ML20207J763

Insp Rept 50-293/86-36 on 861020-24.Two Violations Noted & Three Items Remain Unresolved Re Fire Protection Program

ML20207J763
Person / Time
Site:	Pilgrim
Issue date:	12/23/1986
From:	Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207J740	List: ML20207J737 ML20207J750 ML20207J763
References
50-293-86-36, NUDOCS 8701080581
Download: ML20207J763 (13)

See also: IR 05000293/1986036

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 86-36

Docket No. 50-293

License No. DPR-35 Priority - Category C

Licensee: Boston Edison Company M/C Nuclear

800 Boylston Street

Boston, Massachusetts 02199

Facility Name: Pilgrim Atomic Power Station

Inspection At: Plymouth, Massachusetts

Inspection Conducted: October 20-24, 1986

Inspector: ..th]l['c[ auAvdv

A. Krisopo0 Tot', ~ Reactor Erigineer, DRS

/ /1 B 6

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Approved by: %f_ . 1,. o / _ / _

/ J43/76,

p. J(' Anderson, Cliief, Plant Systps Section ' dat(

Inspection Summary: Inspection on October 20-24, 1986 (Report 50-293/86-36)

Areas Inspected: Routine unannounced inspection of the fire protection / preven-

tion program including a review of: the combustible material control / hazard

reduction program; programmatic administrative controls; installation, oper-

ability and maintenance of fire protection systems; fire protection LERs; fire

fighting capabilities; fire protection equipment maintenance inspection and

tests; periodic inspections and quality assurance (QA) audits of the fire

protection program and a facility tour.

Results: Of the eight areas inspected two violations were identified and three

items remain unresolved.

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DETAILS

1. Persons Contacted

1.1 Boston Edison Company (BECO)

• A. E. Pedersen, Plant Manager

• W. Sullivan, Fire Protection Engineer

• J. McEachern, Resources Protection

• J. Quinn, Plant Engineer

• R. Velez, Project Manager

• E. Ziemianski, Nuclear Management Services Section Manager

B. Lunn, Compliance Engineer

R. Laroue, Training Specialist

1.2 Nuclear Regulatory Commission (NRC)

• M. McBride, Senior Resident Inspector

• Denotes those present at the exit interview.

2. Inspection Purpose and Methodology

The purpose of this inspection was to evaluate the licensee's fire protec-

tion and prevention program (FPPP) and verify that the licensee has

developed and implemented adequate procedures, consistent with the appli-

cable Technical Specifications (TS), license conditions, regulatory

requirements and commitments made in the Final Safety Analysis Report and

the Fire Protection System Evaluation Report (FPSER). The evaluation of

the program consisted of a documentation and procedure review, interviews

with licensee personnel and field observations.

The documents reviewed, the scope of review and the inspection findings

for each area reviewed are described in the following sections.

3. Fire Protection Program Review

3.1 Review of Combustible Material Control - Hazard Reduction

The inspector toured the plant to inspect housekeeping conditions,

work in process and activities or conditions that may present a

hazard to the facility.

The scope of review was to verify that the licensee:

a. Keeps safety related and adjacent plant areas free from transi-

ent combustibles;

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b. Keeps. flammable and combustible liquids under administrative

control and the storage of such liquids is in accordance with

the guidelines of the National Fire Protection Association

(NFPA) Standards;

c. Performs periodic inspection for accumulation of combustibles;

d. Uses wood treated with flame retardant for work inside plant

areas;

e. Does not allow the accumulation of waste, debris, rags, oil

spills, and other combustible materials resulting from a work

activity to extend beyond the end of each work shift or the end

of the activity, whichever is sooner; ,

f. Properly maintains the housekeeping in all areas containing

safety related equipment and components; ,

g. Prohibits smoking in safety related areas except where " smoking

permitted" areas have been specifically designed by plant

management; and

h. Requires special authorization (work permit) for activities

involving welding, cutting, grinding, open flame or other igni-

tion sources, and that these activities are properly safe-

guarded.

During the inspection the inspector did not identify any conditions

that present a safety hazard, however, in the Turbine Building,

elevation 51' 0", the inspector observed that the flammable storage

cabinets located therein, were neither grounded nor vented as per

cabinet manufacturers and NFPA recommendations. The licensee cor-

rected this condition prior to the inspector leaving the site.

