ML20244B219
| ML20244B219 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/05/1989 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-881, NUDOCS 8906130033 | |
| Download: ML20244B219 (11) | |
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- 4 TOLEDO EDISON Docket. Number 50-346
. A c.w enorgy con,ny License Number NPF-3 DONALD C. SHELTON Serial Number 1-881-Voe Presdent-Nuclear,
. t4191e49-eam.-
United States Nuclear Regulatory Commission Document Control Desk Washington, D.:C.
20555
Subject:
-' Fire Protection - Reply to Notice of Violation transmitted in Inspection Report 50-346/89-012' Gentlemen:
Toledo Edisca has received the subject Notice of Violation transmitted by Nuclear Regulatory Commission (NRC) letter dated May 5,.1989 (Log Number-1-2091). Attachment 1 contains the Company's response to the alleged violations.
Violation 89012-02 involves failure to assemble the Fire' Brigade immediately i
upon receipt of any fire' alarm received in the Control Room.
For the reasons l
identified in Attachment 1, Toledo Edison does not believe this activity 1
constitutes a violation and does not believe immediate assembly of the fire brigade for all alarms to be in the best interest of plant safety. Bovever,
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as discussed with NRC Region III staff, Toledo Edison vill not contest the i
violation at this time.
Based on discussion with the inspector during and after his inspection an'd subsequent review by the Company, of greater concern than the specific violation is the excessive number of nuisance alarms received in the Control l
Room. Toledo Edison agrees;that.the number.of nuisance alarms.is excessive and is committed to determine' the underlying cause and; to reduce. the number of these nuisance alarms.
l If you have any questions concerning this matter, please contact l
Mr. R. V. Schrauder, Nuclear Licensing Manager,-at'(419) 249-2366.
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Very truly yours..
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'k MAL /dlm Attachment cc:
P. M. Byron, DB-1 NRC Senior Resident Inspector A. B. Davis, Regional Administrator, NRC Region III i
D. J. Kubicki, NBC'NRR Staff Reviewer J. M. Ulle, NRC/ Region Inspector gp T. V. Vambach, DB-1 NRC Senior Project Manager 1-THE TOLEDO EDISON CC*APANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652 3
8906130033 890605 PDR ADOCK 05000346 Q-PDC
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Response to Notice of Violation
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.,Dockot' Numb 2r 50-346 Licin:2 Nu2btr NPF-3 Serial Number 1-881-
. Attachment 1 Page 1 Violation 89012-02:
Paragraph.2.C.(4) of Amendment Number 18 to Plant Operating License Number NPF-3 requires'the licensee to complete those modifications identified in Section 1 of the Safety Evaluation (SE) deted Jdly 26 1979,-including those modifications 3
specified in Table l'of.the SE.
Section B.14 of Table.1 of the SE requires.that the fire protection administrative controls be revised to follow the NRC document, " Nuclear Plant 1 Fire Protection Functional' Responsibilities, Administrative Controls-and Ouality Assurance." Paragraph 2.0 of Attachment Number 6 to this document states in part,
... administrative. controls...
that govern the fire protection program shall be prescribed by documented instructions-(and) procedures."> Further, Attachment
-Number 5 states, in part, that "the fire fighting procedures, should identify... the need for brigade assistance upon...
receipt of an alarm on the control room annunciator panel..."
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Contrary to the above, Procedure Number AB 1203.37,." Fire Procedure," did not prescribe'the need for fire brigade assistance upon receipt of an alarm in the control room. This allowed an unacceptable time delay in fire brigade response to a fire through the licensee's established practice of dispatching an individual to an alarmed area without assembling the fire brigade after the annunciation in'the control ~ room.
Response
Admission or Denial of Alleged Violation Toledo Edison acknowledges that the Davis-Beste procedures do not require the immediate assembly of the Fire Brigade'upon the receipt'of a fire. alarm in the Control Room, but does not consider this to be a violation of its commitment to Attachment 5 of the cited.1977 regulatory document (NRC letter, Vassallo to I
Roe, dated August 29, 1977, Log Number 280, " Nuclear Plant Fire l
Protection Functional Responsibilities, Administrative Controls j
and Quality Assurance"). Toledo Edison, however, recognizes i
that NRC's Office of Nuclear Reactor Regulation has recently reviewed a denial of this same violation by another licensee and-has upheld Region III's interpretation. Therefore, Toledo Edison vill not contest the matter further at this time.
