ML20205S434
| ML20205S434 | |
| Person / Time | |
|---|---|
| Issue date: | 02/18/1983 |
| From: | Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20205S388 | List: |
| References | |
| FOIA-88-344 NUDOCS 8811110066 | |
| Download: ML20205S434 (2) | |
Text
._
a 0 UNITED : TATE:
- v "88
. # I*,, NUCLEAR REGULATORY COMMISSION
- E' g anoson lll
.- .a too moossvsLT meAo otsN sLLyu, stuwois soin
(
FEB 181983 NEMORANDUM FOR: W. S. Little, Chief. Engineering Programs Branch FROH C. C. Williams, Chief, Plant Systems Section i
SUBJECT:
SURVEILLANCE TESTING OF FIRE PUMPS - INCOMPATABILITY OF TECHNICAL SPECIFICATION AND NFPA-20 REQUIREMENTS Region III inspectorc have identified a number of instances wherein it appears that the Technical Specification requirements for Testing of Fire Pumps does not meet the minimum requirements of the specified code, NFPA
- 20. Instruction and clarification is needed by both Region III and the licensees regarding the intent and requirements for fire pump testing.
This issue was previously discussed with NRR fire protection statf during a meeting with Region III on December 3,1982 (see attachment 6).
To meet the fire protection requirements of 10 CFR 50, Appendix A, General Design Criterion 3, licensee's commit to install fire protection systems
(, in accordance with Appendix A to NRR Branch Technical Position (BTP) APCSB 9.5.1., which states, in part, "Details of the fire pump installation should as a minimum conform to National Fire Protection Association Code-20 (NFPA 20)."
It is our interpretation and position that NFPA-20 requires measurement of the following hydraulic performance parameters during installation and annual fire pump tests
- a. Shut off head with no flow (120 percent or 140 percent of total rated head).
- b. Overload or peak load condition (150 percent of rated capacity or more at 65 percent of rated head).
- c. A convenient rate of flow at or near capacity rating.
Measurement of other pump performance parameters, some of which are directly proportional to fire pump flow capacities are also required by NFPA-20 during annual fire pump capacity tasts. For example:
- a. Direction of rotation of the pump and the speed of operation (RPM's).
- b. Suction inlet and pump discharge pressures (net pressure). .
- c. Voltage and current limitations for motors and auxillary equipment.
- d. Comparison of test results to the manufacturer's certified shop test curve, name plate design parameters and original acceptance test results to determine fire pumps ability to continue to attain satis-( factory field performance at peak loads.
0011110066 001013 bE ~
,o . ;
O W. S. Little FEB 1 b 1983 q
(.
- In each instance examined in Region III, the Technical Specification re- l quirement for fire pump testing does not appear to meet or include our interpretation of the requirements of NFTA-20.
The technical specifications for Point Beach, Big Rock Point, Callaway, Duane Arnold, Kawaunes and Monticello for example, vary in specificity with respect to the frequency of fire pump testing and the required flow capacities. None of these technical specifications require testing in accordance with our interpretation of NFPA 20, although it is the reference code. Typically, technical specification *;equiremento are that "Fire pumps shall be operable at rated capaci.y; a specific flow or a specific flow and pressure." This has resulted in licenses annual fire pump cap-acity tests that measure only pump discharge pressures and flow rates to a flow less than required by NFPA 20.
The significance and potential generic impact of this issue is that licensee's failure to adequately test fire pumps and their essential design parameters ao required by the governing code NFPA-20, is due to the apparent inconsistancy between technical specification requirements and NFPA-20. Thus, test performance and results unacceptable to the re-quirements of NyPA-20 are used to satisfy technical specification requirements.
for the operability of fire pumps. Moreove.;, in most instances the test parameters specified in the subject technical specifications are apparently not capable of establishing the operability of the fire pumps as defined
{ by NFPA-20.
