ML20153F235

Insp Repts 50-321/88-21 & 50-366/88-21 on 880620-24. Violations Noted.Major Areas Inspected:Fire Protection/ Prevention & Followup on Previously Identified Insp Findings

ML20153F235
Person / Time
Site:	Hatch
Issue date:	07/22/1988
From:	Conlon T, Ward D, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20153F215	List: ML20153F212 ML20153F224 ML20153F235
References
50-321-88-21, 50-366-88-21, NUDOCS 8809070159
Download: ML20153F235 (13)

See also: IR 05000321/1988021

Text

UNITED STATES

[ arf 3 ,

flVCLEAR REGULATORY COMMISSION

["~ n REGION ll

g*

• , j 101 MARIETTA STREET,N.W.

' t ATLANTA. GEOROf A 30323

% ,/

.....

Peport Nos.: 50-321/88-21 and 50-366/88-21

Licensee: Georgia Power Company

P.-0. Box 4545

Atlanta, GA 30302

Docket Nos.: 50-321 and 50-366 License Nos.: OPR-57 and NPF-5

Facility Name: Hatch 1 and 2

Inspection Conducted: June 20-24, 1988

Inspectors: k- ,(htettw /3/8cf

G. R. Wiseman Date Sfgned

Ok Y/$88

F. C. Ward Date Signed

Approved by: (1/D/A rE&A //I2/Fv

T. E.Agn,lsfi,' Chief Odt'e Sig~ned

Plan ( Systems Section

Engineering Branch

Division of Reactor Safety

SUMMARY

Scope: This routine, unannounced inspection was in the areas of fire

protection / prevention and followup on previously identified

inspection findings.

Results: Within the areas inspected, the following violation was identified: 4

- Failure to Conduct and Document Required Surveillance of the

Remote Shutdown Panel Halon Suppression System.

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• J. Bennett, Superintendent, Plant Training

R. Bunt, Project Manager, Appendix R

• G. Creighton, Senior Regulatory Specialist

• D. Davis, General Support

• R. Davis, Audit Supervisor

• T. Elton, Administrative Support Supervisor

• P. Fornel, Manager, Maintenance

• G. Goode, Superintendent, General Engineering Support

• J. Lewis, Superintendent, Operations

• D. McAfee, Fire Protection, Engineering Supervisor

• H. Nix, Plant Manager

• T. Portrs, Engineering Manager

• D. Read Plant Support Manager

Other licensee employees contacted during this inspection included

craf tsmen, engineers, operators, mechanics, technicians, and administra-

tive personnel.

NRC Resident Inspector

• R. Musser

• Attended exit interview r

2. Fire Protection / Prevention Program (64704)

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a. Fire Prevention / Administrative Control Procedures

The inspectors reviewed the following Fire Prevention / Administrative l

Procedures.

procedure No. Title

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20AC-ADM-002-05 Rev. 3 Plant Records Management

40AC-ENG-008-05 Rev. O Fire Protection Program ,

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42 FP-FPX-005-OS Ret 0 Drill Planning, Critiques, and

Drill Documentation

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Based on this review, it appears that the above procedures meet the '

NRC guidelines of the document entitled "Nuclear Plant Fire

Protection Functional Responsibilities, Administrative Controls, and <

Quality Assurance" dated June 1977.

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The inspectors verified that procedure 40AC-ENG-008-0S included

specific criteria for the establishment of fire watches during repair

and maintenance activities whenever combustible materials are stored

or moved through the non-sprinklered area of the Intake Structure.

