ML20215D884

Rev 0 to Fire Protection/Prevention

ML20215D884
Person / Time
Site:	Sequoyah
Issue date:	11/26/1986
From:	Gass K, Knightly J, Stewart D TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20215D785	List: ML20215D780 ML20215D796 ML20215D813 ML20215D816 ML20215D844 ML20215D857 ML20215D866 ML20215D876 ML20215D884 ML20215D888 ML20215D892 ML20215D902 ML20215D911 ML20215D914 ML20215D922
References
SWEC-SQN-09, SWEC-SQN-09-R00, SWEC-SQN-9, SWEC-SQN-9-R, NUDOCS 8612170103
Download: ML20215D884 (9)

Text

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. TVA EMPLOYEE CONCERNS REPORT NUMBER: SWEC-SQN-09 SPECIAL PROGRAM

. REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 0

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TITLE: Fire Protection / Prevention REASON FOR REVISION: N/A SWEC

SUMMARY

STATEMENT: The items in this report were identified by the Nuclear Regulatory Commission (NRC) and were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis. All items evaluated within this report were verified to be adequately addressed and SWEC concerns A02841116010-001,

-002, and -005 were closed by NRC. Concern A02841116010-003 is now ready for closure. Concern A02841116010-004 requires additional corrective action.

PREPARED BY:

Wf M- % 26 SIGNATURE DATE REVIEWS PEER:

4 Mut SIGNATURE '

alun DATE Ab $Of a fE

, SIGNATUEE DATE CONCURRENCES l

CEG-H:_ M ///Jt,/f4 SRP: hm & /Me=R /2-S.'FC

• l SIGNATURE DATE DATE G SIGNATURE

• APPROVED BY:

Mo8AJECSPMANAG$lt

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n+80 DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

• SRP Secrotary's signature denotes SRP concurrences are in files.

2242T A0 0 7 hD P

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TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OTHER SITES CEG Element

Title:

Fire Protection / Prevention SWEC Concerns: A0284111t010-001 .

-002

-003

-004

-005 Source Document: NRC Report Numbers 50-327, 328/84-31 Report Number: SWEC-SQN-09 a

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Evaluator: I [. AJ

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// N K. R. Gass Date Reviewed By: '

1I!kb!h J. J. Knightly Date Approved By: dd it /A 6 fil, A.G.Debbap Ifate '

2121T

y 'A Report SWEC-SQN-09 NRC Report 50-327/84-31 and-50-328/84-31.

'I. ~ INTRODUCTION

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period October 23-26, 1984, the Nuclear Regulatory Commission (NRC) conducted a routine, unannounced inspection of the

.Sequoyah Nuclear Plant (SQN) fire protection / prevention program, including follow-up to licensee action on previous enforcement matters and to SQN's compensatory. actions associated with a previous NRC Confirmation of Action (COA) letter on Appendix R fire protection discrepancies. From these three primary areas of inspection activity, NRC identified, among others, two violations, one deviation, a

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nonclosure of a previously identified deviation to stated licensing commitments and a concern, all of which were addressed as issues in the Stone and Webster Engineering Corporation (SWEC) systematic analysis.

These issues are identified as follows:

A. A02841116010-001, Fire Protection System Strainer Maintenanco B. A02841116010-002, Fire Brigade Unqualified for Airborne Contamination C. A02841116010-003, Status Lights Not in Main Control Room for Fire Protection D. A02841116010-004, Lack of Fire Fighting Procedures R. A02841116010-005, Reactor Coolant Pump 011 Collection System Not Per Appendix R Information on the background, plant corrective actions taken, the Employee Concerns Task Group (ECTG) verification methodology and analysis results, the items completion status and any pertinent references associated with the SWEC issues is included in the succeeding paragraphs of this report.

II. VERIFICATION OF SWEC ITEMS A., A02841116010-001, Fire Protection System Strainer Maintenance

1. Background NRC's review of SQN's surveillance inspection and test program for the fire protection automatic water spray and sprinkler system identified that strainers in the supply piping to these systems were not included in a periodic maintenance inspection and cleaning program. The requirement to inspect and clean these strainers is included in section 6012 (1973 edition) of the National Fire Protection Association (NFPA) code as committed to perform in accordance with SQN Final Safety Analysis Report section 9.5.1.4. NRC wrote violations 50-327 and 328/84-31-04 (reference 1) as a result. TVA attributed this violation to an oversight during preparation of the initial fire protection procedures and lack of identification during subsequent reviews (references 2 and 3).

