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{{Adams | |||
| number = ML20207J763 | |||
| issue date = 12/23/1986 | |||
| title = Insp Rept 50-293/86-36 on 861020-24.Two Violations Noted & Three Items Remain Unresolved Re Fire Protection Program | |||
| author name = Anderson C, Krasopoulos A | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000293 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-293-86-36, NUDOCS 8701080581 | |||
| package number = ML20207J740 | |||
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 13 | |||
}} | |||
See also: [[see also::IR 05000293/1986036]] | |||
=Text= | |||
{{#Wiki_filter:. | |||
U.S. NUCLEAR REGULATORY COMMISSION | |||
REGION I | |||
Report No. 86-36 | |||
Docket No. 50-293 | |||
License No. DPR-35 Priority - Category C | |||
Licensee: Boston Edison Company M/C Nuclear | |||
800 Boylston Street | |||
Boston, Massachusetts 02199 | |||
Facility Name: Pilgrim Atomic Power Station | |||
Inspection At: Plymouth, Massachusetts | |||
Inspection Conducted: October 20-24, 1986 | |||
Inspector: ..th]l['c[ auAvdv | |||
A. Krisopo0 Tot', ~ Reactor Erigineer, DRS | |||
/ /1 B 6 | |||
' I dat'e | |||
Approved by: %f_ . 1,. o / _ / _ | |||
/ J43/76, | |||
p. J(' Anderson, Cliief, Plant Systps Section ' dat( | |||
Inspection Summary: Inspection on October 20-24, 1986 (Report 50-293/86-36) | |||
Areas Inspected: Routine unannounced inspection of the fire protection / preven- | |||
tion program including a review of: the combustible material control / hazard | |||
reduction program; programmatic administrative controls; installation, oper- | |||
ability and maintenance of fire protection systems; fire protection LERs; fire | |||
fighting capabilities; fire protection equipment maintenance inspection and | |||
tests; periodic inspections and quality assurance (QA) audits of the fire | |||
protection program and a facility tour. | |||
Results: Of the eight areas inspected two violations were identified and three | |||
items remain unresolved. | |||
10gh $$ 3 | |||
0 | |||
. | |||
. | |||
DETAILS | |||
1. Persons Contacted | |||
1.1 Boston Edison Company (BECO) | |||
*A. E. Pedersen, Plant Manager | |||
*W. Sullivan, Fire Protection Engineer | |||
*J. McEachern, Resources Protection | |||
*J. Quinn, Plant Engineer | |||
*R. Velez, Project Manager | |||
*E. Ziemianski, Nuclear Management Services Section Manager | |||
B. Lunn, Compliance Engineer | |||
R. Laroue, Training Specialist | |||
1.2 Nuclear Regulatory Commission (NRC) | |||
*M. McBride, Senior Resident Inspector | |||
* Denotes those present at the exit interview. | |||
2. Inspection Purpose and Methodology | |||
The purpose of this inspection was to evaluate the licensee's fire protec- | |||
tion and prevention program (FPPP) and verify that the licensee has | |||
developed and implemented adequate procedures, consistent with the appli- | |||
cable Technical Specifications (TS), license conditions, regulatory | |||
requirements and commitments made in the Final Safety Analysis Report and | |||
the Fire Protection System Evaluation Report (FPSER). The evaluation of | |||
the program consisted of a documentation and procedure review, interviews | |||
with licensee personnel and field observations. | |||
The documents reviewed, the scope of review and the inspection findings | |||
for each area reviewed are described in the following sections. | |||
3. Fire Protection Program Review | |||
3.1 Review of Combustible Material Control - Hazard Reduction | |||
The inspector toured the plant to inspect housekeeping conditions, | |||
work in process and activities or conditions that may present a | |||
hazard to the facility. | |||
The scope of review was to verify that the licensee: | |||
a. Keeps safety related and adjacent plant areas free from transi- | |||
ent combustibles; | |||
. | |||
. | |||
. | |||
3 | |||
b. Keeps. flammable and combustible liquids under administrative | |||
control and the storage of such liquids is in accordance with | |||
the guidelines of the National Fire Protection Association | |||
(NFPA) Standards; | |||
c. Performs periodic inspection for accumulation of combustibles; | |||
d. Uses wood treated with flame retardant for work inside plant | |||
areas; | |||
e. Does not allow the accumulation of waste, debris, rags, oil | |||
spills, and other combustible materials resulting from a work | |||
activity to extend beyond the end of each work shift or the end | |||
of the activity, whichever is sooner; , | |||
f. Properly maintains the housekeeping in all areas containing | |||
safety related equipment and components; , | |||
g. Prohibits smoking in safety related areas except where " smoking | |||
permitted" areas have been specifically designed by plant | |||
management; and | |||
h. Requires special authorization (work permit) for activities | |||
involving welding, cutting, grinding, open flame or other igni- | |||
tion sources, and that these activities are properly safe- | |||
guarded. | |||
During the inspection the inspector did not identify any conditions | |||
that present a safety hazard, however, in the Turbine Building, | |||
elevation 51' 0", the inspector observed that the flammable storage | |||
cabinets located therein, were neither grounded nor vented as per | |||
cabinet manufacturers and NFPA recommendations. The licensee cor- | |||
rected this condition prior to the inspector leaving the site. | |||
I | |||
3.2 Review of Administrative Controls | |||
The inspector reviewed the following licensee documents: | |||
- | |||
Technical Specifications, Section 6, Administrative Controls; ; | |||
l | |||
- | |||
License Condition 3.F. Fire protection requiring the licensee l | |||
to implement the administrative controls identified in the Fire ' | |||
Protection Safety Evaluation and the requirements listed in the | |||
" Nuclear Plant Fire Protection Functional Responsibilities, | |||
Administrative Controls and Quality Assurance"; | |||
- | |||
BECO Fire Protection System Evaluation; and | |||
- | |||
Pilgrim Training Manual. | |||
_. -- - | |||
. | |||
. | |||
4 | |||
The scope of review was to verify that the licensee had developed | |||
administrative controls which require that: | |||
a. Work authorization, construction permit or similar arrangement | |||
is provided for review and approval of modification, construc- | |||
tion and maintenance activities which could adversely affect the | |||
safety of the facility; | |||
b. Fire brigade organization and qualifications of brigade members | |||
are delineated; | |||