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3.2 Review of Administrative Controls

The inspector reviewed the following licensee documents:

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Technical Specifications, Section 6, Administrative Controls;  ;

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License Condition 3.F. Fire protection requiring the licensee l

to implement the administrative controls identified in the Fire '

Protection Safety Evaluation and the requirements listed in the

" Nuclear Plant Fire Protection Functional Responsibilities,

Administrative Controls and Quality Assurance";

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BECO Fire Protection System Evaluation; and

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Pilgrim Training Manual.

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The scope of review was to verify that the licensee had developed

administrative controls which require that:

a. Work authorization, construction permit or similar arrangement

is provided for review and approval of modification, construc-

tion and maintenance activities which could adversely affect the

safety of the facility;

b. Fire brigade organization and qualifications of brigade members

are delineated;

c. Fire reporting instructions for general plant personnel are

developed;

d. Periodic audits are to be conducted on the entire fire protec-

tion program; and

e. Fire protection / prevention program is included in the licensee's

QA Program.

No unacceptable conditions were identified.

3.3 Review of Installation, Operability and Maintenance of Fire

Protection Systems

The inspector reviewed the installation of randomly selected fire

protection systems, fire protection system flow diagrams, made obser-

vations on the condition and operability of the fire protection

equipment and reviewed the Fire Protection Equipment Main-

tenance Request List to determine whether:

a. Fire protection equipment such as stand pipes and hose stations

are operable and accessible in all areas important to safety;

b. Adequate portable extinguishers are provided at designated

places in each fire area;

c. The condition of all fire suppression devices inspected is

satisfactory;

d. The system's valves are lined up in the proper position and are

protected from tampering; and

e. The fire protection equipment is well maintained.

f. The fire barriers and related components such as fire doors,

fire dampers, and penetration seals have been installed and

maintained properly to insure against fire propagation.

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As a result of this review the following observations were made by

the inspector:

a. The licensee is not agressively pursuing maintenance and repair

work to the fire protection systems as evidenced by the large

amount of incomplete repair work on fire protection system

components.

This observation is based on the following:

(1) Almost 300 work requests were outstanding for repair

work on fire protection system components

(2) Eight (8) maintenance requests are for work that affects

the fire pump system, and if left undone may affect pump

operability and

(3) Twelve (12) maintenance requests were originated in 1983,

about thirty requests were originated in 1984, and the

remainder of the (300) requests originated in 1985 and

1986.

b. The licensee has relied heavily on fire watches as a substitute

for degraded fire protection system components. During the

inspection period, the licensee had an average of fifty-five

(55) fire watch postings covering about thirty-five (35)

different areas. Thirty (30) of these watches had been in place

for more than three (3) months, eight (8) had been in place for

more than a year and the remainder were established within the

last 3 months.

The above items are collectively categorized as an unresolved item pending

a review of the licensee's actions to implement repairs on the fire pro-

tection system components and minimize the use of fire watches as a

substitute for correcting deficiencies in the fire system. (50-293/86-36-01).

The inspector also noted that the access way to Hose Station No. TA 86-51

was blocked by an instrument cart. This could impede use of the hose

station in an emergency. The licensee took immediate action to relocate

the cart. This appeared to be an isolated incident.

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3.4 Review of Licensee Event Reports (LER)

The inspector reviewed eight recent fire protection LERs. The LERs

reviewed were Nos. 86-23, 86-20, 84-07, 83-41, 83-38, 83-30, 83-25

and 83-27.

The inspector concluded that seven of the eight LER's were related

to fire barrier degradation. Five of the LERs were issued because of

inoperable fire barriers. These barriers were declared inoperable

because of either missed barrier surveillances or because of degraded

barrier components such as penetration seals and fire doors. Two

LERs were issued because fire watches established as compensatory

measures had not perform as required, due to inadequate instructions.