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2. Corrective Actions Taken vc - ..

ec Corrective' actions taken by.SQN, as stated (reference 4) by the

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NRC inspector included the following:

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SQN established'a'n'interia strainer maintenanco program

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which was initiated and completed in November 1984. The-

^^' interim program provided for the inspection and cleaning of six strainer assemblies. According to SQN, some of the

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strainer assemblies.have been in operation for approximately seven years. The strainers inspected under this program consisted of the following:

The strainer assemblies for the four headers entering the reactor building.

The strainer assembly for the header supplying the Train B Auxiliary Building Gas Treatment System (ABGTS) charcoal filter housing.

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The strainer assembly for the header supplying the unit 2 containment purge charcoal filter housing.

The total quantity of foreign materials removed from the above strainers was approximately 78 grams.

SQN has established a fire protection system strainer maintenance program under Maintenance Instruction MI-6.24,

" Cleaning / Inspection of High Pressure Fire Protection Strainers" (reference 5). This program will inspect, maintain, and test the high pressure fire protection system strainers located in the flow paths between the fire pumps and the flow control valves for various sprinkler and water spray system supplying safety-related areas. The strainer program according to the licensee will be performed on an annual basis with the following exceptions:

Those strainers installed immediately upstream of the )

flow control valves supplying the Reactor Building water

, . fire suppression systems will be inspected every 18 months or during each refueling outage.

Where fire protection system strainers are provided with either differential pressure switches or gauges, allowing determination of the differential pressure across the strainers, the differential pressure will be determined once every six months in conjunction with sufficient water flow through the strainer to provide an indication of restriction.

SQN's fire protection system strainer inspection program will be in place and the strainers inspected by startup of unit 1, cycle 3 refueling. This item is closed.

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3. Verification Methodology

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The SWEC concern identified for ECTG verification was stated as follows:

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RIMS NUMBER ISSUE RIMS ITEM e

A02841116010 Strainers in supply piping to -001 fire protection automatic water spray and sprinkler system not included in periodic maintenance inspection and cleaning program ECTG reviewed the Sequoyah Compliance Licensing files for internal and external correspondence related to this issue, and the NRC status and tracking system for the issue. This review of the pertinent documentation formed the basis for this verification activity.

4. Verification Analysis The ECTG review of the pertinent documents indicated that the corrective actions for this concern and the violation have been

. adequately resolved. At the time of this ECTG verification, the SQN plant responses have been found acceptable and the violation has been closed by the NRC.

5. Canoletion Status Based on SQN Corrective Actions as indicated in II.A.2 and NRC closure of this item, the SWEC concern is closed.

B. A02841116010-002 Fire Brigade Unqualified for Airborne Contamination

1. Background The NRC inspector described (reference 1) the background as follows:

a The fire brigade is composed of personnel from the operations group. The team leader is an assistant shift engineer and the brigade members are auxiliary unit operators. There are 16 designated brigade leaders and 79 members. The training, drill and medical review records for four team leaders and ten members were reviewed to verify that these personnel had attended the basic and/or leadership training, quarterly classroom training, two drills within the past year, medical review within the past year, and I were respirator qualified. One member had never received a respirator fit test, one member was five months overdue for a whole body count, and two were

slightly overdue (24 and 4 days) for medical review.

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A cursory document review indicated that a number of other fire brigade members were also not respirator qualified. The failure of brigade members to meet the requirements of the

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qualification progema is identified as Violation Item (327 and 328/84-31-03), All Fire Brigade Members are Not Respirator Qualified.

. 2. Corrective Actions Taken TVA memorandum (reference 9) stated:

The individuals involved have updated their health physics requirements and are now in compliance with the Radiological Hygiene Program. The section supervisor for the individuals is aware of the requirement to inform personnel about health physics requirements, and has assigned a person in his section to ensure that those needing health physics updates are informed approximately two months before expiration date. This is being accomplished by issuance of a memorandum to that individual, requesting acknowledgment under return signature that he or she is cognizant of their upcoming health physics requirement expiration date.

The procedure Physical Security Instruction (PHYSI-13)

" Fire" for addressing fire brigade qualification criteria j was revised to delete the 25-percent extension on fire brigade medical examinations. Since fire beigade personnel normally have their annual medical examination and respirator medical reevaluation done simultaneously, this should preclude any confusion in meeting both health physics '

and fire brigade medical criteria. The revision to PHYSI-13 was completed September 26, 1985 (reference 8).

As of December. 10, 1984, all personnel involved were in full compliance with both health physics and fire brigade criteria.

3. . Verification Methodology

, The SWEC concern identified for ECTG verification was stated as follows:

RIMS NUMBER ISSUE RIMS ITEM A02841116010 Fire brigade members not -002 qualified to respond to airborne contamination areas in event of fire.

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l ECTG reviewed tho'Sequoyah Compliance Licensing Files for I

• - internal and externa 1' correspondence related to this issue, and NRC status and closure files. This review of the pertinent-

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documentation formed the basis for this verification activity.