Pending submittal of a request for deviation from the NRC's interpretation of the cited 1977 regulatory document and the subsequent NRC's review and approval of the deviation, Toledo Edison considers that its ability to achieve and maintain safe
.i shutdown in the event of a fire is adequate. The basis for this position is contained in the description of the current Davis-Besse Fire Brigade program and assessment of its adequacy, as discussed later herein.
Reason for the Alleged Violation The basis for Toledo Edison's position that this matter does not constitute a violation was discussed during a conference call on
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, Dock:t Nu;btr 50-346 j
i Licanza No;b:r NPF-3 I
Serial Number 1-881 l
Page 2 May 12, 1989 between NRC staff members, Hessrs. J. A. Grobe, J. H. Ulie and P-. H. Byron and Toledo Edison representatives, Messrs. R. V. Schrauder, H. A. Lalor and K. A. Spencer. When j
the initial commitment was made to the cited 1977 regulatory l
1 document, Toledo Edison.and many other licensees did not interpret the applicable wording to require immediate assembly I
of the Fire Brigade upon receipt of an alarm in the Control Room. Rather the words " identify... the need for fire brigade assistance..." was understood to mean determine' the need for brigade assistance. This common understanding is evidenced by the fact:that many licensees who committed to this document initially established their program such that upon receipt of an alarm an operator was dispatched to determine the need for brigade assistance. This understanding of the meaning of the words seemed to be confirmed when subsequent rulemaking (i.e.,
10CFR50, Appendix R, Section K) explicitly used the words
" determine the need."
As identified in NRC internal memorandum dated July 20, 1988, (Holahan to Hiller) the more careful wording of Appendix R was provided in recognition of the NRC
" staff's realization that under certain circumstances, such as false fire alarms, fire brigade response might be detrimental to plant safety." Toledo Edison wholeheartedly agrees with the staff's position.
Toledo Edison, and other licensees, committed to the cited 1977 regulatory document as early as 1978.
Since that time, the NRC has performed numerous fire protection program inspections.
including the Fire Brigade. No violations regarding the immediate assembly of the Fire Brigade had been issued in the 10 years since the cited 1977 regulatory document was issued. This indicates that the NRC had given at least tacit agreement to the licensees' interpretation of the commitment.
Consequently, Toledo Edison does not believe this activity constitutes a violation nor is it in the best interest of plant safety.
However, as discussed with NRC Region III staff, Toledo Edison vill not contest the violation at this time.
Based on discussion with the inspector during and after his inspection and subsequent review by the Company, of greater concern than the specific violation is the excessive number of nuisance alarms received in the Control Room. Toledo Edison agrees that the number of nuisance alarms is excessive and is committed to determine the underlying cause and to reduce the number of these nuisance alarms.
4 Issues to be assessed in an evaluation of the underlying cause j
include: multiple messages received in the Control Room for a single plant alarm, detector sensitivity settings, and detector reliability.
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l,' Dock 2t Nu2bar 50-34'6 l
Lic nsa Numb::r NPF-3 1
Serial Number 1-881 l
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Page 3-a Description of Current Fire Brigade Program Currently, Abnormal' Procedure DB-OP-02529 (AB 1203.37) describes i
the personnel actions to be taken upon receipt of a fire alarm in the Control Room. This procedure states:
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"The fire detection and radiation console located in the control room will alert the operator which fire detection zone and/or fire sprinkler system has been activated. The operator then can.
investigate the area affected as described on the CRT console."
The operator sent to investigate the plant area affected by.a fire alarm is one who is a qualified watchstander and trained to respond.to fire alarms received in the Control Room. This operator is knowledgeable of the procedure to contact the Control Room in the event.of'a fire,' the plant fire detection and suppression system, and the operation of the. plant equipment in the affected area. 'In most cases this individual is.or has been a trained. Fire Brigade member.
If a. fire-is identified, the operator is to notify the Control Room;immediately, regardless of the size of the fire. The operator could then attempt to extinguish or control the fire, pending the arrival' of the Fire Brigade.
Upon notification of an observed fire, the Control Room personnel would activate the fire alarm on the plant P.A. System and give the location,. intensity and. type of fire. The Fire:
Brigade vould then assemble and quickly proceed to the affected area under the~ direction of the Fire Brigade Captain.
