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Insp Rept 50-346/89-12 on 890313-17 & 0418.Violations Noted. Major Areas Inspected:Implementation of Licensee Fire Protection Program Through Followup of Licensee Action on Previous Insp Findings
	ML20246K764
Person / Time
Site:	Davis Besse
Issue date:	05/05/1989
From:	Gardner R, Ulie J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20246K759	List: ML20246K754; ML20246K761; ML20246K764;
References
	50-346-89-12, NUDOCS 8905180142
	Download: ML20246K764 (9)
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U.S. NUCLEAR REGULATORY COMMISSION

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REGIDH III

. Report No. 50-346/89012(DRS)-

' Docket No. 50-346' License No. NPF-3

Licensee: Toledo Edison Company-

'300 Madison Avenue

Toledo, OH 43652

Facility Name: . Davis-Besse Nuclear Power Station

' Inspection At: . Oak Harbor,.OH 43449

' Inspection Conductedi March 13-17 and April 18, 1989

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Inspector: Jos ph M. Ulie

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Approved By: Ronald N. Gardner, Chief 5/k87

Plant. Systems Section Date

Inspection Summary

Inspection on March 13-17-and April' 18, 1989 (Report No. 50-346/89012(DRS))

Areas Inspected: Routine, unannounced inspection to review the implementation

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of the licensee's fire protection program through a followup of licensee

action on previous inspection findings; Licensee Event Reports (LER); and

'Information Notices (30703,.64704, 90712, 92700, and-92701).

Results: Of the three areas' inspected, two violations were identified (two

recurring incidents of personnel error that resulted in continuous fire watches

not being established within one hour - Paragraph 3.e; and fire procedure

inadequacy in that the procedure did not prescribe the need for fire n ri

assistance upon receipt of an alarm in the control room - Paragraph 2.e)gade .

Additionally, four other violations were also identified; however, in accordance

with 10 CFR Part 2, Appendix C, Section V.G., a Notice of Violation was not

issued. The~first of these violations regarded differences between the installed.

' fire detection zones.and the operability requirements required by Technical

Specifications (Paragraph 2.c). The second of these violations regarded'the

failure to meet the fire detection system supervised surveillance requirements

(Paragraph.3.b). The third violation regarded a failure to verify the correct'

. position of the fire suppression isolation valves as required (Paragraph 3.c).

The fourth violation regarded the failure to perform an automatic actuation of

the pre-action sprinkler system (Paragraph 3.d). Although numerous deficiencies

were identified, most of these deficiencies were of minor' safety significance.

The licensee'is adequately addressing and correcting these deficiencies. A

-licensee strength was noted regarding the positive attitude of the licensee's

fire protection staff (Paragraph 2.h).

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8905280142 890505

PDR ADOCK 05000346

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DETAILS

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l~ 1. Persons Contacted

Toledo Edison Company (TEC)

D. Brandt, Operations

R. Collings, Quality Assurance

R. Flood, Operations

S. C. Jain, Director, Engineering

+*H. Lalor, Licensing

T. Myers, (acting for D. Shelton, Vice President), Director,

Technical Services

J. Roskoph, Fire Protection Compliance

R. W. Schrauder, Manager, Licensing

F. Sondgerroth, Licensing

L. F. Storz, Plant Manager

J. W. Strausser, Fire Protection Compliance

L. Young, Fire Protection Compliance

A. K. Zarkesh, Independent Safety Evaluation

Nuclear Regulatory Commission (NRC)

D. Kosloff, Resident Inspector

The inspector also contacted other licensee and contractor personnel I

during the course of the inspection.

Denotes persons present at the exit interview on March 17, 1989.

+ Denotes persons participating by telecon in the exit interview on

April 18, 1989.

2. Action On Previous Inspection Findings

a. (Closed) Open Item (346/86005-05): Ruskin had published information

indicating that a backward "5" hook may prevent proper closing of

fire dampers. During a previous inspection, the inspector was unable

to obtain documentation which indicated that the licensee had addressed

the question regarding the backward "S" hook.