c. Fire reporting instructions for general plant personnel are | |||
developed; | |||
d. Periodic audits are to be conducted on the entire fire protec- | |||
tion program; and | |||
e. Fire protection / prevention program is included in the licensee's | |||
QA Program. | |||
No unacceptable conditions were identified. | |||
3.3 Review of Installation, Operability and Maintenance of Fire | |||
Protection Systems | |||
The inspector reviewed the installation of randomly selected fire | |||
protection systems, fire protection system flow diagrams, made obser- | |||
vations on the condition and operability of the fire protection | |||
equipment and reviewed the Fire Protection Equipment Main- | |||
tenance Request List to determine whether: | |||
a. Fire protection equipment such as stand pipes and hose stations | |||
are operable and accessible in all areas important to safety; | |||
b. Adequate portable extinguishers are provided at designated | |||
places in each fire area; | |||
c. The condition of all fire suppression devices inspected is | |||
satisfactory; | |||
d. The system's valves are lined up in the proper position and are | |||
protected from tampering; and | |||
e. The fire protection equipment is well maintained. | |||
f. The fire barriers and related components such as fire doors, | |||
fire dampers, and penetration seals have been installed and | |||
maintained properly to insure against fire propagation. | |||
_ | |||
. _ _ _ _ _ _ _ _ _ _ _ _ _ | |||
, | |||
! . | |||
. | |||
5 | |||
As a result of this review the following observations were made by | |||
the inspector: | |||
a. The licensee is not agressively pursuing maintenance and repair | |||
work to the fire protection systems as evidenced by the large | |||
amount of incomplete repair work on fire protection system | |||
components. | |||
This observation is based on the following: | |||
(1) Almost 300 work requests were outstanding for repair | |||
work on fire protection system components | |||
(2) Eight (8) maintenance requests are for work that affects | |||
the fire pump system, and if left undone may affect pump | |||
operability and | |||
(3) Twelve (12) maintenance requests were originated in 1983, | |||
about thirty requests were originated in 1984, and the | |||
remainder of the (300) requests originated in 1985 and | |||
1986. | |||
b. The licensee has relied heavily on fire watches as a substitute | |||
for degraded fire protection system components. During the | |||
inspection period, the licensee had an average of fifty-five | |||
(55) fire watch postings covering about thirty-five (35) | |||
different areas. Thirty (30) of these watches had been in place | |||
for more than three (3) months, eight (8) had been in place for | |||
more than a year and the remainder were established within the | |||
last 3 months. | |||
The above items are collectively categorized as an unresolved item pending | |||
a review of the licensee's actions to implement repairs on the fire pro- | |||
tection system components and minimize the use of fire watches as a | |||
substitute for correcting deficiencies in the fire system. (50-293/86-36-01). | |||
The inspector also noted that the access way to Hose Station No. TA 86-51 | |||
was blocked by an instrument cart. This could impede use of the hose | |||
station in an emergency. The licensee took immediate action to relocate | |||
the cart. This appeared to be an isolated incident. | |||
' | |||
3.4 Review of Licensee Event Reports (LER) | |||
The inspector reviewed eight recent fire protection LERs. The LERs | |||
reviewed were Nos. 86-23, 86-20, 84-07, 83-41, 83-38, 83-30, 83-25 | |||
and 83-27. | |||
The inspector concluded that seven of the eight LER's were related | |||
to fire barrier degradation. Five of the LERs were issued because of | |||
inoperable fire barriers. These barriers were declared inoperable | |||
because of either missed barrier surveillances or because of degraded | |||
barrier components such as penetration seals and fire doors. Two | |||
LERs were issued because fire watches established as compensatory | |||
measures had not perform as required, due to inadequate instructions. | |||
i | |||
___ | |||
._ | |||
. | |||
. | |||
6 | |||
The inspector reviewed the weekly fire watch logs and the Maintenance | |||
Request List (MRL) to determine the nature and extent of the fire | |||
barrier deficiencies. From these documents and from interviews with | |||
licensee personnel, the inspector learned that the following barriers | |||
were declared inoperable because of suspected barrier degradation: | |||
Vital Motor Generator Set Room Floor | |||
Battery Room B West Wall | |||
Battery Room B North and East Wall | |||
Computer Room West Wall | |||
A Switch Gear Room West Wall | |||
A Switch Gear Room North Wall | |||
Battery Room A East Wall | |||
Battery Room A West Wall | |||
Vital Motor Generator Set Room North Wall | |||
; Vital Motor Generator Set Room West Wall | |||
A Switchgear Room South Wall | |||
' | |||
A Switchgear Room Floor | |||
Diesel Generator Room A East Wall | |||
# | |||
Diesel Generator A/B Area South Wall | |||
Diesel Generator Room East Wall | |||
Turbine Tool Storage Room East Wall | |||
Filter Room South Wall | |||
HVAC #2 Room South Wall | |||
Turbine Deck | |||
Reactor Buildings Floor 91' | |||
Reactor Buildings Floor 51' | |||
Reactor Building 51' South Wall | |||
Fan Room #3 Reactor Building 74' Floor | |||
Reactor Building 74' Floor | |||
Recirculation Motor Generator Set East Floor 51' | |||
Reactor Building 23' Floor | |||
Recirculation Motor Generator Set East Wall 51' | |||
Water Treatment Area North Wall | |||
Auxiliary Boiler Room West Wall | |||
Auxiliary Boiler Room North Wall | |||
Turbine Lube Oil Area North Wall | |||
1 Condensate Pump Area South Wall | |||
Turbine Lube Oil Ceiling | |||
l Intake Structure North Wall of the Service Water Pump Rooms | |||
The licensee established fire watches for the above barriers pending | |||
verification of the barrier status, ie, operable-inoperable or the | |||
barrier operability is not required. | |||
The inspector determtried that the reasons for declaring the barriers | |||
inoperable were the following: | |||
' | |||
, | |||
a. Penetrations seal documentation either does not exist or is | |||
unclear; | |||
i | |||
_ . . _ . _ _ _ - . _ - - - _ - - - - _ _ _ - - _ _ _ . _ - _ _ _ _ _ _ _ _ _ - - - - - - - - _ - _ - - _ _ . - _ - _ _ . _ _ | |||
_ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ | |||
. | |||
. | |||
' 7 | |||
b. Barrier components appear degraded; | |||
