IR 05000424/1988039

Insp Rept 50-424/88-39 on 880829-0902.Violation Noted.Major Areas Inspected:Fire Protection/Prevention & Followup on Previously Identified Insp Items

ML20155E793
Person / Time
Site:	Vogtle
Issue date:	09/26/1988
From:	Conlon T, Ward D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20155E785	List: IR 05000424/1988039 ML20155E781 ML20155E787
References
50-424-88-39, NUDOCS 8810120414
Download: ML20155E793 (14)

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t UNITED STMES j

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.] NUCLEAR REGULATORY COMMISSION REGION ll f

o,g e 101 MArJETTA ST., N.W.

j e,,,,j ATLANTA. OEORQlA 30323 i

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Report No.: 50-424/88-39 Licensee: Georgia Power Company  ;

P. O. Box 4545 f l

Atlanta, GA 30302 i I Docket No.: 50.424 License No.: NPF-68 l

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t Facility Name: Vogtle 1

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Inspection Conducted: August 29 - September 2,1988 l

Inspector: M t'W G D **'L/ 9 F4 Date Signed

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D. C. Ward i Approved by: /g4P / 7 G ?

T. E. CortT6n, Section Chie f'~W~ D&te 5fgned i l Engineering Branch  ;

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Division of Reactor Safety j i  !

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

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Fire Protection / Prevention and follow-up on previously identified  ;

inspection items, i

• s Results: The inspector identified the following strengths in the implementation of the licensee's fire protection program:

- The licensee's training program for the fire brigade leader and f

, fire brigade members appears to be very effective. This is i

evident based on the quality of the fire brigade perfonnance in i j drills witnessed by the inspector during this inspection and in I

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a previous inspection (87-71). I

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- The licensee's management program for ensuring fire brigade members attend the required training and for documenting brigade qualifications appears to be effective. This is evident based [

l on the quality of the fire brigade training records reviewe l i

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- The licensee's management is responsive to NRC initiative ; This is evident based on the licensee's procurement of two f

firefighting foam carts and radios for fire brigade use which  ;

1 were recomendations in a previous inspection repor a t j addition, the licensee actively pursued the resolution ci oil j j previous open items identified in the fire protection are ;

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881012C'414 800930 PDR ADOCK 05000424 l

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The following weakness was identifie The licensee's FSAR action statement for compensatory measures to be taken when fire detection instrumentation becomes inoperable does not appear adequate to implement the defense-in-depth concept outlined in fNREG 0800, Section 9.5-1, "Standard

' Review Plan - Fire Protection Program."

Within the areas inspected, the following violation was identified:

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- Failure to implement Action Statement for Inoperable FSAR Fire Hydran . _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

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REPORT DETAILS

, Persons Contacted

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Licensee Employees

• Burns, Manager, Nuclear Licensing ,

• H. Butterworthy, Supervisor, Operations [

• Cail, Senior Training Specialist

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• Driver, Superintendent Plant Training

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• Frederick, Manager, Site Quality Assurance

• Gabbard, Senior Regulatory Compliance Specialist

• Greene, Manager, Plant Support

• Mosbaugh Assistant Manager, Plant Support

• Nicklin, Supervisor, Regulatory Compliance

• Sprankle, Senior Plant Engineer

• Swart: welder Manager, Regulatory Compliance

• Varnadoe, Supervisor, Plant Engineering Other licensee employees contacted during this inspection included craftsmen, engineers, operators, mechanics, security force members, technicians, and administrative personne NRC Resident inspectors

• Rogge

• Aiello

• Attended exit interview Fire Protection / Prevention Program (64704) Fire Prevention / Administrative Control Procedures The inspector reviewed the following Fire Prevention / Administrative Procedures:

Procedure N Title r,evision 00350-C/Rev. 13 Maintenance Program 92000-C/Rev. 4 Fire Protection Program 92005-C/Rev. 3 Fire Response Procedure 92010-C/Rev. 3 Weekly Fire Inspections 92006-C/Rev. 3 Fire Protection Work Evaluation 92027-C/Rev. 4 Fire Watch Program 92035-C/Rev. 3 Fire Protection Operability Requirements