This was a special conditional commitment identified in the Hatch

Supplemental Safety Evaluation Report dated January 2, 1987, in

support of an exemption request approval by the NRC.

b. Fire Protection Surveillance Procedures

The inspectors reviewed the following Fire Protection System

Surveillance procedures:

Procedure No. Ti tle

42SV-FPX-006-OS (Rev. 0) Fire Damper Surveillance

42SV-FPX-009-25 (Rev. 1) Inspection and Testing of the

Halon 1301 Fire Extinguishing

System, Remote Shutdown Panel

42SV-FPX-013-0S (Rev. 1) Automatic Fire Door Surveillance

42SV-FPX-023-05 (Rev. 1) Fire Hose, Hydrostatic Test

Based on this review, it appears that various test outlines and

inspection instructions adequately implement the surveillance

requirements of Appendix B of the plant's Fire Hazards Analysis. In

addition, it appears that the inspection and test instructions in

the procedures follow general industry fire protection practices, NRC

fire protection program guidelines and the guidelines of the National

Fire Protection Association (NFPA) Fire Codes.

c. Fire Protection System Surveillance Inspections and Tests

The inspectors reviewed the following surveillance inspection and

test records for the dates indicated:

Procedure No. Dates

42-FPX-009-25 03/28/87 - 02/10/88

42-SV-L43-001-IS (Fire Doors) 07/19/85, 08/16/85, 08/26/85,

09/14/85, 09/23/85, 12/16/85,

02/26/86

The surveillance test record data associated with the above fire

protection system surveillance test / inspections were found to be

satisfactory with regard to meeting the requirements of Appendix B of

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the plant's Fire Hazards Analysis. In addition, the inspectors

reviewed the surveillance results associated with procedure

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F2SV-FPX-009-25 to ensure the 62 day surveillance of the Unit 2 l

remote shutdown panel halon suppression system was conducted within  !

the required interval. This onsite review identified that the

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required documentation was not available in Document Control, to t

indicate the performance of the required surveillance between

03/28/77 and 07/17/87 tests and between 08/19/87 and 11/20/87 tests.

This interval exceeds the maximum interval of 62 days plus 25% of the  !

interval or 77.5 days.  !

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During a subsequent telephone conversation on June 28, 1988, the  !

licensee stated that the documentation package for the surveillance  !

performed on May 13, 1987, had not been transmitted to Document i

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Control but was found in the possession of the Engineering Fire

The licensee also stated that their review

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Protection Group.

indicated no evidence that the required surveillance was performed f

between 08/19/87 and 11/20/87. Failure to perform this surveillance

1 and failure to transmit the May 13, 1987 surveillance package to f

Document Control is identified as Violation Item 50-366/88-21-01,

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Failure to Conduct and Document Required Surveillance of the Remote

! Shutdown Panel Halon System,

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d. Fire Brigade

(1) The total station fire brigade is composed of approximately 73

members from the operations staff. The on duty shift fire

brigade leader is normally one of the shift supervisors and the

remaining four fire brigade members are composed of plant

a equipment operators. The inspectors reviewed the on duty shif ts

for the following dates and verified that sufficient qualified

fire brigade personnel were on duty to meet the provisions of

l the plant's Technical Specifications:

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l 06/18/88

i 06/19/88

06/20/88

06/21/88

06/22/88

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In addition, the inspectors verified that sufficient personnel

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were assigned to each shift to meet the minimum operating and

i fire brigede staff requirements of the Technical Specifications,

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! The licensee has recently initiated an informal shift roster

i which is used to designate the-personnel assigned to the fire

brigade and to the minimum shutdown crew. In reviewing these

4 rosters for the day shif ts on 06/18/88, 06/19/88, and 06/20/88,

j the inspectors found that two individuals who were not fire

i brigade qualified had signed in on the roster as fire brigade

members. These two individuals are Auxiliary Plant

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Operators (AP0s). AP0s are not presently trained for fire

brigade duty. Further review of the rosters for the dates

above, identified that additional fire brigade qualified

personnel had also signed in on the roster and that a five man

brigade was available exclusive of the unqualified AP0s. In

addition, the inspectors found that there is no method of

verifying that only trained individuals sign in as fire brigade '

members. At the beginning of each shift, the fire brigade and

minimum shutdown crew members sign in on the roster maintained

by the shift supervisor; however, the shif t supervisor does not

have a list of qualified brigade members to compare with the

roster to ensure only qualified personnel are assigned to the

brigade.