c. Uncertainty exists as to whether the fire barrier is required. | |||
With regard to Item a, the licensee stated that during a check of the | |||
documentation necessary to verify the fire rating of the seals, ques- | |||
tions were raised as to the adequacy of QC during seal installation. | |||
In addition, seal test data and other parameters necessary to estab- | |||
lish seal adequacy were not available. In some cases, the licensee | |||
stated that the documantation either can not be found or does not | |||
exist. With regard to Item b, field inspections by the licensee | |||
identified penetrations with some impairments. The licensee had not | |||
completed their evaluation of these deficiencies. With regard to | |||
i Item c, a number of penetrations were identified as degraded. How- | |||
ever, uncertainty exists as to whether these barriers are required. | |||
' | |||
The licensee is in the process of evaluating all of the suspected | |||
! | |||
non-conformances in a systematic way. An analysis is being performed | |||
4 to identify which of the barriers are required by the Technical | |||
i Specification, Appendix R or by licensing commitments. The licensee | |||
is evaluating the adequacy of all seals either by analysis or sim- | |||
ilarity tests. Any non-conformances identified during this process i | |||
will be reported in accordance with the applicable reporting require- | |||
' | |||
' | |||
; ments. | |||
The above was collectively categorized as an Unresolved Item pending | |||
review of the licensee's actions to evaluate the barriers, report | |||
non-conformances and implement required repairs. (50-293/86-36-02). | |||
3.5 Review of Fire Fighting Capabilities | |||
t | |||
The inspector reviewed the licensee documents listed below, conducted | |||
interviews with personnel and inspected fire fighting gear to evaluate the | |||
on-site capability of the licensee to fight fires: a | |||
! | |||
The documents reviewed were: | |||
i | |||
; | |||
- | |||
License Amendment No. 35 section 3.F; | |||
; - | |||
Fire Protection Safety Evaluation Report | |||
i | |||
- | |||
Pilgrim Training Manual; | |||
: - | |||
Fire Brigade Training Drill Procedure No. 1.4.23, Revision 7; , | |||
- - | |||
Fire Watch Procedure No. 8.B.14, Revision 7; | |||
i - | |||
Special Fire Procedure No. 5.5.2; and | |||
i | |||
- | |||
Qualified Fire Fighter Rosters. | |||
i | |||
The scope of the review was to: | |||
I | |||
l a. verify that all personnel designated to take part in fire emer- | |||
i gencies are trained in these actions and in the overall emergency | |||
plan, | |||
: | |||
i | |||
- - . . - , . ~ --,,e ,..-,~.,-,._.._.---,..,,-,n.-,--- . | |||
- . _ , , . , , - , . ~ . , , _ , _ , __..,..__---,--.v---- | |||
- | |||
. | |||
. | |||
8 | |||
b. verify that the licensee has established a training program that | |||
ensures the capability to fight potential fires; | |||
c. verify that the licensee's training p ogram consists of initial | |||
classroom instruction followed by periodic classroom instruction, | |||
firefighting practice and fire drills, | |||
d. verify that the licensee had developed fire fighting strategies for | |||
fires in all safety related areas and in areas in which a fire could | |||
present a hazard to safety related equipment and | |||
e. verify that the fire fighters can fight plant fires with the equip- | |||
ment available. | |||
With regard to the above, the inspector made the following observations | |||
concerning the overall adequacy of the fire brigade training, the adequacy | |||
of the fire watches, the adequacy of and use of the fire fighters | |||
protective gear and the ability to fight plant fires jointly with the | |||
local fire department: | |||
Fire Brigade Training | |||
The Pilgrim Station Operating License, Number DPR-35, in Section 3.F. | |||
titled " Fire Protection", requires the licensee to implement the | |||
administrative controls specified in Section 6 of the NRC Fire | |||
Protection Safety Evaluation (SE) dated December 21, 1978. | |||
Section 6 of the SE states that the licensee will provide the fire brigade | |||
training in accordance with the guidelines contained in the " Nuclear Fire | |||
Protection Functional Responsibilities, Administrative Controls and Qual- | |||
ity Assurance" document. This document specifies that the Fire Brigade | |||
Members Qualification and Training Program includes the following: | |||
- | |||
Initial classroom instructions; | |||
- | |||
All brigade members shall have hands-on fire fighting practice | |||
at least once per year; | |||
- | |||
Classroom instruction is provided to all fire brigade members | |||
every 3 months so that the initial classroom program is | |||
repeated over a two year period; | |||
- | |||
Fire brigade drills are performed so the brigade can practice as | |||
a team; | |||
- | |||
Membership to the brigade should include satisfactory completion | |||
of a physical examination for performing strenuous activity; and | |||
\ | |||
. | |||
. | |||
9 | |||
- | |||
The training shall be as specified in the National Fire | |||
Protection Association (NFPA) Standard 27. | |||
The inspector reviewed the training records for the brigade members | |||
and interviewed all of the shift fire brigade members to eval- | |||
uate the licensees conformance with the above requirements. The | |||
review identified the following: | |||
The licensee allowed in calendar year 1986 at least nine (9) fire- | |||
fighters who missed two (2) consecutive quarterly training sessions | |||
and twenty-one (21) fire fighters who missed one (1) quarterly training | |||
session to be active members of the brigade. | |||
The above is a violation of the license requirement to provide | |||
quarterly classroom instruction to all active members of the Fire | |||
Brigade. (50-293/86-36-03) | |||
The inspector also noted that about thirty (30) fire fighters had not i | |||
participated in any fire drills. However, NRC Report No. 86-21 pre- | |||
viously identified this deficiency as a deviation from the training | |||
requirements. | |||
The licensee indicated that an accelerated Fire Brigade Training | |||
Program is being implemented so that the qualifications of all | |||
brigade members are maintained. | |||
The inspector reviewed the licensee's followup to LER 86-23. In the | |||
LER the licensee identified a deficiency with fire watches not | |||
properly documenting their surveillance of certain fire areas. No | |||
deficiencies were observed, during this inspection, with regard to | |||