S s e e 9: # f% -
C. C. Williams, Chief Plant Systems Section Attachments:
- 1. Point Beach Inspection Report (Partial)
- 2. Calle.'ay Inspection Report (Partial)
- 3. NFPA Response Letter
- 4. Manufacturers Pump Data-Point Beach
- 5. Point Beach Annual Pump Teat Data
- 6. Williams /Terguson memo dated 1/4/83
+ _ - - - - - - - -
6
- /k?q13Mr
- %g UNITO gTATES /
a
! NUCLEAR REZULATGRY COMMISSIOfw i REGION til 7ee noossysLT poAn
'.,' 1 k etsw sLLym.iLLusois som g seee*
( (enc Losus.g W~ kesoAA** vons re
.* u c e~se A,spons hvae.so~* &
NOV 3 01982 1
Docket No. 50-266 Docket No. 50-301 ;
Wisconsin Electric Power Company 1 A'ITN: Mr. Sol Burstein Executive Vice President Power Plants 231 West Michigan Milwaukee, WI 53201 This refers to the routine safety inspection conducted by Messrs. C. Ramsey, J. U11e and J. Grobe of this office on June 28 through July 1, and July 8, 1982, of activities at Point Beach Nuclear Plant, Units 1 and 2, authorized by NRC Operating Licenses No. DPR-24 and No. DPR-27 and to the discussion of our findings with Mr. Glenn Reed at the conclusion of the inspection on July 7, 1982.
The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective ,
examination of procedures and representative records, observations, and '
interviews with personnel, i During this inspection, certain of your activities appeared to be in non- ,
compliance with NRC requirements, as specified in the enclosed Appendix. 1 A written response is required. )
Other issues, specified as unresolved items in the enclosed report, raised questions concerning the integrity of fire doors, the adequacy of quality assurance audits and the acceptability of portable fire extinguisher com-ponents. In addition to responding to the specific items of noncompliance, please describe your actions or plans to resolve these items.
We have concluded that no particular finding resulting from this inspection was of such significance to warrant further enforcement action at this time.
However, we are concerned that the broad scope of noncompliances, when viewed in total perspective, indicate that management has not been adequately l effective in implementing the facility fire protection program. Specifically, (1) there were no acceptance criteria to determine satisfactory completion of fire protection systems surveillance testing; (2) fire protection systems surveillance testing procedures were inadequate; and (3) fire protection
j Appendix l
k !
NOTICE OF VIOI.ATION 1 l
Wisconsin Electric Power Company Docket No. 50-266 l Docket No. 50-301 As a result of the inspection conducted on June 28 through July 1, and July 8,1982, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982), the following violations were identified:
- 1. Technical Specification 15.4.15 requires periodic inspection and testing of fire protection equipment to verify operability. 10 CFR 50 Appendix B, Criterion XI, requires establishment of a test program that assures all testing required to demonstrate structures, systems and components will perform satisfactorily in service, in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Test results are required to be documented and evaluated to assure that test requirements have been satisfied.
Contrary to the above:
- a. The following surveillance testing procedures reviewed for the
( period January 1980 through June 1982 did not incorporate all the established requirements in applicablaa design documents to assure operability of fire protection structures, systems and components.
(1) 75-19, "Annual Fire Pump Capacity Test", did not include testing the pumps at maximum peak loads of 150% of rated -
capacity at 65*. of rated head, and 140% of rated shut off head. Data necessary to assess pump performance such as revolutions per minute suction pressure and current flow (where applicable) were not included in fire pump testing i procedures.
(2) TS 16 "Bi-Monthly Fire Detector Testing", did not include measurement of the detector sensitivity and demonstration of alarm actuation on local annunciators or in the control room.
(3) There was no surveillar.ce testing / inspection procedure i established to assure operability of fire doors protecting safety related areas. .
l l
i
~ . .
7 Appendix 2 .
k
- b. There were no acceptance criteria for determining satisfactory completion of T3-7, Monthly Diesel Fire Pump Fan:tional Test.
TS-16, 31-Honthly Tire Detector Test, or TS-19, Annual Fire Pump Capacity Tast. In the absence of such acceptance criteria it can.not be clearly ascertained that the data documented from test results demonstrates acceptable performance or operability of these fire protection systema.
This is a Severity Level IV violation (Supplement I.D.2).
- 2. Technical Specification 15.3.14 states in pas i, "All penetration fire barriers protecting safety related areas shall be functional.
l' In the event of a penetration barrier impairment a continuous fire watch shall be established on at least one side of the affected penetration barrier within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />."
Contrary to the above, on June 28, 1982, the inspectors observed the west three hour rated fire door between diesel generator rooms 3D and 4D stuck in the open position. There was no fire watch in.
of' fact on either side of the nonfunctional fire door.
This is a Severity Level IV violation (Supplement I.D,2).
- 3. Technical Specification 15.6.8.1.8 for Units.1 and 2 states in part, C "The plant shall be operated and maintained in accordance with approved procedures ... for the following operations where these operations involve nuclear safety of the plant ... fire protection implementation."
Contrary to the above, there were seven examples of inadequate or nonexistant fire protection program implementing procedures and three examples of not following approved procedures:
- a. The fire protection program requires all plant contractor per-sonnel be indoctrinated in fire protection administrative controls.