For the dates reviewed by the inspectors, the assignment of

unqualified personnel to the brigade is not considered a

violation of plant Technical Specifications since additional

qualified personnel were assigned brigade duty to meet the five

man minimum. However, the lack of a method of positive

verification that only qualified personnel are assigned brigade

duty is considered a weakness in the implementation of the Fire

Protection Program. This weakness had been previously

identified as part of Unresolved Item 50-321,366/88-15-02 in

Inspection Report No. 88-15. Based on the inspectors' review of

this unresolved item, it was determined that the licensee was

taking adequate corrective action to eliminate all weaknesses

identified in the item except in the area of controlling fire

brigade assignments. Since none of the weaknesses identified in

the Unresolved item constitute a violation of the licensee's

Technical Specifications or Fire Protection License Condition,

the Unresolved Item 88-15-02 will be closed in this report and a

new Inspector Followup Item, 50-321,366/88-21-02, Failure to

Provide Control of Assignment of Fire Brigade Members, is

identified here to track the weakness in assigning personnel to

the fire brigade.

Based on the review of the duty rosters associated with the

above dates, there was sufficient manpower on duty to meet both

the operational and the fire brigade requirements of the plant's

Technical Specifications.

(2) Training

The inspectors attended a one hour session of the initial 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />

fire brigade training dealing with the use of firefighting foams

on flammable / combustible liquids fires and a two hour session

for fire brigade leaders in which fire ground command and

management were discussed.

The session on the uses of fire fighting foams included a video

tape and a classroom discussion of plant specific foam use. The

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session was well organized and provided adequate information on

the use of fire fighting foams at Plant Hatch.

The training session for fire brigade leaders is the licensee's i

initial implementation of a new fire brigade leadership training

program. The program was developed in response to an internal

QA audit finding which identified a weakness in the area of fire <

brigade training program. The training program is set up to be

conducted quarterly and will include the following erial -

covered over a two year period:

• Critical Factor Analysis .

Fire Fighting Systems Model  :

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Time Constraints

• Fire IP,cident Comand

Tactics for Fire Control

• General Tactical Principles

Special Hazards Tactics  ;

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The training in the two hour session, in which fire ground

command and management were discussed, provided a good

background in the subject areas; however, the training lacked

plant specific information necessary for an effective leadership

training program for Plant Hatch. The fire brigade leader

perfomance during the fire drill witnessed during this

inspection and during a previous inspection indicated that

adequate training was not being conducted for brigade leaders.

Therefore, an Inspector Followup Item, 50-321,366/88-21-03,

Followup on the Implementation of Fire Brigade Leadership .

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Training, is identified to ensure the implementation of this

training is reviewed in future inspections.

(3) Fire Brigade Firefighting Strategies ,

The inspectors reviewed the following plant firefighting ,

strategies:

Pre-Plan No. Description

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SR-2407 Diesel Generator Room 2C

SR-2404 Diesel Generator Switchgear Room 2E

SR-2402 Diesel Generator Battery Room 2A

SR-2401 Diesel Generator Oil Storage Room 2A

SR-2203F Unit 2 Reactor Building North CRD Area

SR-2205F Unit 2 Reactor Building South CRD Area F

SR-0501-IS River Intake Structure ,

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Based on this review, the inspectors detemined that the above ,

firefighting strategies adequately addressed the fire hazards in  !

the area, the type of fire extinguishants to be utilized, the  ;

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direction of attack, systems in the room / area to be managed in

order to reduce fire damage, heat sensitive equipment in the

room / area, and specific fire brigade duties with regard to smoke

control and salvage.

(4) Fire Brigade Drill

During this inspection, the inspectors witnessed an unannounced

fire brigade drill. The drill fire scenario was a fire in a

temporary tent setup on the 130' elevation of the Unit 2 Reactor

Building.

Ten fire brigade members responded to the pending fire emergency

in full protective clothing and self contained breathing

apparatus. The fire brigade advanced two 1-1/2 inch fire attack

hose lines into the area. The hose lines were placed in service

on the fire and the tent fire was placed under control in

approximately 40 minutes.