the proper documentation of surveillances performed. However, the | |||
inspector observed that the fire watch assigned to patrol the | |||
degraded fire barriers in the MG Set room on October 21, 1986 did not | |||
inspect the room. The fire watch entered the room, signed the fire | |||
watch log and laft. Similarly, the inspector observed that the fire | |||
watches assigned to patrol the degraded fire barriers the vital MG | |||
Set room never entered the room, instead they signed the log locnted | |||
outside the room and left. This was ascertained by an examination of | |||
the security logs which electronically identifies all individuals | |||
entering the room. | |||
Technical Specification 6.8.D. requires that " Written Procedures to | |||
implement the Fire Protection Program shall be established, imple- | |||
mented and maintained." One Fire Protection Program Procedure is | |||
8.B.14, Fire watch, which requires that fire watches inspect the | |||
plant areas found with inoperable fire protection equipment or | |||
degraded barriers. The failure of the fire watches to perform as | |||
required by procedure, is a violation of the Technical Specification | |||
6.8.D in that the individuals did not perform the required room | |||
surveillance. (50-293/86-36-04) | |||
! | |||
-_ | |||
. | |||
. | |||
10 | |||
The licensee, subsequent to the inspector's observation, issued a | |||
memo to all fire watches iterating the performance requirements for | |||
the job and specifically included the warning that although it is | |||
important to document the fire watch activity, the primary function | |||
of the watch is to look out for fire and fire hazards. | |||
Availability of Fire Fighter Gear | |||
The licensee's fire fighting procedures require that when a fire | |||
alarm is received the designated shift fire brigade leader is dis- | |||
patched to the fire ccene to perform an assessment of the fire hazard | |||
while a second operator goes to the fire brigade locker to don | |||
protective equipment. The second operator is then responsible for | |||
bringing protective equipment to the fire scene for the brigade use. | |||
The protective equipment involved is boots, gloves, turnout coat, | |||
helmet, self-contained breathing apparatus and flash lights. This | |||
equipment is bulky and heavy. The inspector expressed the concern | |||
that this method of responding to fires (with one operator doning the | |||
protection equipment) is physically demanding and might result in | |||
delaying the brigades initial response to the fire. | |||
The licensee agreed with the inspectors observation. In order to | |||
facilitate use of the protective equipment the licensee plans to | |||
either provide additional protective equipment throughout the plant | |||
or disperse the available equipment so that the distance travelled | |||
by the operator carrying the equipment from the fire locker to the | |||
fire scene is minimized. | |||
Fire Fighting With Off-Site Fire Departments | |||
TN. licensee conducts a fire drill once per year with the local fire | |||
dei .rtment. The inspector observed that although the local fire | |||
, de >.rtment is cooperating with the licensee. in that regard, a formal | |||
l agreement specifying responsibilities and designating the person in | |||
! charge at the fire scene does not exist. The inspector discussed | |||
with plant management that such agree.nent may prevent disagreements, | |||
i during an emergency among the site and offsite brigade leaders. A | |||
! | |||
useful agreement would specify the function of the off-site depart- | |||
ment in the fire fighting activity and specify that the person who | |||
, will be in charge at the fire scene is a member of the licensee's | |||
j staff who is competent to assess the potential safety consequences of | |||
a fire and fire suppresants and is able to advise control room | |||
personnel. The NRC in Branch Technical Positions 9.5-1 provides | |||
guidance for joint drills and training with offsite fire departments. | |||
. | |||
The licensee plant management committed to pursue a resolution to | |||
I this issue by preparing a formal cooperation agreement with the local | |||
fire department addressing the concern. | |||
l | |||
_-- - __ | |||
. l | |||
. | |||
11 | |||
3.6 Review of Equipment Maintenance, Inspection and Tests | |||
The inspector reviewed the following documents to determine whether | |||
the licensee had developed adequate procedures which establish . | |||
maintenance, inspection, and testing requirements for the plant fire | |||
protection equipment: | |||
* | |||
Procedure No. 3.M.4-72, once/ cycle Diesel Fire Pump Engine | |||
Check, Revision 0; | |||
* | |||
Procedure No. 8.B.19, Fire Brigade Equipment Inspection, | |||
Revision 1; | |||
* Procedure No. 8.B.4, Smoke and Heat Detection System, | |||
Revision 14; | |||
* | |||
Procedure No. 8.B.11, Fire Valve Operability, Revision 7; | |||
* Procedure No. 8.B.3.1, Fire Hose Station Equipment Inspection, | |||
TS Related, Revision 1. | |||
In addition to reviewing the above documents, the inspector reviewed | |||
the maintenance / inspection / test records of the items marked with an | |||
asterisk to verify compliance with Technical Specifications and | |||
established procedures. | |||
3.7 Periodic Inspections and Quality Assurance Audits | |||
3.7.1 Annual Audit | |||
The inspector reviewed Audit Report 85-55, Annual Fire | |||
Protection Audit. The scope of review was to ascertain | |||
that the audit was conducted in accordance with the Tech- | |||
nical Specification Section 6.14.1 and audit findings were | |||
being resolved in a timely and satisfactory manner. | |||
i | |||
3.7.2 Biennial Audit | |||
! The inspector reviewed Audit Report 85-22, Fire Protection | |||
! Biennial Audit. This audit was performed by the licensee | |||
in accordance with the guidelines contained in Generic | |||
Letter 82-21. | |||
L | |||
l | |||
. | |||
. | |||
12 | |||
3.7.3 Triennial Audit | |||
The inspector reviewed Audit Report 84-27, Fire Protection | |||
Triennial Audit. | |||
The scope of review was to ascertain that the audit was | |||
conducted in accordance with TS 6.14.2 and audit findings | |||
were being resolved in a timely and satisfactory manner. | |||
With regard to the above, the inspector observed that the | |||
QA audits identified specific deficiencies in the fire | |||
brigade training, the fire watch training and deficiencies | |||
with degraded barriers. It was noted that the audit | |||
