ML20132A560

Insp Repts 50-327/84-31 & 50-328/84-31 on 841023-26. Violation Noted:All Fire Brigade Members Not Respirator Qualified & Lack of Maint Program for Fire Protection Strainers

ML20132A560
Person / Time
Site:	Sequoyah
Issue date:	11/08/1984
From:	Conlon T, Miller W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20132A500	List: ML20132A495 ML20132A513 ML20132A536 ML20132A560
References
50-327-84-31, 50-328-84-31, NUDOCS 8507230091
Download: ML20132A560 (9)

See also: IR 05000327/1984031

Text

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UNITE] STATES

( g neev k NUCLEA] RE20LATr.Y COMMISSION

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3 g 101 MARIETTA STREET N.W.

• * ATI.ANTA, GEORGIA 30303

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Report Nos.: 50-327/84-31 and 50-328/84-31

Licensee: Tennessee Valley Authority

500A Chestnut Street

Chattanooga, TN 37401

Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79

Facility Name: Sequoyah

Inspection Condu ted: ctob 1984

Inspector -

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O' Eb

W. H. Miller, Jr. Date Signed

Approved by

T. E. Conlon, Section Chief

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Date Signed

Engineering Branch

Division of Reactor Safety

SUAMARY

Scope: This routine, unannounced inspection entailed 27 inspector-hours on site

in the areas of fire protection / prevention, followup on the licensee's

compensatory actions regarding Confirmation of Action Letter on Appendix R fire

protection' discrepancies, and review of corrective actions on previously

identified NRC and licensee identified items.

Results: Of the areas inspected, two apparent violations were found (all fire

brigade members are not respirator qualified - paragraph 6.a. and no maintenance

program provided for fire protection strainers - paragraph 6.c. One apparent

deviation was Lfound (fire protection system containment isolation valves are not

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provided with statu lights in the main control room - paragraph 3.e).

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8507230091 841114

PDR ADOCK 05000327

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REPORT DETAILS

1. Licensee Employees Contacted

J. Alexander, Shift Engineer

• W. H. Baker, Fire Protection Engineer

• J. Blankenship, Information Officer

• L. Bush, Operations Group

• S. Butler, QA Supervisor.

• M. R. Cooper, Compliance Engineer

• D. E. Crawley, Health Physics Supervisor

• J. T. Dills, Jr., Asst. Health Physicist

• V. L. Dudley, Fire Protection Engineer

• R. W. Fortenbury, Engineering Section Supervisor

• M. R. Harding, Engineering Group Supervisor

• G. B. Kirk, Compliance Engineer

• J. B. Krell, Plant Superintendent (Maintenance)

• J. D. McCamy, Engineering and Testing

R. Moore, DQA/QAB

• L.M. Nobles, Superintendent (0&E)

• R. W. Olson, Modification Manager

• D. L. Paul, Senior Engineer, Site Service

• M. A. Purcell, Mechanical Engineer

• J. H. Sullivan, Appendix R. Project Manager

• J. M. Qualls, Operations

• P. R. Wallace, Plant Manaser

• J. E. Wills, Licensing Engineer

• G. G. Wilson, Assistant Ops Supervisor

NRC Resident Inspector

E. Ford

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on October 26, 1984, with

.those persons indicated in paragraph 1 above. The licensee acknowledged the

following inspection findings:

a. Inspector Followup Item (327 and 328/84-31-01), Fire Detectors Over

ERCW Pumps are Not Included in the Technical Specifications - paragraph

3.a.

b. Deviation Item (327 and 328/84-31-02), Fire Protection System

Containment Isolation Valves Are Not Provided with Status Lights in the

Main Control Room - paragraph 3.e.

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c. Violation Item (327 and 328/84-31-03), All Fire Brigade Members Are Not

Respirator Qualified - paragraph 6.a.

d. Violation item (327 and 328/84-31-04), No Maintenance Program Provided

for Fire Protection System Strainers - paragraph 6.c.

3. Licensee Action on Previous Enforcement Matters

a. (Closed) Deviation Item (327/81-14-03), Fire Detection Is Not Provided

Over ERCW Pumps. Fixed temperature type fire detectors have been

provided over each ERCW pump. These detectors are not included in

Technical Specifications as required. This is identified as Inspector

Followup Item (327 and 328/84-31-01), Fire Detectors Over ERCW Pumps

are not Included in the Technical Specifications, and will be reviewed i

during a subsequent NRC inspection.

, b. (Closed) Unresolved Item (328/81-14-03), Fire Detection is Not Provided

Over ERCW Pumps. Refer to abw e item 3.a.

c. (0 pen) Deviation Item (327/80-10-01), Substandard Fire Protection

Administrative Procedures. As previously reported in Report Nos.