As noted in Inspection Report 88-028, positive observations of a fire drill conducted in September 1988 was that'the number of fire brigade members responding exceeded NRC minimum requirements, the members vore proper protective clothing, and the fire brigade response to the fire scene vas timely.
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Additionally, the operations readiness area has'been relocated l
closer to the Fire Brigade turnout area since the issuance of q
Inspection Report 88-028 in order to improve the timeliness of
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the Fire Brigade response.
j Assessment of Adequacy
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The ability to achieve safe shutdown is not adversely impacted j
by Toledo Edison's practice of confirming that a fire exists prior to assembling the Fire Brigade. The response of the Fire i
Brigade is not the only means of fire protection for equipment j
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necessary to achieve and maintain safe shutdown. The fire protection program at Davis-Besse'is based upon the defense-in-depth concept and is not dependent upon any one aspect of the fire protection program. The defense-in-depth i
program has the following objectives l
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To prevent fires from starting; l
, Dock 5tNu2b:r50-346-Licenza Numb:r NPF-3 Serial' Number 1-881-Page 4 2)
To promptly detect, control'and extinguish those fires that do occur; and 3)
To provide protection for structures, systems and, components.important to' safety so'that a' fire that is not promptly extinguished by the fire suppression activities vill not prevent safe shutdown of the plant.
These objectives are identical to those specified in 10CFR50, Appendix R.
To. support the defense-in-depth objectives, Toledo Edison has installed significant fire protection systems to protect plant equipment in order to satisfy the requirements of Appendix'A to BTP APCSB 9.5-1..
Additionally, Toledo Edison is currently in the process of identifying and implementing various system modifications to satisfy.the requirements of 10CFR50, Appendix-R.
Pending the completion of the Appendix R modifications, Toledo Edison has implemented certain compensatory measures including fire watches, that have been accepted by the NRC as adequate to assure safe operation as documented in letter dated September 23, 1983, (Log Number 1375).
The Nuclear Utility Fire Protection Group (NUFPG), of which Toledo Edison is a member, has developed the following criteria to be used in identifying those fire areas which should require the immediate assembly of the' Fire Brigade upon receipt of a fire alarm that is transmitted to the Control Room:
- 1) Redundant trains of safe shutdown equipment required to achieve and maintain safe shutdown in the event of a fire (SSDF equipment) are contained in the same area, and
- 2) The fire loading in the area is sufficient to threaten SSDF equipment, considering both quantity and location of combustibles, and
- 3) The fire protection in the area does not meet the separation criteria of Appendix R,Section III.G.2, and 4)- The exemption or deviation applicable to the area took credit for prompt response of the fire brigade.
Toledo Edison intends to follow these guidelines in determining which areas, if any, would necessitate the need for immediately assembling the Fire Brigade upon receipt of an alarm. An initial evaluation using these criteria has been performed on Davis-Besse as it will exist following the planned upgrade.and additional fire protection features required to satisfy 10CFR50, Appendix R scheduled to be completed prior to restart from the
,Dockat Nu;bar 50-346 Licin2a Numb:r NFF-3
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Serial Number 1-881 Fage'5 sirth refueling outage. This initial review, using the NUFFG criteria, indicates that Davis-Besse vould not have any fire area that requires the immediate assembly'of the Fire Brigade upon the receipt of a fire alarm in the Control. Room. :Although Davis-Besse is' currently implementing the requirements of 10CFR50, Appendix R, those compensatory measures ~ accepted.by the NRC in Log Number 1375 are in place. Therefore, the intent of the NUFFG's criteria'is currently. satisfied.
Consequently, Toledo. Edison considers that the existing 1 fire protection features, supplemented by the' aforementioned compensatory measures, are adequate to protect structures, systems and components-important to safety and ensure safe shutdown of the plant pending the confirmation of a fire and the:
arrival of the Fire Brigade.
Toledo Edison believes that the' current p'ractice of assembling the Fire Brigade only'after confirmation of a fire is preferred-to assembling the Fire Brigade for every alarm.