Fire brigade performance was identified as steadily deteriora-

ting in Inspection Report No. 87-30, Inspector Followup Item

50-321,366/87-30-04. This trend appeared to have improved only

minimally in the drill witnessed. The following weaknesses

identified in Inspection Report No. 87-30 still exist:

The brigade leader failed to establish a command post with

adequate comunication.

• The brigade leader did not perform a proper sizeup of the

fire situation prior to initiating firefighting activities.

Health Physics personnel did not promptly respond to assist

the fire brigade.

l The primary problem identified was the lack of leadeaship

provided by the fire brigade leader in the drill. The licensee

has recently initiated a leadership training program for all

fire brigade leaders. The inspectors feel the successful

implementation of such a training program will eliminate the

deficiencies identified during the two drills previously

witnessed. The Inspector Followup Item 50-321,366/87-30-04

will remain open pending the NRC witnessing a satisfactory fire

brigade drill.

e. Review of Appendix R Nonconformances

Through discussions with plant personnel, the inspectors found that

the licensee had recently identified a number of nonconformances from

the requirements of 10 CFR 50 Appendix R for the protection of

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circuits required for plant shutdown. These nonconformances were

identified through the licensee's review of a number of backlogged

Unit 1 As-Built Notices (ABNs) associated with the Analog

Transmitter Trip System (ATTS) design change which was completed in

the Spring of 1986. The nonconformances are identified in a letter

dated June 10,1988 (Log No. REA-8-6-809) from William F. Garner of

Southern Company Services to D. R. Madison of Georgia Power Company.

Included in this letter are recommended actions for eliminating the

nonconformances which include the revision of plant Emergency

Operating Procedures (EOPs) to include additional operator actions or

the installation of fire rated barriers to protect electrical cable.

The inspectors reviewed each of the nonconformances with the site

Fire Protection Engineering Supervisor and the Appendix R Project

Manager from Southern Company Services. This review established that

the licensee had evaluated each of the nonconformances for its effect

on the ability to reach and maintain Unit 1 plant shutdown. The

licensee's representatives stated that in all cases the consequences

of a fire damaging the unprotected circuits could have L'een mitigated

by:

• Corrective actions which would have been implemented through the

plant symptom based E0Ps; or

Availability of redundant systems. For example, a loss of High

Pressure Core Injection (HPCI) could have been supplemented by

the use of safety relief valves, which are protected, to

depressurize to the point where Low Pressure Core Injection

(LPCI)couldinitiate.

Therefore, the existence of these nonconfermances would not have

prevented Unit 1 from achieving plant shutdown.

The licensee is required by Appendix B of their Fire Hazards Analysis

to submit a special report within 30 days to document the failure to

provide protection for these circuits. This special report will

include the licensee's evaluation of why failing to protect these

circuits would not have prevented them for achieving safe plant

shutdown. Upon discovery of the nonconformances the licensee

implemented roving fire watches in the affected fire areas which will

remain in effect until corrective actions have been implemented,

f. Plant Tour and Inspection of Fire Protection Equipment

(1) Permanent Plant Fire Protection Features

The inspectors conducted a tour of the Diesel Generator Building

and Cable Spreading Room. The fire / smoke detection systems,

manual fire fighting equipment (i.e., portable extinguishers,

hose stations, etc.) and the fire area boundary walls, floors

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and ceiling were inspected and found to be in service or

functional.

The CO2 system installed in each of the Diesel Generator Rooms

and the Pre-Action sprinkler system protection in the Cable i

Spreading Room were inspected and found to be in service.

The tours of these areas also verified the licensee's

implementation of the fire prevention administrative procedures. .

The control of combustibles and flammable materials, liquids and !

gases, and the general housekeeping were found to be

sa tisfactory, i

(2) Appendix R Fire protection Features i

The inspectors visually inspected the fire rated raceway barrier !

on conduit 2E21601 in Fire Area 0014. This fire barrier was  !