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Based on this review, it appears that the above procedures meet the NRC guidelines of NUREG-0800. Section 9.5-1, "Standard Rev13w Plan -

Fire Protection Program." and the licensee's commitments ou : lined in the Vogtle Final Safety Analysis Report (VEGP FSAR), exce)t the operability requirements for fire detection instrumentati in in Procedure 92035-C and Section 9.5-1 of the VEGP FSA These operability requirements presently allow up to one half of the Function A, alarm only, detectors to be inoperable without requiring any compensatory measures to be establishe The inspector noted that some detection zones at Vogtle include a large number of detectors (examples are Zones 99 and 46). Detectors in these zones provide coverage to large areas which include a number of small rooms. Under the present operability requirements, it is possible for a number of individual rooms to be without detection and without compensatory measures being implemented. This does not appear to adequately implement the "defense-in-depth" concept outlined in Section 9.5-1 of the Standard Review Pla In addition, the inspector noted that the licensee's operability statement was not consistent with the operability statement for fire detection instrumentation in Revision 5 of the Standard T3chnical Specification Section 3.3.3.8 Action Statement b, of the Standard Technical Specifications requires an hourly fire watch to be established when any two or more adjacent fire detection instruments are inoperabl Based on these concerns, the inspector requested the licensee evaluate the need to add the requirements to establish an hourly fire watch whenever any two or more adjacent detectors are inoperable with respect to their fire detection opecability requirement This is identified as an Inspector Followup Item (IFI) 88-39-01 Evaluate Need To Upgrade The Fire Detection Operability Requirements, Fire Protection Surveillance Procedures The inspector reviewed the following Fire Protection System Surveillance Procedures:

Procedure N Revision Title 92403-C/Rev. 6 Hydrant Hose House Monthly Visual Inspection 92413-C/Rev. 2 Fire Pump Batteries Quarterly Inspection 9?431-C/Rev. 1 Deluge System - Annual Visval Inspection and Cleaning 92433-C/Rev. 3 Fire Hydrant Amnal Flow Check and Hose Hydro Inspection 92443-C/Rev. IT Fire Dampers - 18 Month Visual Inspection

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i 92445-C/Rev. 2 Fire Rated Cable and Conduit Wrap and Radiant Energy Shield Assemblies - 18 Month Visual Inspection

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92499-C/Rev. 3 Fire Suppression System - Weekly (

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Surveillance i r

The above surveillance procedures were reviewed to determine if the  !

various test outiines and inspectior instructions adequately l j

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l implement the survei'ilance requirements of VEGP FSA In addition,

these procedures were reviewed to determine if the inspection and test instructions followed general industry fire protection  :

practices. NRC fire protection program guidelines and the guidelines of the National Fire Protection Association (NFPA) Fire Codes. Based i l

on this review, it appears that the above procedures are (

satisfactor , Fire Protection System Surveillance Inspections and Tests

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The inspector reviewed the following surveillance inspection and test i records for the dates indicated: l

L I procedure N Test Results Reviewed 92403-C 1/07/88, 2/22/88, 3/28/88. 4/26/88, !

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92413-C 8/29/36, 11/17/86, 2/16/87, 6/20/87, j 8/10/87, 11/6/87. 3/1/88, 5/9/88 !

f 92431-C 7/10/87 i i

92433-C 9/22/86, 8/03/87, 8/16/88 i f

92499-C 5/11/88, 5/18/88, 5/25/88, 6/1/88 i 6/8/88, 6/15/88, 6/22/88, 6/29/88 l 7/6/38, 7/13/88, 7/20/88, 7/27/88, 8/3/88 The surveillance test record data and testing frequency associated L with the above fire protection system surveillance test / inspections I were found to be satisfactory with regard to meeting the requirements of the VEGP FSA l In addition, the inspector witnessed the weekly surveillance of the Fire Suppreision System conducted under Procedure 92499- During (

the test, it was noted that a portion of the procedure for testing the electric fire pump could not be run in the step sequence outlined in the procedure. Specifically, for restoring the pump the procedure l instructs the operator to place the pump in "Auto" prior to l l