findings had been closed out. Since the deficiencies | |||
identifed in-the above audits are similar to the deficiencies | |||
identified by the inspector it appears that the licensee's | |||
corrective actions and actions to prevent recurrence were | |||
inadequate. | |||
This is an unresolved item pending a review of the licensee's | |||
actions to close out the QA findings related to the fire | |||
program. (50-293/86-36-05) | |||
3.8 Facility Tour | |||
The inspector examined the fire protection water systems. This | |||
included fire pumps, fire water piping and distribution systems, post | |||
indicator valves, hydrants and the contents of hose houses. The | |||
inspector toured accessible vital and non-vital plant areas and | |||
examined fire detection and alarm systems, automatic and manual fixed | |||
suppression systems, interior hose stations, fire barrier penetration | |||
seals, and fire doors. The inspector observed general plant house- | |||
keeping condition and randomly checked tags of portable extinguishers | |||
for evidence of periodic inspections. No deterioration of equipment | |||
was noted. The inspection tags attached to extinguishers indicated | |||
that monthly inspections were performed. The inspector did not | |||
identify any unacceptable conditions other than those identified in | |||
; other sections of this report. | |||
4. Unresolved Items | |||
Unresolved items are matters about which more information is required to | |||
ascertain whether they are acceptable items, violations or deviations. | |||
Unresolved items disclosed during the inspection are discussed in Sections | |||
3.4, 3.5 and 3.7. | |||
. | |||
. | |||
13 | |||
5. Exit Interview- | |||
The inspector met with the licensee representatives (see Section 1.0 for | |||
attendees) at the conclusien of the inspection on October 24, 1986. The | |||
inspector summarized the scope and findings of the_ inspection at that | |||
time. The inspector also confirmed with the licensee that the report will | |||
not contain any proprietary information. The licensee agreed that the | |||
inspection report may be placed in the Public Document Room without prior | |||
ifcensee review for proprietary information (10 CFR 2.790). | |||
Atkotimeduringthis-inspectionwaswrittenmaterialprovidedtothe | |||
licensee by the inspector. | |||
; | |||
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}} |
Latest revision as of 16:11, 19 December 2021
ML20207J763 | |
Person / Time | |
---|---|
Site: | Pilgrim |
Issue date: | 12/23/1986 |
From: | Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
To: | |
Shared Package | |
ML20207J740 | List: |
References | |
50-293-86-36, NUDOCS 8701080581 | |
Download: ML20207J763 (13) | |
See also: IR 05000293/1986036
Text
.
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 86-36
Docket No. 50-293
License No. DPR-35 Priority - Category C
Licensee: Boston Edison Company M/C Nuclear
800 Boylston Street
Boston, Massachusetts 02199
Facility Name: Pilgrim Atomic Power Station
Inspection At: Plymouth, Massachusetts
Inspection Conducted: October 20-24, 1986
Inspector: ..th]l['c[ auAvdv
A. Krisopo0 Tot', ~ Reactor Erigineer, DRS
/ /1 B 6
' I dat'e
Approved by: %f_ . 1,. o / _ / _
/ J43/76,
p. J(' Anderson, Cliief, Plant Systps Section ' dat(
Inspection Summary: Inspection on October 20-24, 1986 (Report 50-293/86-36)
Areas Inspected: Routine unannounced inspection of the fire protection / preven-
tion program including a review of: the combustible material control / hazard
reduction program; programmatic administrative controls; installation, oper-
ability and maintenance of fire protection systems; fire protection LERs; fire
fighting capabilities; fire protection equipment maintenance inspection and
tests; periodic inspections and quality assurance (QA) audits of the fire
protection program and a facility tour.
Results: Of the eight areas inspected two violations were identified and three
items remain unresolved.
10gh $$ 3
0
.
.
DETAILS
1. Persons Contacted
1.1 Boston Edison Company (BECO)
- A. E. Pedersen, Plant Manager
- W. Sullivan, Fire Protection Engineer
- J. McEachern, Resources Protection
- J. Quinn, Plant Engineer
- R. Velez, Project Manager
- E. Ziemianski, Nuclear Management Services Section Manager
B. Lunn, Compliance Engineer
R. Laroue, Training Specialist
1.2 Nuclear Regulatory Commission (NRC)
- M. McBride, Senior Resident Inspector
- Denotes those present at the exit interview.
2. Inspection Purpose and Methodology
The purpose of this inspection was to evaluate the licensee's fire protec-
tion and prevention program (FPPP) and verify that the licensee has
developed and implemented adequate procedures, consistent with the appli-
cable Technical Specifications (TS), license conditions, regulatory
requirements and commitments made in the Final Safety Analysis Report and
the Fire Protection System Evaluation Report (FPSER). The evaluation of
the program consisted of a documentation and procedure review, interviews
with licensee personnel and field observations.
The documents reviewed, the scope of review and the inspection findings
for each area reviewed are described in the following sections.
3. Fire Protection Program Review
3.1 Review of Combustible Material Control - Hazard Reduction
The inspector toured the plant to inspect housekeeping conditions,
work in process and activities or conditions that may present a
hazard to the facility.
The scope of review was to verify that the licensee:
a. Keeps safety related and adjacent plant areas free from transi-
ent combustibles;
.
.
.
3
b. Keeps. flammable and combustible liquids under administrative
control and the storage of such liquids is in accordance with
the guidelines of the National Fire Protection Association
(NFPA) Standards;
c. Performs periodic inspection for accumulation of combustibles;
d. Uses wood treated with flame retardant for work inside plant
areas;
e. Does not allow the accumulation of waste, debris, rags, oil
spills, and other combustible materials resulting from a work
activity to extend beyond the end of each work shift or the end
of the activity, whichever is sooner; ,
f. Properly maintains the housekeeping in all areas containing
safety related equipment and components; ,
g. Prohibits smoking in safety related areas except where " smoking
permitted" areas have been specifically designed by plant
management; and
h. Requires special authorization (work permit) for activities
involving welding, cutting, grinding, open flame or other igni-
tion sources, and that these activities are properly safe-
guarded.