By screening.
fire alarms for possible false or nuisance. alarms, the Fire Brigade would be summoned only with cause'and have an enhanced attitude and be better mentally prepared for their duties when called upon in the event of'an actual fire. Toledo Edison considers that assembling'the Fire Brigade without cause could unintentionally lead to diminished "esponse on the part of some Fire Brigade members. Additionally, the current Davis-Besse Fire Brigade is limited to members of the Operations staff.
This membership provides a Fire Brigade which has aut enhanced familiarity of the plant configuration and cognizance of plant-equipment potentially affected by a postulated fire.
Such a Fire Brigade membership exceeds the minimum regulatory requiremen d ar.J 'e superior to a staffing of dedicated Fire Brigade me: a "
i t vever, assembling the Fire Brigade for every fire alarm wee'd norecessarily disrupt the regular duties of plant operators v;< are on call as Fire Brigade members.
Toledo Edison also believes that a uniform response to the receipt of a fire alarm in the Control Room is preferred.
Toledo Edison considers it impractical to require the~ Fire Brigade to be summoned for an alarm for certain fire areas and not to summon the Fire Brigade for. fire alarms in other areas.
Such a requirement to selectively summon the Fire Brigade could lead to confusion and be an added burden for the Control Room operators. Additional administrative controls to ensure Control Room operators selectively summon the Fire Brigade would simply consume more Control' Room operator time and more likely lead to administrative errors in implementing procedures for an issue that would not significantly improve plant safety in the event of a fire.
. Docket Nurb:r 50-346 Licanza Numbar NPF-3 Serial Number.1-881 Attachment.1 Page 6 In summary, Toledo Edison' believes that confirmation of.a fire prior to assembling the Fire Brigade is-adequate to ensure the safe shutdown of the plant in the event of a fire and is preferred to assembling the Fire Brigade for every alarm.
Corrective Actions 1
Toledo Edison has reviewed AB 1203.37 and vill improve the j
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Control Room response to fire alarms by requiring the Fire Brigade to immediately assemble if. multiple confirming and diverse indications of a fire are transmitted to the Control i
Room.
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This procedure revision will improte the response to fire alarms since assembling the Fire Brigade for multiple confirming and l
diverse alarms would be a consistent practice for the Control Room operators to follow and minimize the number of unnecessary Fire Brigade assemblies and disruptions in plant operation.
1 Date When Full Compliance Will Be Achieved The procedure revision stated above will be completed by l
August 31, 1989. An evaluation of nuisance fire alarms will be addressed in the review of NFPA Code 72D to be submitted to NRR l
by July 31, 1989. By September 30, 1989, Toledo Edison will j
also submit to NRR a request for a deviation from NRC's.recent i
interpretation of the cited 1977 regulatory document. 'This request will contain a comparison of Davis-Besse to the NUFFG criteria to determine when the Fire Brigade is to immediately assemble due to the receipt of a fire alarm in the Control Room.
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... Dock 3t Numbar 50-346
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Liccn:o Numb:r NPF-3 Serial Number 1-881 Page 7 Violation 89012-06:
Paragraph 2.C.(4) of Amendment Number 18 to Plant Operating License Number NPF-3, requires the licensee to complete those J
modifications identified in Section 1 of the SE dated July 26, 1979, including those modifications specified in Table 1 of the f
SE.
Section B.14 of Table 1 of the SE requires that the fire l
protee' ion administrative controls be revised to follow the NRC
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docume..t, " Nuclear Plant Fire Protection Furictional i
Responsibilities, Administrative Controls and Quality.
Assurance.' Paragraph 8.0 of Attachment Number 6 to this document requires, in part, that conditions adverse to quality be promptly identified and corree'.ed.
Contrary to the above, Toledo Edison Company failed to assure that corrective actions taken in response to a previously identified Severity Level IV violation (failure to establish required fire watches) were adequate in that on November 17, 1988, and Januar/ 12, 1989, the licensee failed to establich continuous fire vatches within one hour as required by Technical Specification 3.7.10.a.
Acceptance or Denial of the Alleged Violation Toledo Edison accepts the alleged violation.
Reason for the Violation The reason for the violation is attributed to personnel error in not correctly following the established administrative controls.