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found intact and it appeared that the one hour fire barrier .

integrity has been maintained. In addition, the inspectors  !

visually inspected the three-hour rated raceway fire barriers

applied to the conduit / raceway bank located in Fire Area 1412

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(Diesel Generator Switchgear Room 1E) which contained the i

following safe shutdown circuits: l

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ESA-4 ESA-26

ESA-6 ESA-28

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ESA-8 ESA-84

ESA-10 ESA-86 i

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ESA-12 ESA-90

ESA-14 ESA-91 j

This fire barrier was found intact and it appeared that the '

three hour barrier integrity was maintained.

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The following eight-hour emergency lighting units were

inspected: j

i 1R42-E041 1A Diesel Generator Room .

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1R42-E066 1A Diesel Generator Room

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1R42-E068 1A Diesel Generator Room .

1R42-E109 1A Diesel Generator Room

j 2R42-E038 2A Diesel Generator Room

l 2R42-E045 2A Diesel Generator Room

These units were in service, lamps properly aligned and appeared

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to be properly maintained.

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g. Response to NRC Information Notice 88-04

On Feburary 5, 1988, the NRC issued Information Notice 88-04,

Inadequate Qualification and Documentation of Fire Barrier

Penetration Seals. The purpose of the notice was to make licensees

aware that some installed fire barrier penetration seal designs may

not be adequately qualified for the design rating of the penetrated

fire barriers. The licensee's proposed response to the Notice was

l reviewed during this inspection.

The licensee has completed a preliminary evaluation of the concerns

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outlined in the Information Notice and has proposed the following

action to evaluate these concerns as they apply to Plant Hatch.

l - Evaluate Plant Hatch's test qualification documentation with

t respect to adequacy and completeness. This evaluation will also

consider the method of installation or repair used for the fire

barrier penetration seals.

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- Cross reference the test qualification documentation to each

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specific fire barrier penetration seal (or repairs to that

specificseal).

- Offer resolutions to any problems encountered.

The licensee has a preliminary completion date of March 1989 for the

cross referencing process. If the licensee implements the proposed

plan of action described above, the concerns outlined in Infonnation

Notice 88-04 should be adequately evaluated.

In addition, the inspectors attempted to verify that the following

four penetration seals located in the cable spreading room could be

tracked to specific test data which demonstrated the seal was a

qualified three hoitr fire barrier:

H033F

H034F

H068F

H072F

However, the lack of a cross reference between the seal and test data

made the task very cumbersome and the inspectors were unable to

verify the seals were installed in a tested configuration. The

inspectors noted during this review that at least one of the seals,

H033F, had been modified from the original design detail.

The licensee's implementation of their action plan in response to the

Information Notice will be followed up in a future inspection.

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3. Action on Previous Inspection Findings

a. (Closed) IFI 321,366/86-27-02, Proposed Firefighting Strategies /

Preplans Lack Fire Brigade Guidance. The inspectors reviewed the plant

Preplans (Revision 1)datedApril 23, 1987, for the Diesel Generator

Building and Reactor Buildings. This review determined that

Revision 1 preplans adequately gives the locations of portable

extinguishers for brigade use, addresses management of plant systems

with references to appropriate E0Ps and Abnormal Operating Procedures

(ACPs) located in the control room, gives locations of telephones and

communications systems, and provides guidelines for fire attack

access and command post locations. These revised preplans appear

adequate to meet NRC guidelines; therefore, this item is closed,

b. (Closed) Violation 321,366/87-30-02, Failure to Implement Fire

Protection Program Procedures for Documentation of Fire Protection

Activities. This violation involved two examples of the licensee's

failure to document fire protection activities in accordance with

plant procedures.

- Example 1 resulted from the failure of the licensee's staff

assigned to critique plant fire drills to complete the required

records to document the drill as satisfactory or unsatisfactory.

The licensee's corrective action included the revision of the

plant procedure, 42FP-FPX-005-OS (Rev. 0), for performing plant

fire drills to include the requirement that drill evaluation be

completed and transmitted to Document Control within 30 days.

The inspectors verified that all drill critiques sent to

Document Control for the fourth quarter of 1987 were complete.