During the inspection the inspector did not identify any conditions
that present a safety hazard, however, in the Turbine Building,
elevation 51' 0", the inspector observed that the flammable storage
cabinets located therein, were neither grounded nor vented as per
cabinet manufacturers and NFPA recommendations. The licensee cor-
rected this condition prior to the inspector leaving the site.
I
3.2 Review of Administrative Controls
The inspector reviewed the following licensee documents:
-
Technical Specifications, Section 6, Administrative Controls; ;
l
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License Condition 3.F. Fire protection requiring the licensee l
to implement the administrative controls identified in the Fire '
Protection Safety Evaluation and the requirements listed in the
" Nuclear Plant Fire Protection Functional Responsibilities,
Administrative Controls and Quality Assurance";
-
BECO Fire Protection System Evaluation; and
-
Pilgrim Training Manual.
_. -- -
.
.
4
The scope of review was to verify that the licensee had developed
administrative controls which require that:
a. Work authorization, construction permit or similar arrangement
is provided for review and approval of modification, construc-
tion and maintenance activities which could adversely affect the
safety of the facility;
b. Fire brigade organization and qualifications of brigade members
are delineated;
c. Fire reporting instructions for general plant personnel are
developed;
d. Periodic audits are to be conducted on the entire fire protec-
tion program; and
e. Fire protection / prevention program is included in the licensee's
QA Program.
No unacceptable conditions were identified.
3.3 Review of Installation, Operability and Maintenance of Fire
Protection Systems
The inspector reviewed the installation of randomly selected fire
protection systems, fire protection system flow diagrams, made obser-
vations on the condition and operability of the fire protection
equipment and reviewed the Fire Protection Equipment Main-
tenance Request List to determine whether:
a. Fire protection equipment such as stand pipes and hose stations
are operable and accessible in all areas important to safety;
b. Adequate portable extinguishers are provided at designated
places in each fire area;
c. The condition of all fire suppression devices inspected is
satisfactory;
d. The system's valves are lined up in the proper position and are
protected from tampering; and
e. The fire protection equipment is well maintained.
f. The fire barriers and related components such as fire doors,
fire dampers, and penetration seals have been installed and
maintained properly to insure against fire propagation.
_
. _ _ _ _ _ _ _ _ _ _ _ _ _
,
! .
.
5
As a result of this review the following observations were made by
the inspector:
a. The licensee is not agressively pursuing maintenance and repair
work to the fire protection systems as evidenced by the large
amount of incomplete repair work on fire protection system
components.
This observation is based on the following:
(1) Almost 300 work requests were outstanding for repair
work on fire protection system components
(2) Eight (8) maintenance requests are for work that affects
the fire pump system, and if left undone may affect pump
operability and
(3) Twelve (12) maintenance requests were originated in 1983,
about thirty requests were originated in 1984, and the
remainder of the (300) requests originated in 1985 and
1986.
b. The licensee has relied heavily on fire watches as a substitute
for degraded fire protection system components. During the
inspection period, the licensee had an average of fifty-five
(55) fire watch postings covering about thirty-five (35)
different areas. Thirty (30) of these watches had been in place
for more than three (3) months, eight (8) had been in place for
more than a year and the remainder were established within the
last 3 months.
The above items are collectively categorized as an unresolved item pending
a review of the licensee's actions to implement repairs on the fire pro-
tection system components and minimize the use of fire watches as a
substitute for correcting deficiencies in the fire system. (50-293/86-36-01).
The inspector also noted that the access way to Hose Station No. TA 86-51
was blocked by an instrument cart. This could impede use of the hose
station in an emergency. The licensee took immediate action to relocate
the cart. This appeared to be an isolated incident.
'
3.4 Review of Licensee Event Reports (LER)
The inspector reviewed eight recent fire protection LERs. The LERs
reviewed were Nos. 86-23, 86-20, 84-07, 83-41, 83-38, 83-30, 83-25
and 83-27.
The inspector concluded that seven of the eight LER's were related
to fire barrier degradation. Five of the LERs were issued because of
inoperable fire barriers. These barriers were declared inoperable
because of either missed barrier surveillances or because of degraded
barrier components such as penetration seals and fire doors. Two
LERs were issued because fire watches established as compensatory
measures had not perform as required, due to inadequate instructions.
i
___
._
.
.
6
The inspector reviewed the weekly fire watch logs and the Maintenance
Request List (MRL) to determine the nature and extent of the fire
barrier deficiencies. From these documents and from interviews with
licensee personnel, the inspector learned that the following barriers
were declared inoperable because of suspected barrier degradation:
Vital Motor Generator Set Room Floor
Battery Room B West Wall
Battery Room B North and East Wall
Computer Room West Wall
A Switch Gear Room West Wall
A Switch Gear Room North Wall
Battery Room A East Wall
Battery Room A West Wall
Vital Motor Generator Set Room North Wall
- Vital Motor Generator Set Room West Wall
A Switchgear Room South Wall
'
A Switchgear Room Floor
Diesel Generator Room A East Wall
Diesel Generator A/B Area South Wall
Diesel Generator Room East Wall
Turbine Tool Storage Room East Wall
Filter Room South Wall
HVAC #2 Room South Wall
Turbine Deck
Reactor Buildings Floor 91'
Reactor Buildings Floor 51'
Reactor Building 51' South Wall
Fan Room #3 Reactor Building 74' Floor
Reactor Building 74' Floor
Recirculation Motor Generator Set East Floor 51'
Reactor Building 23' Floor
Recirculation Motor Generator Set East Wall 51'
Water Treatment Area North Wall
Auxiliary Boiler Room West Wall
Auxiliary Boiler Room North Wall
Turbine Lube Oil Area North Wall
1 Condensate Pump Area South Wall
Turbine Lube Oil Ceiling
l Intake Structure North Wall of the Service Water Pump Rooms
The licensee established fire watches for the above barriers pending
verification of the barrier status, ie, operable-inoperable or the
barrier operability is not required.