During this inspection, the inspector reviewed procedure

No. DB-FF-03024, " Eighteen Month Fire Damper Visual Inspection,"

Revision 00, dated March 24, 1988, and procedure No. DB-MM-09039

(formerly MP 1405.07), " Fire Damper Maintenance," Revision 00,

dated December 6, 1988. Each of these procedures have incorporated

steps that specify in writing or by drawing the correct placement

of an "S" hook assembly. Therefore, this concern is considered

resolved,

b. (Closed) Unresolved Item (346/86006-03(DRS)): The inspection team l

questioned whether Technical Specification (TS) compensatory

measures were acceptable for extended periods with all required

fire dampers inoperable. Discussions between the Office of Nuclear ;

Reactor Regulation (NRR) and the inspector indicated that the {

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, ' licensee's schedule for resolving the fire damper issue had been.

previously discussed and accepted by the NRC. NRR considered

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the compensatory measures to be adequate. A review of the

licensee's long term corrective action will be reviewed during a

future inspection. This item is considered closed.

c. (Closed) Unresolved Item (346/86016-03): inis item regarded

discrepancies between the plant TS and the installed number '

of fire detectors in'four plant areas as described in Licensee

Event Report'(LER) No. 86025.

A review of TS 3.3.3.8 revealed four differences between the

installed fire detection zones and the operability requirements.

In two cases, there were flame detectors installed'instead.of the

listed smoke detectors and in the other cases there were fewer

detectors installed than were required by the TS.

Upon being notified of the condition, the shift supervisor declared

the fire detection zones (FDZ) inoperable and initiated the required

roving fire watches.

In order.to correct these~ discrepancies, a request for TS change

was to be prepared to bring the TS into agreement with the National

Fire Protection Association (NFPA) codes.

The licensee's analysis of these discrepancies identified that

zones FDZ-320A and FDZ-321A had a flame detector installed'instead

of a smoke' detector;'however, the flame detector was installed per

the NFPA code for the type of hazard (diesel fuel) involved. In

-addition, it was determined to be a preferred type of detector-for

these applications. Therefora, these configurations were determined

to be acceptable.

A third discrepancy was identified in zone FDZ-208, where eight

instead of ten detectors were installed. The licensee's fire

protection engineer performed a review of the NFPA 72E code which

showed that eight detectors provided sufficient coverage for this

zone.'

The fourth discrepancy was identified in zone FDZ-516, where one 1

detector was installed. TS 3.3.3.8, Table 3.3-14, Item 4.b,

required that a minimum of five smoke detectors be operable in this

zone. The zone consists of the non-radwaste ventilation ares and

the turbine building ventilation area and houses the backup

electrical cabling for channel 1 of the control room emergency

ventilation condenser and fan. As stated in the Fire Hazards

Analysis Report and in the submitted LER, and as indicated by

licensee personnel, the ability to operate the plant to achieve

hot or cold shutdown would not have been affected by an undetected

fire. This zone will be modified (Field Change Request 86-163)

by the end of the sixth refueling outage to bring it into confor-

L mance with the NFPA code standards.

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. ~The differences between the. installed fire detection zones and the

, -operability requirements required by Technical Specifications are

considered a violation (346/89012-01(DRS)).

It was determined that the tests of 10 CFR Part 2, Appendix C,

Section V.G were met, consequently, no Notice of Violation will

be issued, and this matter is considered closed.

d. (0 pen) Open Item (346/87027-02): A number ~of deficiencies were

observed in plant fire drills during previous NRC inspections.

During the last two.-regional inspections (346/87027 and 346/88028),

three fire brigade drills were witnessed. Although the licensee has

initiated actions to improve and maintain the overall fire brigade

readiness, the licensee's performance ~during these drills provided

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indication that additional licensee attention was necessary. .The

licensee has. signed an agreement with Sun.011 in Oregon to conduct

fire training. A fire training building at Sun.011 is under construc-

tion and will be available periodically for licensee fire brigade use

during the summer or fall of 1989. In addition, the licensee is in

the process of revising the fire pre-plan strategies. Further,

according to'the licensee's staff, a fire brigade leader two part

training. course has been completed by each of the brigade leaders and

all. shift brigade members have been trained to a recently implemented

. fire brigade: training procedure. This. item will remain open pending

verification of licensee actions to improve fire brigade performance,

e. (Closed) Unresolved Item (346/87027-04): The licensee's fire

procedure did not prescribe the need for fire brigade assistance

upon receipt of a fire alarm in the control room (fire alarm

annunciator panel). This issue was categorized as an unresolved

item pending further evaluation of this issue by NRR. The NRC has

completed its review of this issue. Based on this review, the NRC

has concluded that.a violation of NRC requirements did occur.

Therefore, the failure of fire procedure No. AB 1203.37 to prescribe

the need'for fire brigade assistance upon receipt of a fire alarm is

considered a violation (346/89012-02(DRS)) of the licensee's fire

protection license condition as described in the Notice of Violation.