There is no procedure governing contractor fire protection training and this training in the areas of combustible materials controls J and transient fire load controls was not being accomplished. l
- b. The fire protection program requires the instruction of personnel on the handling of leaks or spills of flammable materials. There is no procedure concerning personnel fire protection training in the hand'ing cf flammable material leaks or spills and this training is not beim3 accomplished. ,
l i
l 1
l l
i
- w. v
\, .
M Number Revision Date Title
( TS-19 Major 3/1/78 Annual Fire Pump Capacity Test TS-20 Major 8/26/80 Annual Tire System Automatic System and Valve Actuation TS-25 Major 11/20/80 Alara Valve Test and Drain Test TS-26 Major 10/10/81 Fire Main Flow Test (2) Plant Tours The inspectors examined fire protection systees an a equipment configurations and operability during tours of the following areas:
Turbine Buildings Auxiliary Building Facade Pump House Plant Yard
- b. Findings (1) Noncompliance (50-266/82-17-01A; 50-301/82-17-01A): Fire l'
Pump Testing.
Section 5.2.3.2 of the Point Beach Nuclear Power Plant Fire Protection Review, dated June 20, 1977 states in part, "The fire pumps were installed to meet the requiraments of NFPA 20."
Section 4.1 of NTPA 20 (1976) states in part, "Pumps shall furnish not less than 150 percent of the rated capacity at a total head of not less than 65 percent of the total rated head. The total shutoff head shall not exceed 140 percent of the total rated head for end suction pumps." Section 6.5
. and 8.2 of NTPA 20 (1976) concerning electric motors for fire pumps specifies motor rating requirements for horsepower output, revolutions per minute at full load, voltage, and full load current. Section 12, specifies acceptance, operations and maintenance criterions for fire pumps, field acceptance and yearly tests are described in part as "A yearly test shall be made at full capacity and over to rake sure that neither pump nor suction pipe is obstructed. The field acceptanes test hal; be as good as the manufa'eturer's certified shop test chai acteristic curve for the pump being tested within the accu: acy limits of the test aquipsant. For electric I .
3
2 J
a
.$ 9 L' motors at rated voltage. The full load aspete rating shall i - not be exceeds 3 under any conditions of pump load. The
( voltage at the motor should not very more than five percent below or 10 percent above rated voltage during the test. The l operating pump speed shall be the speed at which the pumping <
unit would be expected to operate during a fire. The suction inlet sage as well as the discharge pressure sage shall be read occasionally to see that the inlet is not obstructed by a choked screen or foot valve." {
"che Basis for Technical Specification 15.4.15 states in part, l "The National Fire Protection Association and the plant in- ;
surance carrier have specified periodic tests and inspections to demonstrate fire protection equipeent operability. The listed tests and inspection include and exceed the requirements of these organizations."
l Contrary to the above, the testing procedures in the licensee's annual fire pump capacity tests. 75-19, for the years 1978, i 1979, 1980 and 1981 did not include, as a sinisua, the require-3 sents specified in NTPA 20. The data collected during the test (discharge pressure and pitot readings) was not adequate data to ensure operability and demonstrate performance charac- ;
teristics of the pumps in accordance with the original manu-t facturer's design specifications and NTPA 20. Design points '
such as pump not discharge pressure, engine speed (RPM) asperes (current) at condition. of pump load and churn pressore (shut off head) were not included ir. any of the test results reviewed.
{
Therefore, it was not possible to compare pump speed and horse-power to the manufacturer's design specifications.
Review of the results from test conducted show inconsistent pump performance from 1978 to 1981. n e test conducted were not run to 150 percent of rated capacity at 65 percent of l rated head. However, test results of 13C/1 of rated capacity j j at 69.7% of rated head in 1978; 129.9*. of rated capacity at ,
80.9% of rated head in 1979; 124.2'. of rated capacity at 76%
i or rated head in 1980; and 128% of rated capacity at 88.9% l
~
of rated head in 1981, indicate mechanical malfunctions may <
) be occurring during pump performance. l This is a violation of Technical Specification 15.4.15 and 10 CTR 50, Appendix 3, Criterion XI. i (2) Noncompliance (50 266/82 17-013; 50-301/82 17-013): Fire l Signalling System Testing.
l' The Point Beach Nuclear Power Plant fire protection system includes a fire signiling system which trantaits fire ind'i- '
, cating alarms and supervisory trouble alarms to the control !
