IR 05000277/1988041

Insp Repts 50-277/88-41 & 50-278/88-41 on 881003-07.No Violations Noted.Major Areas Inspected:Fire Protection/ Prevention Program

ML20206M015
Person / Time
Site:	Peach Bottom
Issue date:	11/08/1988
From:	Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206M013	List: IR 05000277/1988041 ML20206M008
References
50-277-88-41, 50-278-88-41, CAL, NUDOCS 8811300346
Download: ML20206M015 (8)

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U.S. NUCLEAR REGULATORY COMMISSION RFGION I Report No /88-41 50-278/88-41 Docket N SC-277 50-278 OPR-44 License Nos. OPR-56 Category C Licensee: Philadelphia Electric Company '

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P. O. Box 7520 *

Philadelphia, Pennsylvania 19101

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Facility Name: Peach Bottom Units 2 and 3 Inspection At: Delta, Pennsylvania Inspection Conducted: October 3 - 7, 1988 Inspectors: '

A. hmpoM s It f I ,

A. Krasopo';'os, Reac' tor Engineer date Plant System Section, EB, DRS i Approved by: bf CT~JTVAnderson,Ch!ef u/r!U date Plant Systems Section, EB, DRS  ;

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Inspection Summary: Inspection __on October 3-7, 1988 (Combined Report N ~

50-2717278/88-41)

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Areas Inspected: Routine unannounced inspection of the fire protection /

prevention program that included t, review of the corrective actions taken in response to two violations in the fire protection area and a review of the .

actions taken to resolve other related concern l The inspection also included plant tours and a review of the Quality Assurance -

Audits and surveillances performed to satisfy Technical Specification requirement i r

_Results: Of the areas inspected no violations were identifie I L

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GS117,CM)346 83111 * -

PDR ADOCK 05CH)0277 *

O PDC

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DETAILS 1.0 Persons Contacted 1.1 Philadelphia Electric Co. (PECo)  !

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D. M. Smith, Vice President, Peach Bottom J, B. Cotton, Superintendent Operation '-

L. Fulton, Fire Protection Manager G. Hanson, Regulatory Engineer G. J. Hewen, Regulatory Engineer T. E. Cribbe, Regulatory Engineer ,

J. M. Pratt, Quality Assurance '

K. M. Bunnenbohn, Engineering i

C. Bruce, Fire Protection Engineer W. Eclunar, Nuclear Qaality Assurance  !

S. Yvill, Fire Protection Coordinator

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G. Lenayel, Maintenance Support Engineer t G. Daebeler, Technical Superintendent l J. Davenport, Engineer ,

W. Birely, Licensing j 0. Spammer, Electrical Engineer  ;

i 1.2 NuclearRegulatoryCommission(NRCl l f

T. Johnson, Sr. Resident Inspector i L. Myers, Resident Inspector t R. Urban, Resident Inspector f I

• Denotes those present at the exit meeting, t 2.0 Followup __of Previous Inspection Findings t

(Closed)_ Violation (50-277/87-11-01 and 50-278/87-11-01) 10 CFR 50 l h pendix R violation, failure to maintain at least one safe shutdown I train free from fire damag !

Backgroun_d The Nuclear Regulatory Commission (NRC) during March 17-21, 1986 [

performed an inspection to assess the licensee's safe shutdown capability I required by 10 CFR 50, Appendix As a result of this inspection, the [

NRC, on April 11, 1935, issued a Confirmatory Action Letter requesting J that the licensee complete the Appendix R safe shutdown confirmatory i program and inform the NRC Region I of any violations of Appendix R j requirements. The licensee, by letters dated May 22, 1986, September 17, .

1936 and October 31, 1986, informed the NRC that in at least 51 instances, i the requirements of 10 CFR 50 Apper. dix R,Section III, G were not satisfie l t

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Subsequently, the licensee on November 28, 1986 issued a Justification for !

Continued Operation (JCO) addressing the Appendix R non-conformances and describing their compensatory measures and planned corrective action The NRC reviewed the JC0 and concurred with the licensee that continued a operation with the compensatory measures described in the JC0 was accept- :

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! The NRC on April 9,1987 performed an inspection to review the licensee

! identified non-conformances. The NRC after reviewing the circumstances a

and causes for the non-conformances determined that a Notice of Violation and proposed imposition of civil penalty was warranted. The licensee committed to initiate and complete all required modifications to assure compliance with the requirements prior to restart of each uni Scope of inspection

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This inspection was conducted to verify that the corrective actions taken by the licensee to correct the Appendix R non-conformances are adequate and satisfy the commitments made in the J.C.0.