According to the licensee, one reason for not relying on the first

unplanned activation of the fire detection system was the number of

spurious fire alarms that were occurring. The occurrences of

numerous spurious fire alarms are also of concern to the NRC.

Therefore, the licensee was informed that corrective action should

be: initiated to resolve the spurious fire alarm problem.

As the licensee is aware, discussions between a nuclear utility

industry group, of which the licensee is a member, and the NRC have

been occurring on this subject. It has been determined that the

NRC would consider a deviation from the 1977 governing fire protection

requirements. In support of such a request for deviation, a licensee

would be required to conduct a review to determine which fire areas

in the plant contain redundant safe shutdown systems or contain

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significant fire hazards that represent a threat to the safe shutdown i

capability. Based on.this review, it would be necessary upon receipt

of a fire alarm in these locations for the licensee to dispatch the ;

fire brigade to the fire brigade equipment station (s), in addition to (

dispatching an operator to the alarmed area. If a licensee chooses to j

deviate from the governing fire protection requirements, the licensee

is required to submit a formal request to NRR. -

f. (Closed) Open Item (346/87027-05): A concern was identified )

concerning wooden planking used in scaffolding which could create a j

patantial sprinkler head spray pattern obstruction. In addition, the !

planking was considered a combustible hazard. These concerns were !

strengthened due to the scaffolding being left in-place for extended {

periods with no apparent administrative controls. Eight of the 1

14 areas had sprinkler systems installed in which certain sprinkler i

head spray patterns did appear to be obstructed, l

During this inspection, it was determined that the licensee has i

implemented Maintenance Procedure (MP) No. DB-MM-01637.00,

" Scaffolding Erection and Removal Guidelines," Revision 00, dated

October 18, 1987. While performing plant tours of the plant on l

March 14 and 15, 1989, the inspector observed that the licensee has

improved controls regarding scaffolding assemblies left in-place

for extended periods. .v.so, the number of scaffold assemblies has

been reduced. The inspector concluded that the scaffolding

procedure was being adequately implemented. This has improved the

fire protection sprinkler system effectiveness. Therefore, this

' item is considered closed.

g. (Closed) Violation (346/87027-07): The licensee failed to complete ,

the modifications identified in Sections B.9, B.10, B.12, and B.13

of Table 1 of the Safety Evaluation Report.

In complying with the overall fire protection / safe shutdown

requirements, the licensee had previously submitted a schedule for

the subject modifications yet to be completed. In the interim,

appropriate compensatory measures are in place and will remain in

place until the modifications are completed. The NRC has reviewed

and accepted the licensee's schedule for complying with the

Appendix R requirements. Therefore, this item is considered closed.

However, the licensee must maintain the in-place fire protection

features described in the applicable license conditions unless relief

is granted by NRR. The NRC will continue to review " Conditions Adverse

to Quality Reports" on a case by case basis. Therefore, this item is '

considered closed.

h. (Closed) Unresolved Item (346/89005-05(DRS)): The licensec determined l

that certain hose stations (HCS) did not have the necessary length of

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fire hose attached to the standpipe. This condition was addressed

in Potential Condition Adverse to Quality Report (PCAQR) No. 88-0084.

This was the second time a problem of this type had occurred within

the previous two years.

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During this inspection, the inspector conducted an audit of HCS

locations and confirmed by visual observation that sufficient hose

lengths were installed. The inspector reviewed licensee drawings

which indicated that hose length was considered as part of the NFPA

code conformance review. Also, according to licensee personnel who

performed this review, certain plant area hose stations and racks j

having questionable hose lengths were physically measured to verify

sufficient fire hose coverage. Discussions were also held with

licensee fire protection personnel regarding two plant areas where

the hose length coverage deviated from both NRC and NFPA guidelines.

No discrepancies were noted during this review and a positive

attitude was displayed by the licensee's staff. Based on the above

review, this item is considered resolved.

3. Licensee Event Report (LER) Followup (92700, 90712)

The inspector reviewed the following LERs through discussions with

licensee personnel and a review of event report records:

a. (Closed) Special Report (346/86017-LL): The low density silicone

foam for a fire barrier penetration in the main steam line entering

the east wall-of main steam line room 602 was found degraded.

As an interim measure the penetration was stuffed with Kaowool.

