ML20246K764
| 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: |
| References | |
| 50-346-89-12, NUDOCS 8905180142 | |
| Download: ML20246K764 (9) | |
See also: IR 05000346/1989012
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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
W1. &
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Inspector: Jos ph M. Ulie
% S,19 d
DatV
QoQ.j) w
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
of the licensee's fire protection program through a followup of licensee
action on previous inspection findings; Licensee Event Reports (LER); and
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'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
assistance upon receipt of an alarm in the control room - Paragraph 2.e)gade
inadequacy in that the procedure did not prescribe the need for fire
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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
ADOCK 05000346
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DETAILS
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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
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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
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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.
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previously discussed and accepted by the NRC.
NRR considered
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
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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
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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-
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mance with the NFPA code standards.
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~The differences between the. installed fire detection zones and the
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-operability requirements required by Technical Specifications are
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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
indication that additional licensee attention was necessary. .The
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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
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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
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dispatching an operator to the alarmed area. If a licensee chooses to
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deviate from the governing fire protection requirements, the licensee
is required to submit a formal request to NRR.
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f.
(Closed) Open Item (346/87027-05): A concern was identified
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concerning wooden planking used in scaffolding which could create a
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patantial sprinkler head spray pattern obstruction.
In addition, the
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planking was considered a combustible hazard.
These concerns were
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strengthened due to the scaffolding being left in-place for extended
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periods with no apparent administrative controls. Eight of the
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14 areas had sprinkler systems installed in which certain sprinkler
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head spray patterns did appear to be obstructed,
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During this inspection, it was determined that the licensee has
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implemented Maintenance Procedure (MP) No. DB-MM-01637.00,
" Scaffolding Erection and Removal Guidelines," Revision 00, dated
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October 18, 1987. While performing plant tours of the plant on
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
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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
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considered closed.
h.
(Closed) Unresolved Item (346/89005-05(DRS)):
The licensec determined
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that certain hose stations (HCS) did not have the necessary length of
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
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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
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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
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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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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,
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Section V.G were met, consequently, no Notice of Violation will be
issued, and this maf
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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 <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, 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 <br />0.308 hours <br />0.00184 weeks <br />4.22355e-4 months <br />.
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 <br />0.419 hours <br />0.0025 weeks <br />5.74555e-4 months <br />.;, 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 <br />0.423 hours <br />0.00252 weeks <br />5.795015e-4 months <br />.
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 <br />0.643 hours <br />0.00383 weeks <br />8.808575e-4 months <br />, 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 <br />0.59 hours <br />0.00351 weeks <br />8.085625e-4 months <br /> 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
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action statement requirement.
These two examples of personnel error in not properly following
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the fire protection procedure resulted in an incorrect type of
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fire watch being established. During 1988 (Inspection Report
346/88028), four other instances occurred whereby continuous
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fire watches had not been established within one hour as required.
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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.
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Where discrepancies were noted by the inspector during plant tours of
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
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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
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as proprietary. The licensee acknowledged the findings of the inspection.
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On April 18, 1989, a conference call was held between the inspector and
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licensee representatives to discuss issues that remained open at the time
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of the March 17, 1989 exit interview.
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