The inspector determtried that the reasons for declaring the barriers
inoperable were the following:
'
,
a. Penetrations seal documentation either does not exist or is
unclear;
i
_ . . _ . _ _ _ - . _ - - - _ - - - - _ _ _ - - _ _ _ . _ - _ _ _ _ _ _ _ _ _ - - - - - - - - _ - _ - - _ _ . - _ - _ _ . _ _
_ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
' 7
b. Barrier components appear degraded;
c. Uncertainty exists as to whether the fire barrier is required.
With regard to Item a, the licensee stated that during a check of the
documentation necessary to verify the fire rating of the seals, ques-
tions were raised as to the adequacy of QC during seal installation.
In addition, seal test data and other parameters necessary to estab-
lish seal adequacy were not available. In some cases, the licensee
stated that the documantation either can not be found or does not
exist. With regard to Item b, field inspections by the licensee
identified penetrations with some impairments. The licensee had not
completed their evaluation of these deficiencies. With regard to
i Item c, a number of penetrations were identified as degraded. How-
ever, uncertainty exists as to whether these barriers are required.
'
The licensee is in the process of evaluating all of the suspected
!
non-conformances in a systematic way. An analysis is being performed
4 to identify which of the barriers are required by the Technical
i Specification, Appendix R or by licensing commitments. The licensee
is evaluating the adequacy of all seals either by analysis or sim-
ilarity tests. Any non-conformances identified during this process i
will be reported in accordance with the applicable reporting require-
'
'
- ments.
The above was collectively categorized as an Unresolved Item pending
review of the licensee's actions to evaluate the barriers, report
non-conformances and implement required repairs. (50-293/86-36-02).
3.5 Review of Fire Fighting Capabilities
t
The inspector reviewed the licensee documents listed below, conducted
interviews with personnel and inspected fire fighting gear to evaluate the
on-site capability of the licensee to fight fires: a
!
The documents reviewed were:
i
-
License Amendment No. 35 section 3.F;
- -
Fire Protection Safety Evaluation Report
i
-
Pilgrim Training Manual;
- -
Fire Brigade Training Drill Procedure No. 1.4.23, Revision 7; ,
- -
Fire Watch Procedure No. 8.B.14, Revision 7;
i -
Special Fire Procedure No. 5.5.2; and
i
-
Qualified Fire Fighter Rosters.
i
The scope of the review was to:
I
l a. verify that all personnel designated to take part in fire emer-
i gencies are trained in these actions and in the overall emergency
plan,
i
- - . . - , . ~ --,,e ,..-,~.,-,._.._.---,..,,-,n.-,--- .
- . _ , , . , , - , . ~ . , , _ , _ , __..,..__---,--.v----
-
.
.
8
b. verify that the licensee has established a training program that
ensures the capability to fight potential fires;
c. verify that the licensee's training p ogram consists of initial
classroom instruction followed by periodic classroom instruction,
firefighting practice and fire drills,
d. verify that the licensee had developed fire fighting strategies for
fires in all safety related areas and in areas in which a fire could
present a hazard to safety related equipment and
e. verify that the fire fighters can fight plant fires with the equip-
ment available.
With regard to the above, the inspector made the following observations
concerning the overall adequacy of the fire brigade training, the adequacy
of the fire watches, the adequacy of and use of the fire fighters
protective gear and the ability to fight plant fires jointly with the
local fire department:
Fire Brigade Training
The Pilgrim Station Operating License, Number DPR-35, in Section 3.F.
titled " Fire Protection", requires the licensee to implement the
administrative controls specified in Section 6 of the NRC Fire
Protection Safety Evaluation (SE) dated December 21, 1978.
Section 6 of the SE states that the licensee will provide the fire brigade
training in accordance with the guidelines contained in the " Nuclear Fire
Protection Functional Responsibilities, Administrative Controls and Qual-
ity Assurance" document. This document specifies that the Fire Brigade
Members Qualification and Training Program includes the following:
-
Initial classroom instructions;
-
All brigade members shall have hands-on fire fighting practice
at least once per year;
-
Classroom instruction is provided to all fire brigade members
every 3 months so that the initial classroom program is
repeated over a two year period;
-
Fire brigade drills are performed so the brigade can practice as
a team;
-
Membership to the brigade should include satisfactory completion
of a physical examination for performing strenuous activity; and
\
.
.
9
-
The training shall be as specified in the National Fire
Protection Association (NFPA) Standard 27.
The inspector reviewed the training records for the brigade members
and interviewed all of the shift fire brigade members to eval-
uate the licensees conformance with the above requirements. The
review identified the following:
The licensee allowed in calendar year 1986 at least nine (9) fire-
fighters who missed two (2) consecutive quarterly training sessions
and twenty-one (21) fire fighters who missed one (1) quarterly training
session to be active members of the brigade.
The above is a violation of the license requirement to provide
quarterly classroom instruction to all active members of the Fire
Brigade. (50-293/86-36-03)
The inspector also noted that about thirty (30) fire fighters had not i
participated in any fire drills. However, NRC Report No. 86-21 pre-
viously identified this deficiency as a deviation from the training
requirements.
The licensee indicated that an accelerated Fire Brigade Training
Program is being implemented so that the qualifications of all
brigade members are maintained.
The inspector reviewed the licensee's followup to LER 86-23. In the
LER the licensee identified a deficiency with fire watches not
properly documenting their surveillance of certain fire areas. No
deficiencies were observed, during this inspection, with regard to
the proper documentation of surveillances performed. However, the
inspector observed that the fire watch assigned to patrol the
degraded fire barriers in the MG Set room on October 21, 1986 did not
inspect the room. The fire watch entered the room, signed the fire
watch log and laft. Similarly, the inspector observed that the fire
watches assigned to patrol the degraded fire barriers the vital MG
Set room never entered the room, instead they signed the log locnted
outside the room and left. This was ascertained by an examination of
the security logs which electronically identifies all individuals
entering the room.