- room where they are annunciated at the fire panel. The !
- signalling system transmits indications and alarus for water i . ( -
, 1 i
l 4
4
o g
(
WISCONSIN Elecinc m coumr 231 E. MICHIGAN, P.O. BOK 2044. MILWAUREE. WI $3201 January 21, 1983 Mr. J. G. Keppler, Regional Administrator Office of Inspection and Enforcement, Region III U. S. NUCLEAR REGULATORY COMMISSION 799 Roosevelt Road G11n Ellyn, Illinois 60137
Dear Mr. Keppler:
DOCKET NOS. 50-266 AND 50-301 REPLY TO INSPECTION REPORT NOS. 50-266/82-17 AND 50-301/82-17 POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 Enclosed is our response to Inspection Report Nos.
50-266/82-17 and 50-301/82-17 which were forwarded by letter
- ( dated November 30, 1982.
As noted in the attached discussion of each item, we disagree with some of the findings and provide the basis for our position. We concur with some Items of Noncompliancc; for these items we have stated corrective action to be taken, corrective steps taken to avoid further items of noncompliance, and dates when action will be completed In addition, we plan to undertake further action in areas where we believe violautons or noncompliances did not occur but where such actions woulf. enaance ou.: fire protection program.
Some of the findings appear to resu) 4.;: u +13 inability to produce documentation at the time of the 1: spuem which was subsequently determined to be available. We atc v- g action related to the management of the fire protection program in the plant which we believe will minimize such problems in the future.
Very truly yours,
$V j
(
@M/-7hEhh[
C. W. Fay A vicepresident-Nhlearpower Enclosures JAN 241983 !
Copy to NRC Resident Inspector l
t .
I ~ ,
- . e .
s
! +
RESPONSE TO INSPECTION REPORT NOS.
j ,
50-266/82-17 (DETP) AND 50-301/_J2-17 (DETP) i t
k violation 1, Item a (1)
Woncompliaree 2.b(1) (82-17-OLA, Fire Pump Testine) l l .'
- We do not agree with the NRC opinion that' Violation 1,
i
- Item a(1), is a violation of Technical specification 15.4.15 or 10 CFR 50, Appendix E, criterion XI. With respect to !
l Noncomp1Aance 82-17-OlA, we da not concur with the NRC opinion that our tests have not met National Fire Protection Association '
(NTPA) standards. Further, we feel the test results indicate adequate purg performance rather than mechanical malfunction.
{. ;
) Technical specification test TS-19, "Annual Fire Pump Capacity i j Test", does not need to measuas the performance parameters '
stated 'n violation 1, Item a (1), or Noncompliance 82-17-01A d
to comp y with the NFPA standards for annual performance testing. ,
i l
NFPA (1976), Chapter 11, Section 6.2, entitled "Field Acceptance !
Test", states it. part "Upon completion of the entire fire pump !
installation, an operating test shall be made...All applicable i 4 provisions o* 12-1 shall be followed." NFPA fl976), Chapter 12, l j 8ectica 1. is entitled "Field Acceptance Test'. This term is ;
i onderstood to mean a test performed following initial installation i j . of a pump to ensure acceptability. Our understanding is reinforcedi
(- by NFPA 20 (1976), Chapter 12, section 11, which states "The l l pump manufanturer shall have an engineer present at the field ;
t acceptance tests wnen requested by the installing contractor."
i Additional substantiation of the intent of Field Acceptance l I Test is obtained from NFPA 20 (1980) , Chapter 11, Section 2.1, i
- , which states "The acceptance test of the pump installation shall l 3
be the responsibility of the installing contractor. Field acceptance test of the entire fire pump assembly shall be performedl l by the pump manufacturer or his qualified representative prior !
i to acceptance of the installation by the owner." The licensee .
[ agrees that all the pump operating parameters discussed in f Noncompliance 82-17-01A are applicable to the Field Acceptance !
i Test, however, the licensee does not agree that all these i performance test paraneters nsed apply to periedic performance i j tests performed on a routine basis. ,
The intent of our annual test has been to demonstrate pump !
) _ capacities 'rq acceptable. Thus, we believe that the appropriate !
- code is NFF; 'O '1976), Chapter 12, Section 3.1, entitled i "Yearly Ter U does ot state any specific test performance i i parameters to av obtatn;d txcept "A yearly test shall be made i g at full cape and otin c aake sure neither pump nor su-tion '
a B.
pipe is ob.,d +4 N (1980), Chapter 11, section 3.1, l under tho , : . . ,ax Puup ia9ts". states "An annual teht of the fir; pis 4 - ,. .
ttall be performed to determine its f
s, ability to ec .> 1;.n entisfactory performance at peak i loads." j i
I i-i i .