Methodology and inspection results

!l i The inspector reviewed three modification packages to verify that the

! design, installation and testing of the proposed modifications is thorough.

;omplete and performed under the proper Quality Assurance supervision.

l The modification packages reviewed were Nos. 13510, 2030 and 208 I 1 Modification 13510 corrects the deficiency regarding the possible loss of j the Emergency Service Water from blown control power fuses. This deficiency

is described in the JC0 paragraphs, I.B.1 and 1.B.2. The deficient condition

is that a fire in any of several plant areas had the potential of damaging i the ESW system. Modification 2080 corrects the condition when the ability 1 to isolate the HPCI system is lost if a design basis fire occurs in fire

area 13N. This concern was identified in paragraph I.C.1 of the JCO.

i Modification 2084 corrects the deficiency identified in paragraph II.A.2

of the JCO. This modification provides for the protection of the minim flow for the Reactor Heat Removal (RHR) System.

The inspector reviewed the drawings, specifications, testing procedures safety evaluations, and Engineering Work Letters, to assure that the i implemented modifications adequately address the JC0 concerns. The inspector 4 also reviewed the installation of the components described in the modifica-

! tion packages and reviewed the changes in tbc shutdown procedures resulting j from the modifications. During a ,alk-down the inspector observed that

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one of the stop watches that is needed to time the RHR LpCI injection valve,

>troke time was not working. Timing of the valve strcke time is required j by the shutdown procedure, The licensee explained and the inspector veri-i fied that a routine surdillsnee conducted on September 21, 1958, by the i

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licensee idcatified the same problem. The licensee committed to purchase and maintain a more reliable stop w uch in the safe shutdown cabinet, i

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-4-The inspector, in addition to reviewing the modification packages described above, performed an inspection at the engineering off1 cts of the license During this inspection the inspector reviewed the engineering work performed to address the JC0 items I.A.1, I.A.2 and I.A.3. These J. concerns are being resolved by the work associated with modification packages 2085, and 207 JC0 item 1.A.1 concerned the loss of instrumentation required to monitor process variables for a fire in fire area 13N. Modification package 20S5 along with a revision of procedure T-313 Revision I, Fire Guide, addressed j this concern by protecting the instrumentation required for shutdown.

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1 JC0 items I.A.2 and I.A.3 relate to a potential problem resulting from a design basis fire in fire area 2 which would cause the loss of the Emergency Diesel Loss of Emergency power concurrent with a loss of off-site power will result in the loss of: inventory control, dacay heat removal capabi-lity and the monitoring of process variables that are required for shutdow Modification package 2078 provides for protection of the Emergency Diesels

, that could be lost as a result of a fire in this area Suyna ry 3 The inspector perforned a review of three modifications that were made to

correct non-conforming conditions with 10 CFR 50 Appendix R requirements.

a The inspector also reviewed the licensee's actions to address and correct

the items identified in the JC This review determined that the licensee has established a program to address the JC0 concerns. The review of the modifications, and associated engineering work did not identify any unacceptable conditions.

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This violation is closed.

(Closed) Violation (50-277/278/87-30-01) Inadequate Fire Brigade Trar.ing e

) The NRC identified the concern that not all Fire Brigade members participate in all required fire brigado training. A review of the training records and an observation of a fire drill determined that currently the licensee has a program and procedures that include: Requirements for announced and unannounced drills; Requirements for fire brigade training and retraining at prescribed frequencies; Requirements for at least one drill per year to be performed on a

"back shi f t" fo. each brigade; Requirements for maintenance of training record ,, .

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j The training records review determined that for calendar year 1988 the j fire fighters had attended the required quarterly training, participated a

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in a quarterly drill, and received the annual hands-on fire extinguishment practice.