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The inspector reviewed the weekly fire watch logs and the Maintenance

Request List (MRL) to determine the nature and extent of the fire

barrier deficiencies. From these documents and from interviews with

licensee personnel, the inspector learned that the following barriers

were declared inoperable because of suspected barrier degradation:

Vital Motor Generator Set Room Floor

Battery Room B West Wall

Battery Room B North and East Wall

Computer Room West Wall

A Switch Gear Room West Wall

A Switch Gear Room North Wall

Battery Room A East Wall

Battery Room A West Wall

Vital Motor Generator Set Room North Wall

Vital Motor Generator Set Room West Wall

A Switchgear Room South Wall

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A Switchgear Room Floor

Diesel Generator Room A East Wall

Diesel Generator A/B Area South Wall

Diesel Generator Room East Wall

Turbine Tool Storage Room East Wall

Filter Room South Wall

HVAC #2 Room South Wall

Turbine Deck

Reactor Buildings Floor 91'

Reactor Buildings Floor 51'

Reactor Building 51' South Wall

Fan Room #3 Reactor Building 74' Floor

Reactor Building 74' Floor

Recirculation Motor Generator Set East Floor 51'

Reactor Building 23' Floor

Recirculation Motor Generator Set East Wall 51'

Water Treatment Area North Wall

Auxiliary Boiler Room West Wall

Auxiliary Boiler Room North Wall

Turbine Lube Oil Area North Wall

1 Condensate Pump Area South Wall

Turbine Lube Oil Ceiling

l Intake Structure North Wall of the Service Water Pump Rooms

The licensee established fire watches for the above barriers pending

verification of the barrier status, ie, operable-inoperable or the

barrier operability is not required.

The inspector determtried that the reasons for declaring the barriers

inoperable were the following:

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a. Penetrations seal documentation either does not exist or is

unclear;

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b. Barrier components appear degraded;

c. Uncertainty exists as to whether the fire barrier is required.

With regard to Item a, the licensee stated that during a check of the

documentation necessary to verify the fire rating of the seals, ques-

tions were raised as to the adequacy of QC during seal installation.

In addition, seal test data and other parameters necessary to estab-

lish seal adequacy were not available. In some cases, the licensee

stated that the documantation either can not be found or does not

exist. With regard to Item b, field inspections by the licensee

identified penetrations with some impairments. The licensee had not

completed their evaluation of these deficiencies. With regard to

i Item c, a number of penetrations were identified as degraded. How-

ever, uncertainty exists as to whether these barriers are required.

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The licensee is in the process of evaluating all of the suspected

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non-conformances in a systematic way. An analysis is being performed

4 to identify which of the barriers are required by the Technical

i Specification, Appendix R or by licensing commitments. The licensee

is evaluating the adequacy of all seals either by analysis or sim-

ilarity tests. Any non-conformances identified during this process i

will be reported in accordance with the applicable reporting require-

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ments.

The above was collectively categorized as an Unresolved Item pending

review of the licensee's actions to evaluate the barriers, report

non-conformances and implement required repairs. (50-293/86-36-02).

3.5 Review of Fire Fighting Capabilities

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The inspector reviewed the licensee documents listed below, conducted

interviews with personnel and inspected fire fighting gear to evaluate the

on-site capability of the licensee to fight fires: a

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The documents reviewed were:

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License Amendment No. 35 section 3.F;

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Fire Protection Safety Evaluation Report

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Pilgrim Training Manual;

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Fire Brigade Training Drill Procedure No. 1.4.23, Revision 7; ,

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Fire Watch Procedure No. 8.B.14, Revision 7;

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Special Fire Procedure No. 5.5.2; and

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Qualified Fire Fighter Rosters.

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The scope of the review was to:

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l a. verify that all personnel designated to take part in fire emer-

i gencies are trained in these actions and in the overall emergency

plan,

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b. verify that the licensee has established a training program that

ensures the capability to fight potential fires;

c. verify that the licensee's training p ogram consists of initial

classroom instruction followed by periodic classroom instruction,

firefighting practice and fire drills,

d. verify that the licensee had developed fire fighting strategies for

fires in all safety related areas and in areas in which a fire could

present a hazard to safety related equipment and

e. verify that the fire fighters can fight plant fires with the equip-

ment available.

With regard to the above, the inspector made the following observations

concerning the overall adequacy of the fire brigade training, the adequacy

of the fire watches, the adequacy of and use of the fire fighters

protective gear and the ability to fight plant fires jointly with the

local fire department:

Fire Brigade Training

The Pilgrim Station Operating License, Number DPR-35, in Section 3.F.

titled " Fire Protection", requires the licensee to implement the

administrative controls specified in Section 6 of the NRC Fire

Protection Safety Evaluation (SE) dated December 21, 1978.