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realigning system valves. The pressure tap which provides the start signal to the pump controller on low header pressure is on the pump side of the loop isolation valve which is closed during the tes Therefore, whenever the operator attempted to place the pump in

"Auto", the pump would start on low header pressure. The fire protection engineer generated a temporary change to the procedure to instruct the operator to realign the system vdives prict to placing the pump in the "Auto" mode. This will eliminate the problem, The inability to perform the surveillance in the sequence outlined in the procedure had no impact on the acceptability of the test results, d. Fire Prctection Audit The most recent audit reports of the Vogtle Fire Protection Program were revi2we These audits were:

QA Audit of Fire Protection Program, April 7-21, 1988, OP20-88/14 Nuclear Mutual Limited Periodic Inspection January 19-22, 1988 These audits identified several fire protection program discrepancies and unresolved items, and recornended several program improvement The licensee has either implemented the corrective actions associated with these audit findings or a scheduled date for completion of the corrective actions had been established. The licensee appears to be taking the appropriate corrective ections on these audit findings, e. Fire Brigade (1) Organization The total station fire brigade is composed of approximately 120 personnel from the Operations staff. The on duty shift fire brigade leader is one of the licensed operators and the remaining four fire brigade members are composed of plant equipment operators. The inspector reviewed the on duty shif ts for the following dates and verified that suf ficient qualified fire brigade personnel were on duty to meet the provisions of the plant's Technical Specification and VEGP FSA June 1988 July 1988 In addition, the inspector verified that sufficient personnel were assigned to each shif t to meet the minimum operating and fire brigade staff requirements of the Technical Specifications and VEGP FSA Therefore, it appears based on the review of the duty rosters associated with the atsose dates, that there was sufficient manpower on duty to meet both the operational and the fire brigade requirements of the plant's Technical

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Specifications and VEGP FSA One minor clerical error was !

identified during this review in the assignment of fire brigade t

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membars in the Shift Supervisor log for the AM shift June 2 l 198 However, the inspector was able to verify that five

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qualified brigade members were available on shift. This was l l considered an isolated incident and is, therefore, not identified [

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(2) Training  :

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i..e inspector reviewed the training and drill records for six I I brigade leaders and nine brigade members for calendar years 1987 l l and 198 The records reviewed indicated that each of these !

leaders and members had attended the required training and had .

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participated in the required number of drills. The inspector i q

also verified that a fire brigade drill had been conducted every !

three months for each shift for fourth quarter 1987 through !

second quarter 1988. The fire brigade training records which (

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In addition, the inspector reviewed the licensee's new training )

j prog am for fire brigade leiders. The lesson plans for the !

j program have been approved and the Training Department is I

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presently determining how to effectively implement the program, i i The training is presently planned to be made up of an initial

! 14-16 hours of training and followed up by retraining to be I conducted on a two year cycle, i f

The inspector reviewed the following lesson plans: l f'

Lesson Plan Title f;

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FP-LP-01101-00 Introduction and Overview i j FP-LP 01102-00 Fire Team Captain; Functions and (

i Responsibilities  ;

{ FP-LP 01103-00 Fire Ground Comand Systems [

j FP-LP-01104-00 Emergency Scene Sizeup L J FP-LP 01105-00 Manpower and Resource Utilization and i

! Allocation l i FP-LP-01106-00 Fire Scene Safety j j FP-LP-01107-00 Strategy and Tactics i i FP-LP-01108-00 Fire Cause and Determination r i FP-L P-01109-00 Brigade Leader Sinulator Training (

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These lesson plans appeared to be complete and should be very !

I beneficial to the brigade leaders once the training program is :

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(3) Fire Brigade Drill During this inspection, the inspector witnessed an unannounced c fire brigade dril The drill fire scenario was a fire in the Train A Electrical Chase (Room 19) of the Auxiliary Building ,

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which was appar(ntly caused by an intentionally set flammable liquids fire in the roo '

Five fire brigade members responded to the pending fire emergency, The brigade assembled outside the Electrical Chase in full protective firefighting turnout clothing and self  ;

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contained breathing apparatu An initial size-up of the fire condittor, was made by the fire brigade lesder. The leader  ;

determined that the Electrical Chase was inaccessible at that l time to safely initiate manual fire fighting activities within the chas Therefore, the leader initiated fire fighting f activities around the perimeter of the Electrical Chase to prevent the fire from spreading outside the chase until offstte .

assistance arrived. In addition, the brigade leader directed  !

the brigadc to trip the preaction sprinkler systems in adjacent l areas. After approximately twenty minutes, the drill controller i allowed the brigade to simulate entering the electrical chas !