1 . -. - - - . - . - ... - . . . . . _ . .. . - .
d It appears that thn NRC may be applying the Field Acceptance
( Test requirement in this violation rather than the more appropriate annual test requirement.
Included in Attachment 2 are pump curves for the plant fire pumps. These curves shew the manufacturer's curves, ASME section XI pump performance limits (using the manufacturer's curves as baseline), and actual test data for 1978, 1979, 1980, 1981, and 1982. Of the 36 data points taken, only three fell outside the ASME limits and in directions which indicate no particular trend. Significant indication does not exist to suspect mechanical malfunction of the fire pumps or to believe they would not perform at 150% rated capacity.
We wish to point out that our pump capacity test, as presently performed, utilizes our fire system test facilities to their maximum capacity. It is impossible to generate test flows greater than those now attained with our existing test facilities. In addition, our highest flow test points are ,
greater than the largest single expected fire flow qiven in '
the Fire Hazards Analysis.
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE Although we believe test TS-19 to be adequate, we will revise the test to include additional performance data. This
( is consistant with our policy to make changes which ue believe will enhance our operation. Additional data to be collected will be measured suction lift, diesel pump shutoff pressure, diesel engine speed, and electric pump motor current draw.
An additional section specifying proper analysis techniques will be included. Appropriate changes to TS-19 will be made by January 31, 1983.
Noncompliance _2.b (2) (82-17-01B, Fire Signalling System Testing)_
l We nowledge that TS-7 (Monthly Diesel Fire Pump F l Test) , -17 (Annual Testing of Diesel Room Spr er Valves),
TS-19 (Annu 1 Fire Fire Pump Capacity Test d'TS-26 (Fire 1 Main Flow TestT'd not explicitly inco ate documented
, verification of ala annunciation. -
N W6 disagree, however, wit). an tarpretation of 10 CFR 50, Appendia B, criterion XI, t it is always required to test annunciation actuation. Ariterion XI states in part "A test program shall be est brashed to assure ,that all testing required to demonstrate t structures, systems', and components will perform satis orily in service. . ." For systems and equipment whose sin ar intent is to generate slarms the of course, alarm uniciation must be. verified. Hewever, fo ystems
( and uipment which generate alarm annunciation subsequent to l
' \
-- - - - , , - - , - , , , , , o -- - , . - -
- 1. . . . ;
.. 3 . .. .
- : n. . :. .:
.,,, 3. g . . .- .
. . g s 1.
- e. G. u,a
. . ., ... . - .. I : . 3, e
- r. g_ *I" .
. 1 ...;..._... . . . . . . .
. ~. l )
s .e 4. c . 3 . . m a @-.:r. .. . - . : . ...:_. . .._. ... _, ..e;. . .
.s
. . -. -.s. . .. . : . . . .. . .: '
.C n. ; a wl ., 3 .e%. y..e
. . . - _ :.__- . ..w:
- :.j . 1.. 9.: i. .:: .: :l. i; f . :,. 0004 p.9 : _
j . '. . .: : .: :.:_ .: ... :.* .;
. .i..-e,z *M.:,,_.s*y f.3 ss. ,
4 _.:: --,.:.:_a .... .=,._....:....
.. w.,- 1 u w . . r. . s,..
- s
- . .i- ...
-;., u.:..g . %.
i.,:- g}.
u . ~.~. g a, . .
- . .s: . .: . ..::: ; ::
, i
- ,.;.,.=..- .: .
. . . c. i . . 5 - . = . s. : j . . s. . m,. . . - 1 n : k. . .
- .=. .. : ,~- c . .-, ;
w n .
.e
- + . . s. '.
,o. n
.~
. "u e--
...-.R. '
- a' .
... ~.m- P a
oy e- 4
- n. s.,
6....
... , J. s, ;
.nn
- i. e u,.
i.. u.
- s_
_ . _ - Qs w
- o. !.
.. w h -
1., u.
e .u....... -
....: u.
c _ ....44, j ; a, :., a 3, p -
- 2. . .{
s u s a .
..._..o 1 ,
t
. .t a
a . . .
g e .. .
3, 'j
, a _ g, , . . . . . .
.....'. .....I
, 1 >
- ... .t'. . ..:.. '. . . . . .
.i. .,
4 2 d i., t-d,x e.e .