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No unacceptable conditions were identifie ; This item is closed

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In order to evaluate the brigade training, the inspector requested that a l fire drill be performed. The inspector along with the fire brigade trainer

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went to the Control Room to request permission to conduct the drill. The inspector noticed that the Control Room door was not closed. The inspector

, clon d the door and immediately notified the shift manager. Security was 1 notified and a search for unauthorized persons and articles in the Control i

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Room was conducted by the licensee. The li:ensee explained to the inspector

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that because of air pressure differential the door does not always clos However, after staying ajar sixty seconds the open door alarms security.

A review of the Control Room entry and exit logs established that the door

! was open less than sixty seconds. Subsequent to this event, the Control

! Room gave permission to conduct the drill. However, the drill requested L by the inspector did not take place. The fire brigade trainer pulled the

] designated fire alarm but the Control Room did not acknowledge receipt of

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the alarm. Therefore the brigade was not mobilized.

The reason given was that at the same time that the alarm was pulled the licensee was conducting alarm tests elsewhere in the plant. These activities l were not coordinated properly resulting in 1.he confusion. As a -esult, a there was no response to a valid alarm. Had this been a real fire, valuable i time would have been lost prior to the fire brigade response, To prevent reoccurrence of this proolem, the licensee will modify the Fire

panel in the control room to have the capability to provide a hard copy l and a digital readout of each alarm received. In addition, the alarm i testing procedures and the fire alarm repo. ting procedures will be revised.

] Furthermore, the General Employee training wfil be improved in this are I j- The drill with a different scenario was rescheduled, and conducted. The

inspector observed the drill and did not identify any unacceptable i conditions.

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(C hsc A Unresolved Item (50-277/87-30-02 and 50-278/87-30-02) Hot

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l hutdown Repairs /Fus, Ry lacement j The NRC reviened the licensee's safe shutdown procedure and determined l that the procedure can be easily implemented. Fuse replacement by the j cperators, during hot shutdown, can be readily accomplished with the tools provided.

I This item is closed.

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. (Closed) Unresolved Item (50-277/84-40-01 and 50-278/84-19-01) Functional Test of Tire Dampers The NRC identified the concern that fire dampers need to be functionally tested periodically to verify their proper functio The licensee agreed with this concern and committed to functionally test 10'.' of all dampers each year. A small number of dampers that are inaccessible will not be tested. However, they will be visually inspected as required by the T.S. These actions resolve this concer In addition t:, the above commitment to sample test, the fire dampers annually, the lice.isee assured the operability of the Fire dampers by reviewing damper installation and acceptance test data. Where this information was unavaflable, the licensee drop tested the dampers. Thirty-eight out of 105 dampers were tested by the above metho The remainder were evaluated for operability using either empirical or analytical dat As a result of this review, the licensee determined that some dampers need to be modified by installing additional springs. The springs assure that the dampers close under air flow. For dampers, that can not be modified and can not close under air flow conditions, the licensee has in place procedures to shutdown the associated air fans. This will be done upon verification of a fire in the zone where these dampers are installed. The inspector did not identify any problem with this approach to functionally test fire damper The inspector in reviewing the licensee's approach to resolve the fire damper test deficiency, identified that two dampers required to be visually inspected by the Technical Specifications (TS) were not included in the surveillance procedure. A preliminary review of this finding by the licensee determined that additional dampers requiring visual surveillance by the fS were not included in the procedure The NRC considers this item to be unresolved pending a review of the license evaluation of this concern. (50-272/88-41-01 and 50-2'8/88-41-01)

3.0 Fire Protection / Prevention program The insp'ctor reviewed several documents in the following areas of the program to verify that the licensee had developed and implemented adequate procedures consistent with the Fire Hazard Analysis (FHA), Final Safety Analysis Report (FSAR), and Ter.hnical Specifications (TS). The documents reviewed, the scope of revier, and the inspection findings for each area of the program are described in the following section _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ ___ _ - _ _ _ -. =__ _ __ __ ._.__ __. _ __. _ . .

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-7-3.1 Equipment Maintenance. Inspection and Tests

The inspector reviewed the following documents to determine whether the

, licensee had developed adequate procedures which established maintenance, inspection, and testing requirements for the plant fire protection equipment:

- RT 1.6.3, Emergency Fire Cabinet and Fire Cart Supply, Alternative

, shutdown tool box supply and control room fire ladder check, Revision 8

- ST 16.12, Underground fire main flow test, Revision 2

- ST 16.8A, El Diesel Generator cardox system simulated activation

and air flow test, