ML20235V050

Insp Rept 50-289/89-05 on 890214-15.No Violations Noted. Major Areas Inspected:Performance of Visual Fire Damper Surveillance Test,Surveillance Test Records,Security Records of Personnel Access & Witnessing of Surveillance Test

ML20235V050
Person / Time
Site:	Three Mile Island
Issue date:	02/21/1989
From:	Durr J, Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235V044	List: ML20235V041 ML20235V050
References
50-289-89-05, 50-289-89-5, NUDOCS 8903100011
Download: ML20235V050 (4)

See also: IR 05000289/1989005

Text

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U.S. NUCLEAR' REGULATORY COMMISSION

REGION I

. Report No. 50-289/89-05

Docket No. 50-289

License No. DPR - 50 Category C

Licensee: GPU Nuclear Corporation

P.O. Box 480

Middletown, Pennsylvania 17057

Facility Name: Three Mile Island Unit 1

Inspeccion At: Middletown, Pennsylvania

Inspection Conducted: February 14-15, 1989

Inspector: - nfn

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Approved By: b

Thomas T. Martin, Director

Division of Reactor Safety

Insoection Summary: Insoection on February 14-15,1989 (Recort No.

50-289/89-05)

Areas Insoected: Special inspection to resolve questions relating

to the performance of the visual fire damper surveillance test.

The inspection. consisted of a review of surveillance test

records, an evaluation of security records of personnel access

and the witnessing of the surveillance test.

Results: The inspection disclosed that the fire damper visual

surveillance can be adequately performed within the times noted

in the March 30-31, 1989, licensee surveillance report.

8903100011

DR 890222

ADOCK 05000289

PDC

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1.0 Persons Contacted

R. Barth, Unit 1 Fire Protection Engineer

G. Broughton, Operations and Maintenance Director, TMI-1

J. Enders, Site Protection Lt.

H. D. Hukill, Director, TMI-1

T. A. O Cannor, Lead Fire Protection Engineer

S. Otto, Licensing Engineer

H. B. Shipman, Operating Engineer Manager l

The foregoing personnel attended the Exit Interview conducted on

February 15, 1989 with the exception of H.D. Hukill. Other

personnel were contacted during the course of the inspection as

activities interfaced with their areas.

2.0 Purpose and Scope

The purpose of this inspection was to evaluate the performance of

the visual fire damper surveillance test to ascertain the time to

execute the surveillance and the level of quality achievable within

that time. The inspection covered all fire dampers listed in

Surveillance Procedure No. 1303-12.23, Revision 8.

2.1 Introduction

NRC Inspection Report 50-289/88-23 noted that the Visual Inspection

of Fire Dampers performed on March 30-31, 1988, was accomplished

in only 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> versus the previous surveillance which was

accomplished in approximately 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />. The licensee issued a

letter, C311-88-2157, dated November 17, 1988, providing additional

information in explanation of the differences in the times required

to perform the surveillance. Specifically, the licensee noted that

the previous surveillance was a combined functional and visual

surveillance versus a visual inspection.

2.2 Inspection

On February 14, 1989, the licensee provided an operating engineer

and 2 auxiliary operators to perform the surveillance test while

the NRC inspector witnessed the procedure. This is the usual

complement used to perform this test; the operating engineer

observing the condition of the dampers and the auxiliary operators

assisting in moving ladders, removing access covers and grill

plates and providing aid in gaining access to difficult locations.

The NRC inspector observed the opening of the fire damper access

covers, the inspection of the interiors and fusible links, the

closing of the access covers and the general activities in gaining

access to perform the surveillance test. The inspector

independently examined the condition of most of the fire dampers

to confirm that the fusible links were intact, the dampers were not.

blocked and that the condition of the dampers were indicative of

recent inspection. No unacceptable conditions relative to the

dampers or the surveillance test were noted by the inspector.

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The inspector noted the times required to perform the

February 14, 1989, inspections, the areas requiring access and the

overall duration of the surveillance test. The total time required

to perform the surveillance test was approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The

surveillance test began in the control room shortly after 1:00 p.m.

and was essentially complete at 4:00 p.m. Further, the security

records for area access for the previous surveillance team were

reviewed to determine the relative times spent in each area and

compared to the times spent by the February 14, 1989, surveillance

team. The times expended in each area by the March 30-31, 1988,

team compared favorably with the February 14, 1989 team. In almost

every case, the February 14, 1989, team took less time to perform

the test, indicating that the duration of the March 30-31, 1988

surveillance test was of sufficient length to adequately perform

the test.

2.3 Findings

Based on the independent visual inspection and the review and

analysis of the security records, the inspector concluded that the

March 30-31, 1988, visual fire damper surveillance test was

adequate and that sufficient time was expended to perform the test.

The inspector noted that the original surveillance test record

indicated, in some areas, that one inspector performed most of the

tests; however, the licensee's internal examination of this issue

disclosed that multiple personnel had performed the tests but the

tests were signed by a single individual without attribution to the

activity of other personnel. The licensee's review determined that

the original data sheet with the initials of the performer had been

contaminated and the information had been transferred to the record

copy of the surveillance test. This practice is under review by

the licensee to insure a consistent policy is provided in

situations such as this to establish what the signatures represent.

The inspector observed that several of the fire dampers are in hard

to access areas. In some cases, the access represents an

industrial safety hazard to the individual performing the

inspection. In one instance, the person performing the

surveillance is required to climb above the false ceiling in the

control room with a potential of falling into the control panels.

This creates an industrial and operating safety hazard. The

licensee committed to examine the hazards associated with the

performance of this surveillance and take appropriate corrective

actions.

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3.0 Exit Interview

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I On February 14, 1989, at the conclusion of the inspection, an exit

! interview was held with members of the licensee's staff listed in

paragraph 1.0. The inspector discussed the scope of the inspection

and the findings.

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No written material was provided to the licensee during this

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inspection,

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