1
.-.. .. . . ._ .... . ~ ,
. : l
,,)
e.,.,2, , ;. .... . .., . . . . .... e .
.,: .. . gu. - . 59 ..
- .,u.
~ t tal .
], n. g ii R . . . .. :
n 3,
. &. v n A.
o: i
. .;x u .
.o.4 a.
- ,, )
g, n ...: ._. . . . . . . .
< a y. u, .< ,
. , l
- a. % ;t g .r.: .; I. . .. '
i 9
j lJ {' - l M >o I
- p!. . (i'b!...
g
.O
.1 j-) . ;
.. (o,N ' -
.J
.) l um e. . .
.g.
'-d-
. s<
- p. en C. , %y O
. . . . < a,: !
r .
t . .
T a.
.g: u oo -
l l
.Q h i ' .'.
! ~l - .
- l
- . . '. .s .i 4.
= i i Q-=.0
. . . . . . . . . . g e .
.).
M"-'_cz' ,N/*j , y l., . . .
- i
- g. . .. - ..
._ +.. .. . .. r m g . _',
. .y ._. . . .: 9
_l. . .:. .o m .--,,.a d _ c. '. I '
[ ..
' :* . I . .i . ..g' . .! . .
. ._ . . .:j . 2 3 g M h, td , g. . I. ;. . .. .
i .
> ; 7 1_ .: ._ .. _ . . .
s
. . . .. . . . i._ _ . ... ,. .. '
's ,.h
. ..g. ,,, ,. .
..t....
.., ... ..u. : ....
- 6 t.
- r,.
. l.
g ).q .4 : .:... -
.,. . _. _.. 4 .
.i (- y@ .1 ..
t .: . . . .
.i.
e' _. a.., < , a ._ , . _ _
.j .... . ... _ . . -
i..
, . . . . . -i. . . .
' ,h t, i - .. . - .... - ,
1, .+ 1, 1 .1 ,. . . . .
--- o - :
i .,. N, I \,-
- a s, : . 1 - .
" 2e -
N.[.. ... : 1. .
. .. 8 . . . oi.: . . .; . .. .
1 f.v$.
I* . . : . :
5 .
$ I. .'. .* c11:. . , 3 ,%. _4.1 . . .
- l. -
. . .i.. . . m.. m see ..
1 g , N_..
- -: L ,e I r .i . < !,;; q.
o.
.g . ,
l
.._~_...._..__.-..('-
' . a-
-v
. . $;. ~ '
- d. . ' .
e ... . _
...=_...e
. .'s 1. . ... ._.
. p.....a_T -
- - : . . . . . .:m a%...n=
g i ...-. . -.
.g.:g 1 i .
.. t.._ -.,= g .
,: o ; =
- -s.
i
- o - .
3
...n.....$
.3
=
I- . ,.:..
3..
- . I 8*
a ..t.. 71, PEEi .ESS PUh P I co-v. .... 2 S9 C .
1..:
.. ....-.-.. m MAR;l 2 #dO .""". N At C . ... _. -
.....~-e.,.
. uyonoo1me,ncm oivuno.~ ; ,.. ,,,,,, p.f ~ yjo "y yy . y _ _
- s. v.
4.1. m . ,.... .. .
.,,c...,.. . . . .
.. .,. 7. e,., / . _ .. . . ... . ..r.
,. . .. . ......_,y. ,
. . . . . . . .,\ . ,,,, . c // 7 E l,. . C o it P. .. . . ; ~ ~ ii h ..- n . . . . sc Q G / 5 6 god: .. kG/,;rfy /s,a.>,f..I hhbg - - - - - - - - - - - -
~... 2 y/8 a.. . 78eeM.
- j. .
. . Aeod s.,e /As xs-' -
l'.* '
{
g '
I of ac//os//19-
- j ~
- 9. ']~ f , . 7 /.tIPELLCRS tu //g.X Hg.n
- D/A. -
- i "~l -
- {
.I
....r.sia.g..lt.!
- . . . .. l .
i.e, . s . .. , !,
e la,.. ,
i g
ia. . .
. - - . . .s.. .
i . . .-
. . .. p :. . ,
.j ,, *- -
emciracy . .
i,
~
8- - - -
. qf .. . : l g, [ ,
. ..; g g -[a.Z . . . .
eu .. . . .. ,. f ij .
- y. . .
I ; . . .
. i. 0 /
f,,, /j . . . . .. .
fod 1 .. . .
8 o MS\
- $ (> / '
'h gWgo '
pg,,p/cAPAC I T;y * *
?