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The ECTG review indicated that the violation and concern were adequately resolved. SQN. corrective actions h6ve been completed and are being implemented. At the time of this ECTG verification, the NRC violation has been closed (reference 7).

5. Completion Status Based on SQN corrective action, ccepliance with requirements, and NRC closure of the item, no further action on this item is I ' required. This SWEC concern is' closed.

C. A02841116010-003 - Status Lights Not In Main Control Room for Fire Protection

1. Background

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FSAR, Section 6.2.4.2.2, states that the safeguard position of automatic containment isolation valves is indicated by status lights in the main control room. The safeguard position of the containment isolation valves in the fire protection piping which. penetrates.the containment is not provided with status lights in the control room. Therefore, this FSAR discrepancy which is applicable to both units is identified as Deviation Item (327 and 328/S4-31-02), Fire Protection System Containment Isolation Yalves Are Not Provided With Status Lights in the Main Control Room.

{ 2. Corrective Actions Taken There are only two high pressure fire protection containment isolation valves; namely 26-240 and 26-243, as noted in the FSAR Section 6.2.4.2.2 Table 6.2.4-1. As stated in TVA's

, . response to deviation 327, 328/84-31-02 (reference 4), these valves will have remote position indication installed in the main control room.

1 Valves26-241, 242, and 245 are secondary containment isolation i valves providing isolation for lines which penetrate the shield building into the annulus. These valves are ASME Section II, Category A or B, active valves, and, as such, are stroked-tested on a quarterly basis, or after maintenance or

!. repair work, by performance of Surveillance Inr,truction  ;

(SI)-166.1 or SI-166.6. This surveillance also verifies the operability of the valve position indication lights on the local control panel. SI-167 verifies once every 31 days that the valves are in their correct position in accordance with technical specification surveillance requirement S.R.4.7.11.1.B.

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SQN stated (reference 4):

The actions planned per Regulatory Guide 1.97 will. satisfy

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the requirement for remote position indication in the main control room, and should be completed within the timeframes

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outlined in TVA's commitment to this Regulatory Guide.

Further, the FSAR will be revised to clarify the wording in Section 6.2.4.2.2, in the next annual FSAR update.

3. Verification Methodology RIMS NUMBER ISSUE RIMS ITEM A02841116010 Status lights not installed -003 in control room for auto containment isolation valves within fire protection system ECTG reviewed the Sequoyah Compliance Licensing Files for internal and external correspondence related to this issue and the NRC status and tracking system for the issues. This review of the pertinent documentation fonned tho basis for this verification activity.

4. Verification Analysis The ECTG review indicated that the corrective action described in II-C.2, is adequate to resolve the deviation and the concern. The revision of FSAR (RIMS L44 860411 812) was submitted April 11, 1986.

5. Completion Status Based on SQN corrective action and compliance with requirements, this issue is considered complete and ready for NRC closure.

D. A02841116010-004 - Lack of Fire Fighting Procedures

, 1. Background NRC Report Numbers 50-327, 328/84-31, Paragraph 3.C states (Reference 1):

Deviation Item (327/80-10-01), Substandard Fire Protection Administrative Procedures. As previously reported in Report Nos. 327/80-17 and 328/80-10, the SQN revised the plant procedures to comply with the NRC guidelines for fire brigade training and drills.

Subsequently, procedure PHYSI-13, section 4.5.1, has been revised to require wood used in safety-related areas of the plant to be of the pressure fire retardant type unless an exemptica is granted by the plant safety staff for use of other types of materials. This appears to meet the intent of the NRC guidelines. Fire fighting procedures for all safety-related areas have Page 6 of 9

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not yet been prepared. The licensee stated that

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approximately five procedures for safety-related areas and 20 for nonsafety-related areas remain to be

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prepared. This item is to remain open until these procedures are prepared.

2. Corrective Actions Taken ECTG discussed corrective actions with personnel in the industrial safety section. It was stated that the revision to the fire fighting procedures, referred to in NRC deviation

. Item 327/80-10-01, had not been completed. y

3. Verification Methodology RIMS NUMBER ISSUE RIMS ITEM A02841116010 LFire fighting procedures for all -004 safety-related areas have not yet been prepared. Fire fighting procedures for nonsafety system also not prepared ECTG reviewed the Sequoyah files for internal and external correspondence related to this issue and the NRC status tracking system for the issues. This review of the pertinent documentation formed the basis for this verification activity.

4. Verification Analysis Based on the ECTG verification activities described in II.D.2, it was determined that the SQN corrective actions have not been completed. At the time of this ECTG verification, the NRC deviation item remained open; however, the SQN plant response had been found acceptable to the NRC. This item will remain open until these procedures are prepared.