327/80-17 and 328/80-10, the licensee revised the plant procedures to

comply with the NRC guidelines for fire brigade training and drills.

Subsequently, procedure PHYSI 13, Section 4.5.1, has been revised to

require wood used in safety-related areas of the plant to be of the

pressure fire retardant type unless an exemption is granted by the

plant safety staff for use of other types of materials. This appears

to meet the intent of the NRC guidelines. Fire fighting procedures for

all safety-related areas have not yet been prepared. The licensee

stated that approximately five procedures for safety-related areas and

20 for nonsafety-related areas remain to be prepared. This item is to

. remain open until these procedures are prepared.

d. (Closed)DeviationItem(327/80-10-02), Substandard Supervision of Fire

Protection Control Valves. The licensee has established Procedure

SI 654, Fire Protection Header Valve Seal Inspection (Weekly), and is

inspecting the control valves to the automatic sprinkler systems

weekly. These valves are maintained sealed in the correct alignment.

This arrangement meets the applicable NFPA criterion and is acceptable,

but does not meet the TVA commitments to lock the valves in the open

position. The commitments should be reviewed and revised as required.

However, for Region II's inspection program, this item is closed,

e. (Closed) Unresolved Item (327/80-10-07), Supervision of Containment

Isolation Fire Protection Valves. TVA has taken no corrective action

l on this item. FSAR, Section 6.2.4.2.2, states that the safeguard

, position of automatic containment isolation valves is indicated by

l status lights in the main control room. The position of the contain-

j ment isolation valves in the fire protection piping which penetrates

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the containment is not provided with status lights in the control room.

Therefore, this unresolved item is closed, but this FSAR discrepancy

which is applicable to both units is identified as Deviation Item (327

and 328/84-31-02), Fire Protection System Containment Isolation Valves

Are Not Provided With Status Lights in the Main Control Room.

4. Unresolved Items

Unresolved items were not identified during this inspection.

5. Review of Appendix R Confirmation of Action Commitments (92703)

16 - 20, 1984, 10 CFR 50 Appendix R inspec-

,

following

tion the NRC

of Watts Bar Reg (ion Nos.

Report II July50-390/84-55 and 50-391/84-43), TVA

identified a number of cable interaction deficiencies at Sequoyah. On

August 10, 1984, NRC Region II issued a Confirmation of Action Letter to TVA

identifying the action to be taken by TVA to implement a complete review of

the Appendix R program at Sequoyah, the compensatory measures to be

established for the identified deficiencies, and an established time

schedule for submission of status reports.

TVA's review continues to identify Appendix R deficiencies. The final TVA

report is scheduled to be submitted to Region II prior to January 1,1985,

at which time the appropriate enforcement action will be determined.

This inspection reviewed the following deficiencies as identified by TVA's

report dated October 15, 1984, and the compensatory action taken for the

deficiencies:

a. TVA Appendix R Review Team

TVA has established a team consisting of 51 (38 full-time and 13 part-

time) engineers, technicians, and operational personnel to reevaluate

the Sequoyah plant for com TVA

Design Engineering (ENDES) has 11pliance

peoplewith Appendix

on site and 27 R in requirements.

the design

office in Knoxville and operations has assigned 13 personnel to assist

in the site review. The team appears well managed, organized and is on

schedule to meet the established review completion schedule.

b. Fire Shutdown Logic Diagram

The shutdown logic diagram continues to be revised to reflect the

actual "as built" plant conditions and systems currently considered to

be required for safe shutdown. This item wiil be reviewed during a

future NRC inspection,

c. Cable Interaction Evaluation

As of October 15, 1984, TVA has produced over 90 drawings which

indicate the cable routing in the plant. Approximately 75% of these

drawings had been field verified. Field verification is scheduled to

be completed by October 29, 1984. A total of 34 cable interactions

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which violate Appendix R,Section III.G.2 criteria have been identified

by TVA. The NRC inspector toured each of these interaction areas and

noted that all of these interactions are in areas provided with

automatic sprinkler protection and a fire detection system, except

interactions above the ceiling of the counting room and RWST pipe

tunnel in Unit I which consist of a bank of 36 conduits, and inter-

actions in the Units 1 and 2 pipe chases at 690' elevation. However, a

temporary temperature monitor system has been installed in the Units 1

and 2 pipe chases and ERCW pipe tunnel (Refer to paragraph 5.g below).