',.; E, {u.y ;
O' T;cxx, 8;'t . . . . . ..
,. .y. .
.s. ,) .
- f I', .
<.- 2 Q 617
'500 - .".83.. . . . . . . .. . ~. l...:. g.. . ..
- j . ;
x 77,
/du D'. . . .' 8
. O )el . M. ... M 'I 3"..V W 1
~
i
.et.E, )it .d l .d pW i
- i. . .
s
,. s -
app .. . -
s . .
e
" zoo . .. .
l .
- : .f.. . . . .. . .i ! . .. MP)Y'...u.E:re.i,7.ll04
- ^ '
'pw- A 3. .a..v:it q..m.. a.v. w.d:
2 . 1 :. . . . .
i
~ ' ~ '
g .
l ..
,[/00
.j..i..
[..... .
'c k .4. 1.A.i I ..; *j j
l .
. :. .g. ..:
. .... . . .. . . . s
.. .. .. g. .
~; . . .
neo .tooo .
noo '.ztp., 3 3gx.,- .
- . . l,.s. .
- c. .. .
.aco /60 0 .uoa. .. 9at) . ..
.a .. . .. . . - I .:.. L.. . L : -
L_. -
GALLONS PL
.NUTE
- -- .. , . 2, <:. o 1
, p
- ['g3 C a g*'o~
UNITED $ TAT ES
/' .,..
,. NUCLEAR REGULATORY COMMISSION l
.~'E REGION lli o, $ [ 7e9 RooStvtLT ROAD CLIN ELLYN,1LLINots &O137
( ...../
'O E N Clo Su dt # 2-) .-==* *
~~"'> R R F /
Docket No. 50-483 Union Electric Company ATIN: Mr. Donald T. Schnell Vice President - Nuclear Post Office Box 149 - Mail Code 400 St. Louis, MO 63166 Gentlemen:
This refers to the routine safety inspection conducted by Hessrs. C. Radsey ;
and J. U11e of this of fice on November 1-5, 1982, of activities at Callaway Nuclear Plant, authorized by NRC Constriction Permit No. CPPR-139 and to the discussion of our findings with D. Poole at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection. Vithin these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
. (s PARAGRAP No tems oT oncomp 5.0.
nce with NR requiremen s were i ntified d ing the cou e of th inspec n. Howeve a written esponse requeste to items 50 483/8 14-01A, B, 02 4.nd 5 discussed n the de ils of th r r an dr the ex inte accordance Lt 10 790 o Commission's regulations, a copy of th letter, t enclosures. and ur response to t s letter 11 be placed in e NRC's Pub c Document Room. If this report co ains any formation that ou (or your ,ntractors) belie to be exempt fr disclosu under 10 CTR 9.5(a)(4), it a necessary that ou (a) notify th office b tele-phone w hin ten (10) ays from the date f this letter o vc,or inten on to file a equest for e hholding; and (b) ubmit within tw ty-five ( )
days frt.m t date of tlis 'etter a writt.en lication to th office t wit %old such nformation. your receipt of is letter has een delayed such t t less than se n G) days are as lable for you review, please notify th office pros:;.1 so that a new d dato say be tab-lished. Consisten with Section 4 90(b)(1), any su application st be accompanied by a affidavit execu d by the xner o the informat n O
~ * =-~ an w s r ,. ,~ . - , , ,
'D e Wf l
Contrary to the above, Missile Resistant Door No. 36042 did not ;
have the required permanently affixed label :ttesting to the re-(- quired level of fire resistance. The door nanufacturer indicated l to the inspectors on November 15, 1982, that the reason the door did not have the required permanently affixed label was because it !
had not been tested as rsquired. To resolve this issue, the licensee l should provide certified test data from a nationally : recognized independent testing laboratory attesting to the required level of fire resistance of missile resistance Door Nos. 36042, 13331, 14032, '
33012, 33044, 34021, 35021, 36042, 38011, 41015 and 41017. This is apparently, required by the t.onstruction specification, and the TSAR as identified above. i I
e In addition, the licensee is also requested to respond in writing (clarify) the discrepancies / conflict noted between U.E. Procurement i l
Specification 10466-A-076 which did not specify U.L. labels on fire rated doors and the following documents which did establish this
- requirement: , .
g, 'J i _ _ _-: O __:f L ___. :!':: . C':
%, g, U.E. Construction Specification 4645-23A - Paragraph (d) of the FNUPPS TSAR
% b. Construction Administrative Procedure No. AP-!%-03 Section 3.0 and 4.0.