According to the report, fire watches had previously been implemented

for this room due to other Appendix R considerations. The root cause

of this problem was the misapplication of material for the expected

inservice condition. The low density silicone foam (SF-20) is rated

for use up to 425 F. The main steam line reaches temperatures of

approximately 600 F during normal operation. The licensee conducted

an as-built verification of penetration seals to ensure that the seal

designs met the penetration design and functional requirements. The

licensee has an ongoing seal program to upgrade and maintain the

penetration fire seals. According to the licensee's response to

Information Notice (IN) 88-56 which discusses this event subject

matter, the concerns identified in the Information Notice are addressed

in installation and inspection procedures including Procedure Nos.

MP 1405.03, ST 5016.13 and DB-FP-03025. Degraded penetration fire

seals were observed during plant tours conducted on March 14 and 15,

1989; however, the licensee was already aware of the deficiencies as

demonstrated by attached orange tags (see Paragraph 4 for further !

review of the penetration seal area). Based on the established

compensatory measures and the corrective actions taken, the NRC has

no further questions regarding this matter.

b. (Closed) Licensee Event Report (LER) (346/88003-LL): A review by j

licensee fire protection personnel determined that the supervised

circuit ground fault detection on Fire Detection Panel C-4720 was

inoperable due to a ground fault module failure and a wiring error.

According to the event report, the module was replaced and the wiring

was corrected under Maintenance Work Order (MWO) No. 1-87-3859-00 on

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December 21, 1987. In addition, the licensee's staff specified that

although the supervised surveillance requirements were not met, the

ability of the fire detection system to actuate under fire / smoke

conditions was not affected. Further, the event report indicated

that appropriate personnel who work in areas of fire protection,

instrument and controls, maintenance and operations will participate

in reviews of this event. The training on the lessons learned from

the event was to be completed by April 10, 1988. The failure to meet

the fire detection system supervised surveillance requirements is

considered a violation (346/89012-03(DRS)).

It was determined that the tests of '.0 CFR Pcrt 2, Appendix C,

Section V.G were met; consequently, no Notice of Violation will

be issued, and this matter is considered closed.

c. (Closed) LER (346/88021-LL): During the performance of a NFPA 13 code

compliance review, it was discovered that two in-line isolation valves

in the fire suppression sprinkler system had not been verified to be

in the correct position as required.

Subsequent verification by the licenst.e independently confirmed that

the two isolation valves, FP-116A and FP-ll7A, were in the correct

open position and were locked in that position. Consequently, the

applicable suppression system (s) would have been capable of operating.

as designed. According to t'e event report, the Surveillance Test

(ST) procedure has been revised to include these valves and a design

change request was scheduled to be written by November 14, 1988,

to update the applicable drawings. The failure to verify the correct

position of the fire suppression isolation valves as required is

considered a violation (346/89012-04(DRS)).

It was determined that the tests of 10 CFR Part 2, Appendix C,

Section LG were met, consequently, no Notice of Violation will

be issued, and this matter is considered closed.

d. (Closed) lea (346/88022-LL): During a review of a failure of

Surveillance Test (ST) 5016.15, fire protection personnel concluded

that the test specified only manual actuation of diesel generator

room pre-action sprinkler systems and did not perform an automatic

actuation as required.

The licensee performed a successful simulated automatic actuation of

the diesel generator room pre-action sprinkler systems after the

discovery of this event. Consequently, it was determined that the

pre-action sprinkler systems would have been capable of operating as

designed. Accord *ng to the event report, temporary approval (TA)

TA-88-4886 for ST 5016.15 was approved on October 14, 1988, to require

simulated automatic actuation of diesel generator room pre-action

sprinkler systems. The pre-action sprinkler systems for the diesel

generator rooms were successfully tested. However, the failure to

perform an automatic actuation of the pre-action sprinkler system as

required is considered a violation (346/89012-05(DRS)).

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. It'was determined that the tests of 10 CFR Part 2, Appendix C,

. Section V.G were met, consequently, no Notice of Violation will be

issued, and this maf r is considered' closed.

A review'by the insp tor'of two other LERs identified by the licensee

as similar occurrences concluded that this violation could not have

reasonably been expected to have been prevented by the licensee's

corrective actions for either of the other two specified LERs.

e. (Closed) LERs (346/88024-LL and 346/89002-LL): Due to personnel

error on the following two occasions, continuous fire watches had

Lnot been established within one hour as required:

(1) On November 17, 1988, at approximately 1100 hours0.0127 days 0.306 hours 0.00182 weeks 4.1855e-4 months , an alarm :

was received for zone FDZ 235 makir.g this detection zone

inoperable. An hourly fire watch was established at 1110 hours0.0128 days 0.308 hours 0.00184 weeks 4.22355e-4 months .