Section 6 of the SE states that the licensee will provide the fire brigade

training in accordance with the guidelines contained in the " Nuclear Fire

Protection Functional Responsibilities, Administrative Controls and Qual-

ity Assurance" document. This document specifies that the Fire Brigade

Members Qualification and Training Program includes the following:

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Initial classroom instructions;

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All brigade members shall have hands-on fire fighting practice

at least once per year;

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Classroom instruction is provided to all fire brigade members

every 3 months so that the initial classroom program is

repeated over a two year period;

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Fire brigade drills are performed so the brigade can practice as

a team;

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Membership to the brigade should include satisfactory completion

of a physical examination for performing strenuous activity; and

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The training shall be as specified in the National Fire

Protection Association (NFPA) Standard 27.

The inspector reviewed the training records for the brigade members

and interviewed all of the shift fire brigade members to eval-

uate the licensees conformance with the above requirements. The

review identified the following:

The licensee allowed in calendar year 1986 at least nine (9) fire-

fighters who missed two (2) consecutive quarterly training sessions

and twenty-one (21) fire fighters who missed one (1) quarterly training

session to be active members of the brigade.

The above is a violation of the license requirement to provide

quarterly classroom instruction to all active members of the Fire

Brigade. (50-293/86-36-03)

The inspector also noted that about thirty (30) fire fighters had not i

participated in any fire drills. However, NRC Report No. 86-21 pre-

viously identified this deficiency as a deviation from the training

requirements.

The licensee indicated that an accelerated Fire Brigade Training

Program is being implemented so that the qualifications of all

brigade members are maintained.

The inspector reviewed the licensee's followup to LER 86-23. In the

LER the licensee identified a deficiency with fire watches not

properly documenting their surveillance of certain fire areas. No

deficiencies were observed, during this inspection, with regard to

the proper documentation of surveillances performed. However, the

inspector observed that the fire watch assigned to patrol the

degraded fire barriers in the MG Set room on October 21, 1986 did not

inspect the room. The fire watch entered the room, signed the fire

watch log and laft. Similarly, the inspector observed that the fire

watches assigned to patrol the degraded fire barriers the vital MG

Set room never entered the room, instead they signed the log locnted

outside the room and left. This was ascertained by an examination of

the security logs which electronically identifies all individuals

entering the room.

Technical Specification 6.8.D. requires that " Written Procedures to

implement the Fire Protection Program shall be established, imple-

mented and maintained." One Fire Protection Program Procedure is

8.B.14, Fire watch, which requires that fire watches inspect the

plant areas found with inoperable fire protection equipment or

degraded barriers. The failure of the fire watches to perform as

required by procedure, is a violation of the Technical Specification 6.8.D in that the individuals did not perform the required room

surveillance. (50-293/86-36-04)

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The licensee, subsequent to the inspector's observation, issued a

memo to all fire watches iterating the performance requirements for

the job and specifically included the warning that although it is

important to document the fire watch activity, the primary function

of the watch is to look out for fire and fire hazards.

Availability of Fire Fighter Gear

The licensee's fire fighting procedures require that when a fire

alarm is received the designated shift fire brigade leader is dis-

patched to the fire ccene to perform an assessment of the fire hazard

while a second operator goes to the fire brigade locker to don

protective equipment. The second operator is then responsible for

bringing protective equipment to the fire scene for the brigade use.

The protective equipment involved is boots, gloves, turnout coat,

helmet, self-contained breathing apparatus and flash lights. This

equipment is bulky and heavy. The inspector expressed the concern

that this method of responding to fires (with one operator doning the

protection equipment) is physically demanding and might result in

delaying the brigades initial response to the fire.

The licensee agreed with the inspectors observation. In order to

facilitate use of the protective equipment the licensee plans to

either provide additional protective equipment throughout the plant

or disperse the available equipment so that the distance travelled

by the operator carrying the equipment from the fire locker to the

fire scene is minimized.

