the failure of the licensee's staff
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assigned to critique plant fire drills to complete the required
records to document the drill as satisfactory or unsatisfactory.
The licensee's corrective action included the revision of the
plant procedure, 42FP-FPX-005-OS (Rev. 0), for performing plant
fire drills to include the requirement that drill evaluation be
completed and transmitted to Document Control within 30 days.
The inspectors verified that all drill critiques sent to
Document Control for the fourth quarter of 1987 were complete.
Example 2 resulted from the licensee's failure to implement the
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requirements of Administrative Control Procedure 20AC-ADM-002-05
to perform a quarterly records check.
The licensee's corrective action in response to this example was
to revise the administrative procedure to eliminate the
requirement for a quarterly records check since this requirement
was impractical .
The licensee is relying on the responsible
organization to insure the required records are transmitted to
Document Control.
The inspectors verified that Revision 3 of
20AC-ADM-002-OS no longer requires Document Control to perfom a
quarterly records check.
c.
(Closed) Violation 321,366/87-30-03, Failure to Repeat Unsatisfactory
Fire Brigade Drills Within Required Time Period. Orill critiques for
two drills in 1986 and two in 1987 indicated that drill performance
however, a redrill was not conducted within 30
was unsatisfactory; ith plant procedures.
days in accordance w
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The licensee's corrective action in response to this violation was to
conduct six drills in November and December.
Five of these drills
were conducted to meet the requirement for each shift to participate
in an unannounced drill at least once per year.
One of the drills
was a redrill of an unsatisfactory drill. All drills were considered
satisfactory by personnel assigned to critique the brigade
performance.
The inspectors verified that all six drill critiques
had been transmitted to Document Control and the redrill had beer
conducted within the 30 day time limit.
d.
(0 pen) IFI 321,366/87-30-04, Additional Fire Brigade Training and
Drills Required.
During the 87-30 inspection, a fire brigade drill
was witnessed which was unsatisfactory.
During this inspection,
another brigade drill was witnessed which showed only minimal
improvement in brigade performance.
The major deficiency noted
during this inspection resulted from the lack of leadership by the
fire brigade leaders.
The licensee has recently initiated a training
program for brigade leaders which should eliminate these
deficiencies.
This item will remain open pending the NRC witnessing a fire brigade
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drill which eliminates the concerns outlined in report 87-30 and this
report.
e.
(Closed) IFI 321,366/87-30-05, Justification for CO2 Extinguisher
Mountings in the Control Room. The CO2 extinguishers provided in the
control room were mounted on shelves and not secured to prevent
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falling.
The inspectors were concerned that if the CO2 extingui;'ur
was knocked or fell from the shelf it may become a missile in the
control room since they are high pressure cylinders.
The licensee corrected this
3roblem by removing the CO2 fire
extinguishers from the controi room and replacing them w'th halon
type.
The halon fire extinguishers were permanently mounted with
fire extinguisher brackets designed for mounting extinguishers on
vehicles.
These brackets will ensure the extinguishers cannot be
knocked or fall from the shelves.
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f.
(Closed) Unresolved Item 321,366/88-15-02, Apparent Failure to
Complete Required Periodic Fire Brigade Leadership Training.
During
the Hatch Operational Team Assessment, this item wLs identified to
denote weaknesses in the licensee's methods used to control the
coster of qualified fire brigade leaders and members and imprecise
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administrative instructions controlling fire brigade training.
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During this inspection, it was determined that ths licensee wa: taking
adequate corrective action to eliminate all weaknesses identified in
the item except in the area of controlling fire brigade assignments.
Since none of the weaknesses identified in the unresolved item
constitute a violation of the licensee's Technical Specifications or
Fire Protection License Condition, this Unresolved Item is closed. A
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new inspector followJp item is identified in paragraph 2.d of this
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report.
4.
Exit Interview
The inspection scope and results were summarized on An a 24, 1988, with
those persons indicated in paragraph 1.
The inspectors described the
areas inspected and discussed in detail the inspection results listed
below.
Proprietary infonnation is not contained in this report.
Dissenting coments were not received from the licensee.
Item Number
Description and Reference
366/88-21-01
Violation - Failure to Conduct and Document
Required Surveillance of the Remote Shutdown
Panel Halon Suppression System
221,366/88-21-02
Inspector Followup Item (IFI) - Failure to
Provide Control of Assignment of Fire Brigade
Members
321,366/88-21-03
Inspector Followup Item (IFI) - Followup on
the Implementation of Fire Brigade Leadership
Training
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