Corrective Actions Taken and Results Achieved The instances cited by tha subject violation vere self-identified by Toledo Edison and reported to the NRC in Licensee Event Reports (LER)88-024 and 89-002. These were attributed to personnel error in not correctly following the procedure. The inntance described in LER 88-024 involved the j
failure of the Shift Supervisor to use the fire protection procedure in order to determine the correct fire watch to establish. The instance described in LER 89-002 involved the use of the fire protection procedure but the Shift Supervisor did not identify the room number requiring the fire watch.
Toledo Edison has evaluated each of these instances and detormined that they are isolated instances without a common I<
cause. Appropriate individuals involved were counseled.
- 1 ledo Edison prompr.ly identified the personnel errors in both instances and took the appropriate corrective actions.
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m Dockst Numbsr 50-346L 953'"
Licensa Number NPF-3 e
LSerial Number 1-881 Page 8 The previously identified. Severity Level-IV violation involving fire watches was issued.in NRC letter dated October'19, 1988,
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(Log Number 1-1943) transmitting Inspection-Report 88-028. :This j
violation identified,four. instances where~ continuous ~ fire vatches had not been established within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> as. required byl l
the Davis-Besse' Technical Specifications. These four_ instances.
vere also self-ide'tified by Toledo Edison and reported to the n
NRC in LERs88-005, 88-009,88-010 and 88-011.
Two of these previous instances were' attributed to an inadequate-fire.
protection procedure.while the other two instances were due to
.j personnel erroriin not~following the procedure.-
1 The instance described in LER 88-005 involved the failure to establish a continuous. fire watch in accordance with the
'l Davis-Besse Technical Specifications. The Shift Supervisor was l
not aware'that ~ he fire detection on each side of an' inoperable.
t fire barrier was inoperable. The instance described in LER i
88-10 involved the-failure to establish a continuous fire watch 1
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in accordance with_the Davis-Besse Technical Specifications.
The Shift Supervisor did not recognize.that a fire alarm in a sprinkler system, the result of maintenance on the system, would j
prevent the transmission of alarms from certain fire detection systems and render those systems. inoperable.
Both cases were the result of inadequate procedures'to provide the Shift Suptrvisor with the necessary guidance in determining the i
appropriate fire'vatches required by Technical Specifications.
The instance described in LER 88-009 involved the fail'ure in June 1986 to establish a continuous fire.vatch as a result of a 4
deficient fire door. The necessary continuous fire watch vas subsequently established, but was' inappropriately terminated by the Assistance Shift Supervisor,.following maintenance. This i
decision was made based on a review of another outstanding Maintenance Work Order failed to identify that ongoing repair work had rendered the fire door. inoperable.
The instance-described in LER 88-011 involved the inappropriate termination of a continuous fire watch following maintenance. The Shift Supervisor failed.to recognize that the partial performance of the Surveillance Test,_ performed as. post-maintenance testing, was not adequate to satisfy the Technical Specification surveillance requirements and did not consult'the' Critical Surveillance Test Report which identified this surveillance requirement as past due. Both instances were the~ result-of Control Room personnel inappropriately terminating continuous fire watches following maintenance contrary to existing.
procedures and practices.
l The only commonality between these occurrences is the significant changes teking place in the Davis-Besse fire protection program. Toledo Edison has been upgrading the existing fire protection program at Davis-Besse, which has resulted in significant procedure revisions and substantial number of fire protection components being declared inoperable,
o Docket Number 50-346 License Number NPF-3 Serial Number 1-881 Page 9 mainly fire barriers, pending completion of repairs and testing.
The number of inoperable fire protection components combined with significant procedure revisions' created an increased opportunity for failure on the part of Control Room personnel and resulted in repeated failures to establish the continuous fire watches.
However, Toledo Edison believes that as more fire protection equipment is restored to an operable condition and-Control Room personnel become more familiar with the revised-procedures, the number of failures to establish the correct fire watch required by Technical Specifications will be minimized.
The reduction in' fire watch violations is currerstly evident. In
'1988, Toledo Edison issued 8 LERs due to fire watch violations.
Up to May 31, 1989, there has been only 1 LER for a fire watch db violation, which is a substantial reduction. Toledo Edison believes that the corrective actions taken to date have led to this reduction in fire watch violations and that no additional corrective action is necessary.
Date When Full Compliance Vill Be Achieved y
The corrective actions taken to date, as discussed above and individually in the LERs, have been effective in reducing the number of fire watch violations. Toledo Edison considers that it is presently in full compliance.
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