Unresolved Item (50-483/82-14-01b) Tire door ratings. Door Nos.
4 and 5 of design package 23, Drawing No. 8600-X-8846 (Rev. ?),
( for the fire pumphouse and Door No. 33011 between no switchgear rooms in the communications arridor of the auxilary building at i elevation 2000, did not have the required U.L. labels. As required by Sh'JPPS TSAR, Page 9.5.1.13.
- To resolve these issues, certified test data froe an accredited '
independent fire testing laboratory, attesting to the required level of fire resistance of these doors is apparently required.
Unresolved Item (50-483/82-14-02) Fire Pump Ttsting. In response to issues raised by the NRC concerning fire purp installation and testing, Union Electric's letter of July 5,1978 (UENRC-271) states <
"fire pumps and contrc11ers are underwriters laboratories and factory I mutual rated. Contro11e-s and pumps will be installed and tested in ,
accordance with NFPA 20-1974." NTPA 20-1974 specifies a field acceptance test upon completion of the *ntire fire pump installation, i The field acceptance itant results Te required to be as good as the manuf acturer's certified shop test characteristic curve for the pump being tested. A yearly test is required at full apacity ,
of not less than 150 percoat of rated capacity at a total head not less than 65 percent of total rated head. The shut off head for horizontal split case puun should not excee) 120 percent v rated :
head. Durb a such tessa, intermediate points such as voh current (amps), pump speed (amps), pump suction, discharge J not
( discharge pressures should be measured. Comparing the resuus of i
7 ,
w - _ , _ _ . _ _ ,
v --, ------ -,
l
'D$. hf
.,*==""***"* ,
i these asasurements to pump ratings, the snufacturers certified I shop test characteristic curve and the acciptance test results i
( enables determination of actual pumps fielt performance characteris-tics.
p sy g u s'n s sT & o% f the above, the proposed operating technica*. specifica-ac r O tions for tVc Callaway plant requires fire pump testing every 18 months at 100% of rated capacity and 100% of total rated head.
The testing method does not specify measurement of intermediate points such as puarp speed (rpe's), current, suction and discharge pressures to compare fire pump performance to the original accept-ance test and manufacturers shop test results. )
Testing fire pumps to 100 percent of rated capacity at 100 percer.t
'T.
- of total rated head will not verify the availability of the maxinus Nh I ""
required flow for automatic sprinklers. The maximum system demand for autoestic sprinkers at elevation 2033-0 (North) of the turbine i
building is 2300 gallons per minute plus 1000 gallons per sinthe )
k )4I [ for outside hose streams. The total required flow is 3300 gallons k3 % per minute. Any two fire pumps installed at the Callaway plant, AN operating at 100 percent of rated capacity will deliver only 3000 E **11o"* P*r ai"ut* a hb5w 1
2 :
Mg g r Open Itesi (50-483/82-14-03) Fire loop main ring header isolation '
M
~ I valves. Page'9.5.1-13 of the SNUPPS TSAR and Union Electric Co's 3 -
g, I respouse to water sprinklers and hose standpipe systees spetifies O ( ! =. that "A management supervision program is provided for the fire protection system valves. Valves that are not electrically super-4 A.;3W vised with indications in 'the control roon, are locked th the proper g position with a strict key control system, including the use of C W 1* tamper-proof seals and periodic visual checks." )
b g At the time of this inspection, the three main ring header isola-
% tion valves for the fire pumps discharge into the system were not Eg (0 { * **1*
locked
- "din"the Pr o;.en **dur'position,
"** 1" were
- ffectnottprovided with tamper verify periodic Open Item (50-483/82-14-04) Fuel handling building fire protection proof inspection.
l W M =J equipment. According to Condition VI!! to Special Nuclear Materials
> U =J License No. SNM-1901 for Union Electric's Callaway Plaat Unit 1, 80 "2, D h {, } , entitled "Fire defety", adequate fire protection should be provided to reduce the risk of a large plant fire. In that, 'Tize safety for g the railroad bay, aev fuel shipping container storage area and un- i E- Q)4 loading area is provided by a sprinkler alarm system which can be i deIEh kl activated by a local pull down station. Aiditional fire protection I y
d T VI should be provided by permanently rounted fire hose racks, water axtinguishers, Co extinguishers and one chemical extinguisher."
It further states that, "Fire safety for the new fuel storage ares l consist of one Co and one water extinguisher." '
Interviews with plant personnel indicated that new fuel was expected I
( on site a few days subsequent to this inspection. l l
1 e
8
. , . -