At this time, the brigade leader directed the brigade to enter  :

the room with one 1-1/2 inch fire hose and the fire was placed r under contro The overall perfctmance of the fire brigade was very good. The 7 brigade utilized proper manual firefighting methods and reacted  :

to the drill scenario in an effective and efficient manner. The  !

performance of the fire brigade leader was excellent. The  !

leader performed an effective size-up of the fire and clearly i and consistently directed the brigade in their duties. In l addition, the leader established a comand post near the fire i area and maintained constant and effective comunications with  !

the control room, and brigade member [

f. Plant Tour and Inspection of Fire Protection Equipment ,

(1) Outside Fire Protection Walkdown The incpector verified that the two water storage tanks [

contained sufficient water to meet the requirements of the VEGP FSA The three fire pumps were inspected and found to be in service. The diesel fuel tanks for the diesel driven fire pumps were above the minimum fill line established to satisfy the requirements of the VEGP FSA The ?ollowing sectional control valves in the outside fire protection water supply system were inspected and verified to be properly aligned and locked in position:

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Valve No./ Position Description l l  !

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! T02/Open Diesel Fire Pump #1 Suction j i T03/Open Diesel Fire Pump !2 Suction t 2 T04/Open Electric Fire Pump Suction I Oll/Open Electric Fire Pump Discharge l 014/Opan Olesel Fire Pump #2 Discharge l 026/Open Diesel Fire Pump #1 Discharge !

i The following fire hydrants and fire hydrant equipment houses ;

were inspected:  ;

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C-2301-U4-941 SSE of NSCW Tower A :

C-2301-U4 943 ESE of NSCW Tower A l

! C-2301-U4-946 SE of DG Building i j C-2301-U4 394 SW of NSCW Tower B During the fire hydrant inspection, the inspector noted that I loop isointion Valve 639 was closed and as a result it appeared t j Hydrant C-2301-U4-994 was isolated from the VEGP FSAR water [

! supply. This fact was confinned through discussions with the ,

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Vogtle Fire Protection Engineer (FPE) and site engineers j j involved in the flushing of Unit 2 fire protection systems, t I Hydrant C-2301-U4-994 is isolated from the VEGP FSAR water I

supply on a daily basis to facilitate the Unit 2 flushing. The i

isolation is implemented by closing three loop isolation valves,

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639, 650, and 791.

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l Hydrant C-2301-U4-994 is one of four hydrants the licensee [

requires in Section 9.5-1, Table 9.5.1-10 of the VEGP FSAR to be >

l maintained operable or to implement compensatory meesures when l the hydrant is inoperabl Contrary to this requirement, i Hydrant C-2301-U4-994 was found inoperable, isolated from the [

j VEGP FSAR water supply, without the compensatory measures .

outlined in Action Statement 6.3 of Table 9.5.1-10 being  !

l implemented. This item is identified as a Violation (88-39 02), !

q Failure to implement Action Statement for inoperable FSAR Fire Hydrant.

In response to this finding, the licensee imediately f

4 implemented the requirements of Action Statement 6.3 by placing additional fire hose at Hydrant Hose Fcuse C-2301-04-941 within l one hour of the inspectors finding. Full compliance with the VEGP l i

l FSAR was achieved at this time. In addition, the licensee's FPE [

j had detailed discussions with the site engineers conducting the !

! Unit 2 flushing to ensure that similar problems would not occur, i

The inspector noted that the licensee's failure to implecent the '

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Action Statement was of minor safety significance since Hydrant l

C-2301-04-994 protects the yard area around the "B" Nuclear j Service Cooling Water Towe If a fire had occurred the fire ,

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j brigade could easily have used additional hose to reach the area i from an operable hydrant with only minimal delay. Based on j licensee's imediate corrective actions, actions taken to pervent r

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similar violations ard the minor safety significance, of the l 1 deficiency, no violaticn is been site ;

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The equipment houses contained the minimum equipment requirement  !