Fire Fighting With Off-Site Fire Departments

TN. licensee conducts a fire drill once per year with the local fire

dei .rtment. The inspector observed that although the local fire

, de >.rtment is cooperating with the licensee. in that regard, a formal

l agreement specifying responsibilities and designating the person in

! charge at the fire scene does not exist. The inspector discussed

with plant management that such agree.nent may prevent disagreements,

i during an emergency among the site and offsite brigade leaders. A

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useful agreement would specify the function of the off-site depart-

ment in the fire fighting activity and specify that the person who

, will be in charge at the fire scene is a member of the licensee's

j staff who is competent to assess the potential safety consequences of

a fire and fire suppresants and is able to advise control room

personnel. The NRC in Branch Technical Positions 9.5-1 provides

guidance for joint drills and training with offsite fire departments.

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The licensee plant management committed to pursue a resolution to

I this issue by preparing a formal cooperation agreement with the local

fire department addressing the concern.

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3.6 Review of Equipment Maintenance, Inspection and Tests

The inspector reviewed the following documents to determine whether

the licensee had developed adequate procedures which establish .

maintenance, inspection, and testing requirements for the plant fire

protection equipment:

Procedure No. 3.M.4-72, once/ cycle Diesel Fire Pump Engine

Check, Revision 0;

Procedure No. 8.B.19, Fire Brigade Equipment Inspection,

Revision 1;

• Procedure No. 8.B.4, Smoke and Heat Detection System,

Revision 14;

Procedure No. 8.B.11, Fire Valve Operability, Revision 7;

• Procedure No. 8.B.3.1, Fire Hose Station Equipment Inspection,

TS Related, Revision 1.

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

established procedures.

3.7 Periodic Inspections and Quality Assurance Audits

3.7.1 Annual Audit

The inspector reviewed Audit Report 85-55, Annual Fire

Protection Audit. The scope of review was to ascertain

that the audit was conducted in accordance with the Tech-

nical Specification Section 6.14.1 and audit findings were

being resolved in a timely and satisfactory manner.

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3.7.2 Biennial Audit

! The inspector reviewed Audit Report 85-22, Fire Protection

! Biennial Audit. This audit was performed by the licensee

in accordance with the guidelines contained in Generic

Letter 82-21.

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3.7.3 Triennial Audit

The inspector reviewed Audit Report 84-27, Fire Protection

Triennial Audit.

The scope of review was to ascertain that the audit was

conducted in accordance with TS 6.14.2 and audit findings

were being resolved in a timely and satisfactory manner.

With regard to the above, the inspector observed that the

QA audits identified specific deficiencies in the fire

brigade training, the fire watch training and deficiencies

with degraded barriers. It was noted that the audit

findings had been closed out. Since the deficiencies

identifed in-the above audits are similar to the deficiencies

identified by the inspector it appears that the licensee's

corrective actions and actions to prevent recurrence were

inadequate.

This is an unresolved item pending a review of the licensee's

actions to close out the QA findings related to the fire

program. (50-293/86-36-05)

3.8 Facility Tour

The inspector examined the fire protection water systems. This

included fire pumps, fire water piping and distribution systems, post

indicator valves, hydrants and the contents of hose houses. The

inspector toured accessible vital and non-vital plant areas and

examined fire detection and alarm systems, automatic and manual fixed

suppression systems, interior hose stations, fire barrier penetration

seals, and fire doors. The inspector observed general plant house-

keeping condition 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 monthly inspections were performed. The inspector did not

identify any unacceptable conditions other than those identified in

other sections of this report.

4. Unresolved Items

Unresolved items are matters about which more information is required to

ascertain whether they are acceptable items, violations or deviations.

Unresolved items disclosed during the inspection are discussed in Sections

3.4, 3.5 and 3.7.

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5. Exit Interview-

The inspector met with the licensee representatives (see Section 1.0 for

attendees) at the conclusien of the inspection on October 24, 1986. The

inspector summarized the scope and findings of the_ inspection at that

time. The inspector also confirmed with the licensee that the report will

not contain any proprietary information. The licensee agreed that the

inspection report may be placed in the Public Document Room without prior

ifcensee review for proprietary information (10 CFR 2.790).

Atkotimeduringthis-inspectionwaswrittenmaterialprovidedtothe

licensee by the inspector.

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