The installed sprinkler systems have some minor obstructions from

cable trays, ducts, hangers, structural support, etc. The more

critical obstructions are located on the 714' elevation of the

auxiliary building. The inspector suggested that TVA review the

entire sprinkler system installation and verify that the systems

would meet the requirements of Appendix R,Section III.G., i.e.,

the system must be capable of assuring that in the event of a fire

et least one train of hot shutdown system is maintained free of fire

damage.

d. Associated Circuit Analysis

The associatet circuit analysis is being conducted in TVA's Knoxville

design office This analysis is approximately 55 percent complete for

auxiliary powti cables and 95 percent complete for control power

cables. The analysis is required to be completed and submitted to NRC

Region II by December 21, 1984. A review of this analysis will be made

by the NRC during a subsequent NRC inspection.

e. Reactor Coolant Pump 011 Collection

The oil collection systems for the reactor coolant pumps were

identified by TVA as being of insufficient capacity to hold the oil

resulting from the largest spill due to a single failure. Modifica-

tions which had been made since the initial design of the system to

satisfy other commitments and safety issues had reduced the volume

available for oil collection. TVA's evaluation indicated that the

drain piping system plus a portion of the collection sump would be

sufficient to hold the oil from a single failure if sufficient capacity

was available for oil collection. Therefore, TVA has revised

annunciator procedure No. 501-55-1MS, Annunciator Response, (Change No.

84-1475) and issued a " Night Order" to require the operator to verify

that the reactor building pocket sump is maintained at less than 45%

full in the event of a high or low level alann in either the upper or

lower bearing oil reservoir for the reactor coolant pumps. The

inspector verified that these procedures were properly filed within

the control room.

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The present arrangement of the oil collection system for the reactor

coolant pumps does not meet the requirements of Appendix R,

Section III.0 since the drainage system will not handle an oil break

from all of the lubrication systems simultaneously following a safe

shutdown earthquake. This discrepancy requircs a formal deviation

request. NRC Region !! will review this system in detail during a

subsequent inspection.

f. Emergency Lighting

TVA has identified a number of additional plant areas where operator

action is required to bring the plant to hot shutdown. These

additional areas are not provided with the 8-hour emergency lighting

units required by Appendix R.Section III.J. Approximately 75

additional 8-hour type lighting units will be required. Also, some of

the existing lighting units were found by TVA to have 25 watt lamps in

lieu of 10 watt lamps which are needed for the units to provide eight

hours of illumination. The correct lamps are to be instelled for these

units. As an interim measure, TVA has supplied 12 portable lanterns to

the operation staff for use in the event of the failure of the normal

and other emergency lighting systems. The inspector verified that

these portable lanterns were provided. Nine lanterns were provided in

a cabinet adjacent to the auxiliary control room and three lanterns

were in a cabinet adjacent to the shift engineer's office in the

control building. Additional flashlights and batteries were also

provided.

g. Firewatch

Following identification of the Appendix R. Section III.G, cable

interaction discrepancies, the licensee initiated three roving and one

fixed firewatch per shift to provide continued sur eillance of selected

areas in the auxiliary, control, turbine, diesel generator, and

essential raw cooling water pumping station buildings in which the

interaction discrepancies had been identified. Each roving firewatch

is required to cover his assigned areas once each hour per shift.

Checklists have been provided to document the time each room or area

is visited. The one stationary firewatch monitors the temperature

indicators provided for the two pipe chases and ERCW pipe tunnel. TVA

has implemented a procedure which identifies the firewatch duties and

assignments.

The inspector verified that all of the current personnel assigned

firewatch duties had completed the required training, appropriate

firewatch records were provided and that the program was being imple-

mented. No discrepancies were noted, except the firewatch checklists

for two shifts, August 13 (2300 to 0700) and September 24, (0700 to

1500) 1984, were not available. However, the daily control room

journal log indicated that the firewatch duties were performed for

these dates. This problem occurred following the initial implementa-

tion of this firewatch program. At that time, a portion of the fire

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watch personnel was supplied by two management groups. To improve the

management of this program, TVA assigned all firewatch personnel under

the supervision of the operations supervisor. Presently, this program

appears to be satisfactorily implemented.

h. QA Program

The licensee stated that all modifications accomplished as a result of

this Appendix R reevaluation are to be accomplished under the normal

operations QA/QC program. The inspector reviewed work plan 11192

(ECN-L6209) for the installation of some of the fire barriers and

verified that appropriate OA/QC hold points were designated.

Within the areas examined, no violations or deviations were identified.

However, as noted above, enforcement action on the licensee identified items

is being deferred pending completion of TVA's evaluation.

6. Fire Protection / Prevention Program Implementation (64704)

A review was made of the following fire protection features to verify that

the licensee was implementing a program for fire protection and prevention

that was in conformance with NRC requirements, consnitments to the NRC, and

site procedures:

a. Fire Brigade

The fire brigade is composed of personnel from the operations group.