Technical Specification 6.8.D. requires that " Written Procedures to
implement the Fire Protection Program shall be established, imple-
mented and maintained." One Fire Protection Program Procedure is
8.B.14, Fire watch, which requires that fire watches inspect the
plant areas found with inoperable fire protection equipment or
degraded barriers. The failure of the fire watches to perform as
required by procedure, is a violation of the Technical Specification 6.8.D in that the individuals did not perform the required room
surveillance. (50-293/86-36-04)
!
-_
.
.
10
The licensee, subsequent to the inspector's observation, issued a
memo to all fire watches iterating the performance requirements for
the job and specifically included the warning that although it is
important to document the fire watch activity, the primary function
of the watch is to look out for fire and fire hazards.
Availability of Fire Fighter Gear
The licensee's fire fighting procedures require that when a fire
alarm is received the designated shift fire brigade leader is dis-
patched to the fire ccene to perform an assessment of the fire hazard
while a second operator goes to the fire brigade locker to don
protective equipment. The second operator is then responsible for
bringing protective equipment to the fire scene for the brigade use.
The protective equipment involved is boots, gloves, turnout coat,
helmet, self-contained breathing apparatus and flash lights. This
equipment is bulky and heavy. The inspector expressed the concern
that this method of responding to fires (with one operator doning the
protection equipment) is physically demanding and might result in
delaying the brigades initial response to the fire.
The licensee agreed with the inspectors observation. In order to
facilitate use of the protective equipment the licensee plans to
either provide additional protective equipment throughout the plant
or disperse the available equipment so that the distance travelled
by the operator carrying the equipment from the fire locker to the
fire scene is minimized.
Fire Fighting With Off-Site Fire Departments
TN. licensee conducts a fire drill once per year with the local fire
dei .rtment. The inspector observed that although the local fire
, de >.rtment is cooperating with the licensee. in that regard, a formal
l agreement specifying responsibilities and designating the person in
! charge at the fire scene does not exist. The inspector discussed
with plant management that such agree.nent may prevent disagreements,
i during an emergency among the site and offsite brigade leaders. A
!
useful agreement would specify the function of the off-site depart-
ment in the fire fighting activity and specify that the person who
, will be in charge at the fire scene is a member of the licensee's
j staff who is competent to assess the potential safety consequences of
a fire and fire suppresants and is able to advise control room
personnel. The NRC in Branch Technical Positions 9.5-1 provides
guidance for joint drills and training with offsite fire departments.
.
The licensee plant management committed to pursue a resolution to
I this issue by preparing a formal cooperation agreement with the local
fire department addressing the concern.
l
_-- - __
. l
.
11
3.6 Review of Equipment Maintenance, Inspection and Tests
The inspector reviewed the following documents to determine whether
the licensee had developed adequate procedures which establish .
maintenance, inspection, and testing requirements for the plant fire
protection equipment:
Procedure No. 3.M.4-72, once/ cycle Diesel Fire Pump Engine
Check, Revision 0;
Procedure No. 8.B.19, Fire Brigade Equipment Inspection,
Revision 1;
- Procedure No. 8.B.4, Smoke and Heat Detection System,
Revision 14;
Procedure No. 8.B.11, Fire Valve Operability, Revision 7;
- Procedure No. 8.B.3.1, Fire Hose Station Equipment Inspection,
TS Related, Revision 1.
In addition to reviewing the above documents, the inspector reviewed
the maintenance / inspection / test records of the items marked with an
asterisk to verify compliance with Technical Specifications and
established procedures.
3.7 Periodic Inspections and Quality Assurance Audits
3.7.1 Annual Audit
The inspector reviewed Audit Report 85-55, Annual Fire
Protection Audit. The scope of review was to ascertain
that the audit was conducted in accordance with the Tech-
nical Specification Section 6.14.1 and audit findings were
being resolved in a timely and satisfactory manner.
i
3.7.2 Biennial Audit
! The inspector reviewed Audit Report 85-22, Fire Protection
! Biennial Audit. This audit was performed by the licensee
in accordance with the guidelines contained in Generic
Letter 82-21.
L
l
.
.
12
3.7.3 Triennial Audit
The inspector reviewed Audit Report 84-27, Fire Protection
Triennial Audit.
The scope of review was to ascertain that the audit was
conducted in accordance with TS 6.14.2 and audit findings
were being resolved in a timely and satisfactory manner.
With regard to the above, the inspector observed that the
QA audits identified specific deficiencies in the fire
brigade training, the fire watch training and deficiencies
with degraded barriers. It was noted that the audit
findings had been closed out. Since the deficiencies
identifed in-the above audits are similar to the deficiencies
identified by the inspector it appears that the licensee's
corrective actions and actions to prevent recurrence were
inadequate.
This is an unresolved item pending a review of the licensee's
actions to close out the QA findings related to the fire
program. (50-293/86-36-05)
3.8 Facility Tour
The inspector examined the fire protection water systems. This
included fire pumps, fire water piping and distribution systems, post
indicator valves, hydrants and the contents of hose houses. The
inspector toured accessible vital and non-vital plant areas and
examined fire detection and alarm systems, automatic and manual fixed
suppression systems, interior hose stations, fire barrier penetration
seals, and fire doors. The inspector observed general plant house-
keeping condition and randomly checked tags of portable extinguishers
for evidence of periodic inspections. No deterioration of equipment
was noted. The inspection tags attached to extinguishers indicated
that monthly inspections were performed. The inspector did not
identify any unacceptable conditions other than those identified in
- other sections of this report.
4. Unresolved Items
Unresolved items are matters about which more information is required to
ascertain whether they are acceptable items, violations or deviations.
Unresolved items disclosed during the inspection are discussed in Sections
3.4, 3.5 and 3.7.
.
.
13
5. Exit Interview-
The inspector met with the licensee representatives (see Section 1.0 for
attendees) at the conclusien of the inspection on October 24, 1986. The
inspector summarized the scope and findings of the_ inspection at that
time. The inspector also confirmed with the licensee that the report will
not contain any proprietary information. The licensee agreed that the
inspection report may be placed in the Public Document Room without prior
ifcensee review for proprietary information (10 CFR 2.790).
Atkotimeduringthis-inspectionwaswrittenmaterialprovidedtothe
licensee by the inspector.
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