5. Completion Status

, Corrective actions for NRC violation 327/80-10-01 have not been completed. This issue remains open.

E. A02841116010-005 - Reactor Coolant Pump 011 Collection System Not Per Appendix R.

1. Background NRC Report Nos. 50-327, 328/84-31, paragraph 5.e. states:

The oil collection systems for the reactor coolant pumps were identified by TVA as being of insufficient capacity to hold the oil resulting from the largest spill due to a single failure. Modifications which had been made since the Page 7 of 9

initial dssign of the systen to satisfy othse commitments

. and-safety issues had reduced the volume available for oil

~r' collection. TVA's evaluation indicated that the drain

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piping system plus a portion of the collection sump would

[ be sufficient for oil collection. Therefore, TVA has revised annunciator procedure No. SOI-55-1MS, Annunciator Response, (Change No. 84-1475) and issued a " Night Order" to require the operator to verify that-the reactor building

. pocket sump is maintained at less than 45-percent full in i the event of a high or low level alarm in either the upper

. cr lower bearing oil reservoir for the reactor coolant l' pumps. The inspector verified that these peccedures were

[ properly filed within the control room.

4 The present arrangement of the oil collection system for the reactor coolant pumps does not meet the requirements of Appendix R, section III.0 since the drainage system will not handle an oil break from all of the lubrication systems simultaneously following a safe shutdown earthquake. This

$ discrepancy requires a formal deviation request. NRC i Region II will review this system in detail during a subsequent inspection. ~

2. Corrective Actions Taken-NRC approved on an interim basis, in Inspection Report 327, 328/85-01 (March, 1985) a deviation from requirements based on the following equivalent actions by SQN: System Operating Instruction, SOI-55-INS, " Annunciator Response" was revised to

- maintain the auxiliary sump at less than half-full at times specified in order to have available sufficient capacity to hold the oil from one reactor coolant pump.

A deviation request from Appendix R of 10CFR Part 50, (as discussed in II.E.1 above) was approved by NRC May 29, 1986 (reference 6).

3. yerification Methodology The SWEC concern identified for ECTG verification was stated as

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RINS NUMBER ISSUE RIMS ITEM I

[. A02841116010 Oil collect system for -005 i reactor coolant pump does l

not meet Appendix R Section III since drain system can't

handle oil break from all

systems at once following a safe shutdown earthquake.

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. ECTG reviewed the Sequcyah Compliance Licensing Files for internal and external correspondence'related to this issue and the NRC status and tracking system for the issues. This review of the pertinent documentation formed the basis for this

_ verification activity.

4. Verification Analysis The ECTG review of the pertinent documents indicated that the corrective actions for this concern and the deviation have been completed and are adequate to resolve the concern and deviation. At the time of this ECTG verification, the NRC

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deviation is closed.

5. Completion Status Based on SQN corrective action and compliance with

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requirements, this issue is considered complete.

References:

1. NRC Report Numbers 50-327, 328/84-31, dated November 11, 1984, J. A. 01shinski to H. G. Parris

2. TVA letter, "Sequoyah Nuclear Plant Units 1 and 2, NRC-OIE Region II Inspection Report Numbers 50-327/84-31 and 50-328/84-31 Response to Violations," dated January 20, 1985, from J. W. Hufham to J. P. O'Reilly

3. TVA letter, "Sequoyah Nuclear Plant Unit 1 and 2, NRC-0IE Region II Inspection Report Numbers 50-327/84-31 and 50-328/84-31, Supplemental Response to Violation," dated November 26, 1985, from R. H. Shell to J. N. Grace

4. TVA letter, "Sequoyah Nuclear Plant Units 1 and 2, NRC-OIE Region

! II Inspection Report Numbers 50-327/84-31 and 50-328/84-31," dated l December 18, 1984, from J. A. Domer to J. P. O'Reilly l 5, Memorandum, "Sequoyah Nuclear Plant - Office of Inspection and i Enforcement (OIE) Inspection Report Numbers 50-327/84-31 and

, 50-328/84-31," dated October 28, 1985, from H. L. Abercrombie to i J. W. Hufham i

l 6. NRC memorandum, " Deviation Request From Appendix R of l 10 CFR Part 50," dated May 29, 1986, from. B. J. Youngblood to S. A. White

7. NRC Report Numbers 50-327/85-37 and 50-328/85-37, dated November 18, 1985, from D. M. Verre111 to H. G. Parris

8. Commitment or Corrective Action Tracking Report, CATS Number 85382, I

dated September 26, 1985 l

9. TVA memorandum, "Sequoyah Nuclear Plant - NRC-0IE Region II Inspection Report Numbers 50-327/84-31 and 50-328/84-31," dated December 19, 1984, from H. L. Abercrombie to H. W. Hufham Page 9 of 9

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