The team leader is an assistant shift engineer and the brigade members

are auxiliary unit operators. There are 16 designated brigade leaders

and 79 members. The training, drill and medical review records for

four team leaders and ten members were reviewed to verify that these

personnel had attended the basic and/or leadership training, quarterly

classroom training, two drills within the past year, medical review

within the past year, and were respirator qualified. From the record

data reviewed, the only discrepancy noted was that four of the brigade

members were not respirator qualified. One member had never received a

respirator fit test, one member was five months overdue for a whole

body count, and two were slightly over due (24 and 4 days) for medical

review.

A cursory document review indicated that a number of other fire brigade

members were also not respirator qualified. Radiation Control

Instruction RCI-14,Section V.A. states that respirator protection is

required for conditions involving airborne contamination and that the

workers must have a current whole body count, respiratory fit and

training and current medical review. Technical Specification, Section 6.8.1.a. requires written proccudres to be established, implemented and

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maintained covering the applicable procedures listed in Appendix A of

Regulatory Guide 1.33. This guide requires procedures for radiation

protection. The failure of brigade members to meet the respiratory

qualification program is identified as Violation Item (327 and 328/

84-31-03), All Fire Brigade Members are Not Respirator Qualified.

b. Fire Brigade Equipment

The fire brigade equipment is stored in a locked storage area on 706'

elevation of the service building which is readily accessible to the

auxiliary and control buildings. A total of ten self contained

breathing apparatus with ten spare cylinders, ten sets of turnout gear

(boots, helmets, coats, gloves, etc.), hand lights, fire hose, nozzles,

two portable exhaust fans and miscellaneous equipment were provided.

An equipment trailer with additional fire hose, extinguishers and

miscellaneous equipment is located outside the plant structure near the

main security entrance gate. An additional 82 breathing apparatus and

72 spare cylinders are available to the fire brigade from health

physics, which is adequate to meet the required six-hour supply for the

brigade. The fire brigade equipment appeared satisfactorily maintained,

c. Fire Protection Systems

The completed surveillance inspection and test records for the

following systems at indicted dates were reviewed to verify that these

systems were inspected and tested within the frequency established by

the Technical Specifications:

(1) SI 167, Fire Header Valve Lineup Inspection (Monthly)

January 5 through September 15, 1984

(2) SI172,FireSystemTestableValveCycling(12 months)

August 10, 1982 through August 24, 1984

(3) SI 173, Fire System Nontestable Valve Cycling (18 months)

July 29, 1983 through October 13, 1984

(4) SI 174, Fire System Sprinkler System Testable Valves (12 months)

August 9, 1983 through August 8, 1984

(5) SI 176 Fire Suppression Water Sprinkler System Functional Test

(18 months)

September 12, 1982 through March 2, 1984

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(6) SI 180, Fire Pump Start Test

January 9 through September 15, 1984. Pump 1AA was removed from

service on July 18, 1984, for major repairs. Pump was restored to

service on August 24, 1984.

(7) SI 190, Fire Hose Inventory (Monthly)

January 13, 1984 through October 15, 1984

(8) SI 234.2, Fire Detection System - 714' of Auxiliary Building,

Intake Pumping Station and ERCW Pumping Structure (6 months)

July 2, 1983 through July 16, 1984

In reviewing the licensee's surveillance inspection and test program

for the fire protection automatic water spray and sprinkler system,

it was noted that the strainers in the supply piping to these systems

were not included in periodic maintenance inspection and cleaning

programs required by NFPA-15, Water Spray Fixed Systems for Fire

Protection, Section 6012 (1973 Edition). FSAR, Section 9.5.1.4,

states that fixed water suppression systems are periodically tested

in accordance with the applicable NFPA code requirements to ensure

operability and inspected at regular intervals to ensure that all

equipment is in good operating condition. Technical Specification, Section 6.8.1.f requires written procedures to be established, imple-

mented and maintained for the fire protection program implementation.

The lack of a maintenance program for these strainers is identified as

Violation Item (327 and 328/84-31-04), No Maintenance Program Provided

for Fire Protection System Strainers.

d. Annual Full-Scale Fire Drill With Offsite Fire Fighting Organization

The annual full-scale fire drill was conducted on November 3,1983,

with the site brigade and the Soddy-Daisy Fire Department. A total of

approximately 19 site fire brigade and 15 fire department personnel

participated. The inspector reviewed the drill report and evaluation

and had no further questions.

c. Plant Tour

During the plant tour to review the Appendix R cable interaction

discrepancies, the plant's fire prevention and protection features were

observed. As a whole, the housekeeping and control of combustible and

flammable liquids and gases within the areas toured were satisfactory.

A welding operation was noted in which an approved " hot work" permit

had been issued and appropriate safety precautions were being observed.

The fire protection systems within the areas toured were found to be in

service and appeared to be satisfactorily maintained.

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Within the areas examined, except as noted above, no additional violations

or deviations were identified.