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of that specified by NFPA-24, Private Fire Service Mains and i i Their Appurtenances, and/or the F5tR coe.mitment Thu equipment i

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appeared to be adequately neintaine ;

4 A tour of the exterior of the plant indicated that sufficient i clearance was provided between permanent safety-related l j buildings and structures and temporary butidings, trailers, and l l other transient combustible materials. The general housakteping r

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of the areas adjacent to the permanent plant structures was

satisfactory.

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(2) Pennanent Plant Fire Protection Features l A plant tour was made by the inspecto During tne plant tour, 4 the following safe shutdown related plant areas and their l

related fire protection features were inspected:  !

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i Aurillary Feedwater Pump House f

Diesel Generator Building l

i The fire / smoke detection systems, manual fire fighting emipment i (i.e., portable extinguishers, hose stations, etc.) a..a the fire  !

i area boundary walls, floors and ceiling associated with the I above plant areas were inspected and verified to be in service  !

or functional.

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j The automatic sprinkler systems installed for protection of the >

ll Train C Auxiliary feedwater Pump Room (053), the Train A Diesel (

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Generator Room (032) and the Train B Diesel Generator Room i i (031),and the Halon system protecting the Train B Remote  !

j Shutdown Panel Room were inspected and found to be in service.

Based on this inspection, it appears that the fire protection i

features associated with the above plant areas are i

satisfactorily maintaine ;

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1 The plant tour also verified the licenseo's implementation of t I the fire prevention ad:ninistrative procedures. The control of J combustibles and flarmable m:terials, liquids and gases, and the i general housekeeping were found to be satisfactory in the areas inspecte !

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Building. An approved "Hot Work" permit had been issued for i each of the welding o,)erations and the work practices met the  ;

i licensee's fire prevention control procedure i During the plant tour, the inspector's escort from the Fire l i Protection Group noted that a fire alam in t.evel 1 of the [

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Control Building had come in on the Control Room fire protection 3 computer. The inspector and his escort investigated the alarm  :

and found that 4 falso alarm had occurred. Through discussions l

with crafts personnel working in the area, it was determined that  !

, the craft working under Maintenance Work Order (MWO) 28808587 l

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had wired Unit I detector 1$34-119-6 into the detection zone i

! which was in false alarm. As a direct result of this w rk the i detection system went into alarn and could not be reset. A t review of the MWO found that Item A on the MWO Continuation i Sheet specifically stated that Unit 1 equipment, or systems were

not to be touched, altered or modifie The foreman in charge i acknowledged that the wiring of the detector was clearly out of the scope of the MWO.

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Technical Specification 6.7.1 requires written procedures to be

! implemented covering activities as recomended in Appendix A of t

Regulatory Guide 1.33 Revision 2 February 198 This Regulatory Guide recomends procedures be developed which govern plant maintenanc Plant Procedure 003RO-C. Maintenance Program, implements this Technical Specification and requires l work to b limited to the scope outlined in the MWO or the MWO

) must be revised. Therefore, the crafts failure to limit work to l the scope of the MWO represents a violation of Procedure 00350-C

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and plant Technical Specification 6.7.1.

1 The licensee imediately implemented corrective action of placing a stop work order on the MWO and implementing I compensatory measure for the inoperable detection zon Deficiency Card (DC) 1-88-2462 was issued by the licensee to

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document the violation and the review of the DC will include a i root cause evaluation of the violation, a

i In light of the above, this violation was discussed with the resident inspector and Regional personnel and since all the requirements for a licensee identified violation specified in 10 CFR Part 2. Appendir C.Section V, were satisfied, this

} violation is not cited.