- Example 2 resulted from the licensee's failure to implement the

requirements of Administrative Control Procedure 20AC-ADM-002-05

to perform a quarterly records check.

The licensee's corrective action in response to this example was

to revise the administrative procedure to eliminate the

requirement for a quarterly records check since this requirement

was impractical . The licensee is relying on the responsible

organization to insure the required records are transmitted to

Document Control. The inspectors verified that Revision 3 of

20AC-ADM-002-OS no longer requires Document Control to perfom a

quarterly records check.

c. (Closed) Violation 321,366/87-30-03, Failure to Repeat Unsatisfactory

Fire Brigade Drills Within Required Time Period. Orill critiques for

two drills in 1986 and two in 1987 indicated that drill performance

however, a redrill was not conducted within 30

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days unsatisfactory;

in accordance with plant procedures.

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The licensee's corrective action in response to this violation was to

conduct six drills in November and December. Five of these drills

were conducted to meet the requirement for each shift to participate

in an unannounced drill at least once per year. One of the drills

was a redrill of an unsatisfactory drill. All drills were considered

satisfactory by personnel assigned to critique the brigade

performance. The inspectors verified that all six drill critiques

had been transmitted to Document Control and the redrill had beer

conducted within the 30 day time limit.

d. (0 pen) IFI 321,366/87-30-04, Additional Fire Brigade Training and

Drills Required. During the 87-30 inspection, a fire brigade drill

was witnessed which was unsatisfactory. During this inspection,

another brigade drill was witnessed which showed only minimal

improvement in brigade performance. The major deficiency noted

during this inspection resulted from the lack of leadership by the

fire brigade leaders. The licensee has recently initiated a training

program for brigade leaders which should eliminate these

deficiencies.

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This item will remain open pending the NRC witnessing a fire brigade

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drill which eliminates the concerns outlined in report 87-30 and this

report.

e. (Closed) IFI 321,366/87-30-05, Justification for CO2 Extinguisher

Mountings in the Control Room. The CO2 extinguishers provided in the

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control room were mounted on shelves and not secured to prevent

falling. The inspectors were concerned that if the CO2 extingui;'ur

was knocked or fell from the shelf it may become a missile in the

control room since they are high pressure cylinders.

The licensee corrected this 3roblem by removing the CO2 fire

extinguishers from the controi room and replacing them w'th halon

type. The halon fire extinguishers were permanently mounted with

fire extinguisher brackets designed for mounting extinguishers on

vehicles. These brackets will ensure the extinguishers cannot be

knocked or fall from the shelves.

I f. (Closed) Unresolved Item 321,366/88-15-02, Apparent Failure to

Complete Required Periodic Fire Brigade Leadership Training. During

the Hatch Operational Team Assessment, this item wLs identified to

denote weaknesses in the licensee's methods used to control the

, coster of qualified fire brigade leaders and members and imprecise

' administrative instructions controlling fire brigade training.

During this inspection, it was determined that ths licensee wa: taking

adequate corrective action to eliminate all weaknesses identified in

the item except in the area of controlling fire brigade assignments.

Since none of the weaknesses identified in the unresolved item

constitute a violation of the licensee's Technical Specifications or

Fire Protection License Condition, this Unresolved Item is closed. A

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new inspector followJp item is identified in paragraph 2.d of this ,

report.

4. Exit Interview

The inspection scope and results were summarized on An a 24, 1988, with

those persons indicated in paragraph 1. The inspectors described the

areas inspected and discussed in detail the inspection results listed

below. Proprietary infonnation is not contained in this report.

Dissenting coments were not received from the licensee.

Item Number Description and Reference

366/88-21-01 Violation - Failure to Conduct and Document

Required Surveillance of the Remote Shutdown

Panel Halon Suppression System

221,366/88-21-02 Inspector Followup Item (IFI) - Failure to

Provide Control of Assignment of Fire Brigade

Members

321,366/88-21-03 Inspector Followup Item (IFI) - Followup on

the Implementation of Fire Brigade Leadership

Training

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