TS 3.7.10 required a continuous fire watch to be established

within one hour if the inoperable barrier does not have

operable fire detection on at least one side. Later that day,

at approximately 1510 hour0.0175 days 0.419 hours 0.0025 weeks 5.74555e-4 months .;, the relieving shift supervisor

discovered that the previous shift had incorrectly established

an hourly panel watch instead of the required continuous fire

watch. The continuous watch was established at 1523 hours0.0176 days 0.423 hours 0.00252 weeks 5.795015e-4 months .

This condition had existed for approximately three hours and

twenty-three minutes beyond the one hour action statement

requirement.

(2) On January 12, 1989, at 2315 hours0.0268 days 0.643 hours 0.00383 weeks 8.808575e-4 months , the oncoming shift

supervisor noted that fire door 422 was blocked open with

the wrong type fire watch established. TS 3.7.10 requires a

continuous. fire watch to be established within one hour if the

inoperable barrier does not have operable fire detection on at

least one side. The subject barrier does not have detection on

either side. The door had been blocked open at 2125 hours0.0246 days 0.59 hours 0.00351 weeks 8.085625e-4 months when

the knob pulled'off leaving only the stem. The shift supervisor

on duty when this occurred folicwed the correct process for

determining if and what type watch would be necessary. However,

a personnel error was made while implementing fire barrier

Procedure No. DB-FP-00009, Revision 02, in that room 422A was

evaluated for operable detection in lieu of room 422. This room

did have operable detection on one side of the barrier. This led

the shift supervisor to authorize, incorrectly, blocking the

door open with a roving fire watch as compensation. The door

was subsequently restored to operable status. This condition

had existed for approximately fifty minutes beyond the one hour i

action statement requirement.

These two examples of personnel error in not properly following l

the fire protection procedure resulted in an incorrect type of l

fire watch being established. During 1988 (Inspection Report

346/88028), four other instances occurred whereby continuous l

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. fire watches had not been established within one hour as required.

Two of those occurrences were attributed to an inadequate fire

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protection procedure while the other two * elated to personnel

error in not following the procedure. Dr to the recurring

examples of personnel error in failing t properly follow the

fire protection procedure, this is cons .ered a violation

(346/89012-06(DRS)) as described in tb Notice of Violation.

4. Information Hotices

The inspector. reviewed the licensee's responses to the following

Information Notices (IEN's): (1) IEN 88-04, " Fire Barrier Penetration

Seals"-response dated September 22, 1988; (2) IEN 88-56, " Silicone Foam

Penetration Seals"-resporse dated December 21, 1988; and (3) IEN 88-64,

" Reporting Fires In Nuclear Process Systems At Nuclear Power Plants"-

response dated December 12, 1988. This review concluded that the

licensee has performed an appropriate evaluation of the identified IFNs,

and that, as addressed in the IENs, corrective actions where necessary

have been initiated to address the technical aspects of the notices.

Where discrepancies were noted by the inspector during plant tours of

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penetration fire barriers, the licensee was aware of the discrepancies

and appropriate measures were being taken to resolve those discrepancies.

5. Violations For Which A " Notice of Violation" Will Not Be Issued .

The NRC uses the Notice of Violation as a standard method for formalizing

the existence of a violation of a legally binding requirement. However,

because the NRC wants to encourage and support licensee's initiatives

for self-identification and correction of problems, the NRC will not

generally issue a Notice of Violation for a violation that meets the

tests of-10 CFR 2, Appendix C,Section V.G. These tests are: (1) the

'tiolation was identified by the licensee; (2) the violation would be

categorized as Severity Level IV or V; (3) the violation was reported to

the NRC, if required; (4) the violation will be corrected, including

measures to prevent recurrence, within a reasonable time period; and

(5) it was not a violation that could reasonably be expected to have been

prevented by the licensee's corrective action for a previous violation.

Violations of regulatory requirements identified during the inspection

for which a Notice of Violation will not be issued are discussed in

Paragraph 2 and 3.

6. Exit Interview

The inspector met with licensee representatives (denoted in Paragraph 1)

on March 17, 1989, and summarized the scope and findings of the inspection

activities. The inspector also discussed the likely content of the

inspection report with regards to documents or processes reviewed by the

inspector. The licensee did not identify any such documents or procesees 1

as proprietary. The licensee acknowledged the findings of the inspection. {

On April 18, 1989, a conference call was held between the inspector and j

licensee representatives to discuss issues that remained open at the time

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ML20246K764

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