! (3) Appendix R Fire Protection Fea wres I

J The inspector visually inspectod the following fire rated j raceway fire barriers required for compliance with NUREG 0800

Section 9.5-1, Position C5.5.2

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Raceway Building / Room 1BE311RS123 Control /842&B50 IBE311R$124 Control /8428t350 IBE311RR314 Control /B42 IBE311RS130 Control /B42 1BE311RS149 Control /B42 1BE311RS184 Control /B42 1BE321RS172 Control /B42 18E311'dX217 Control /842 1CE33rRX167 Control /862 1AE321RX324 Control /877 1AE321RX325 Control /B77 Based on the inspector's observations of the above raceway fire barrier enclosures, it appears that the three hour fire barrier integrity associated with the aoove fire barrier assemblies was being properly maintained in a satisfactory conditio The inspector made a walkdown of the sprinkler protection provided in the following plant areas to meet the guidelines NUREG 0800, Section 9.5-1:

System N Area Protected 059 Level A&B Control Building 062 Level B Control Building 068 Level A Control Building Based on this walkdown the inspector determined that the sprinkler protection provided for the areas identified above provided sufficient protection witil respect to controlling in expusure fir The following eight-hour emrgency lighting units were inspected:

Unit N Location 47-6-4 Train C Auxiliary feedwater 50-6-3 Train C Auxiliary Feedwater 47-4-5 Train B Diesel Generator 47-4-6 Train B Diesel Generator 32-1 1 Train B Remote Shutdown Panel 32-1-2 Train B Remote Shutdown Panel 28-1-3 Train A Remote Shutdown Pariel 29-1-4 Train A Remote Shutdown Panel TNse units were in service, lamps properly aligned and appeared to be properly maintaine _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

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i Except as noted above, within the areas inspected, no additional  !

violations or deviations were identifie l L Action On Previous inspection Findings (92701 and 92702) ,

r (Closad) IF! 424/87 02 01, Fire Brigade And Other Operational l Employees Are Not Respirator Qualifie This item was identified in ;

an inspection report p. ior to Unit 1 comercial operation when not  !

all fire brigade and other operation personnel had completed

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l respirator trainin r l The inspuctor verified that 15 fire brigade / operations personnel had  ;

received respirator /SCBA training and that retraining was conducted annuall !

t (Closed) IF! 424/87-71-01, 18 Honth Fire Pump Surveillance Does Not i include Recording Driver Speed As Required By NFPA 20. The inspector i

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verified that Revision 3 of procedure 92437-C issued on February 15, l 1988 included recording driver spee : (Closed) Violation 424/87-71 02, Failure To Droperly Document On ,

Shif t Plant Operations and Fire Brigade Assignments. The inspector reviewed the Shift Supervisor's Log entries for the months of June ,

I and July 1988 and verified that operations and fire brigade l l assignments were being properly documente With the exception of one minor clerical error, the log was found complete and accurate,

, (Closed) Violation 424/87-71 03. Failure To Maintain A Fully }

Qualified Five-Man Fire Brigade Onsite At All Time This violation f

' was a result of the licensee's failure te ;r.&c. the fire brigade {

l exclusive of the minimum technical specification operating staff as i required by VEGP FSAR Section 9.5.1. In a subsequent inspection !

the licensee demonstrated that facility shutdown could be carrieo out  !

with a minimum of three operator Therefore, VEGP FSAR ,

t Section 9.5.1.5.3 was revised under LCDR FS-88-055 to state that the fire brigade shall be manned exclusive of the three man shutdown i crew. This requirement has also been included in Procedure 10303-C, (;

Manning the Shif t, which states the 0505, R0 and BOP cannot serve fire brigade dut l I

The inspector verified that for the months uf June and July 1988 a l five man qualified fire brigade had been assigned exclusive of the >

three man shutdown crew in the Shift Supervisors Log. With the  !

exception of one minor clerical error, the log entries were found to {

meet the procedural requirement ,

4 Exit Interview The inspection scope and results were sumarized on September 2,1988, l with those persons indicated in Paragraph 1. The inspector described the ,

areas inspected and discussed in detail the inspection results If sted j i

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belo Proprietary information is not contained in this report.

,' Dissenting comments were not received from the license Item Number Description and Reference l 424/88-39-01 IFI - Evaluate Need To Upgrade t.S Fire i Detection Operability Requirement Par 4 graph 2a.

l 424/88-39 02 Violation - Failure To implement Action

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Statement For Inoperable FSAR Fire Hydrant, i Paragraph 2.f.(1).

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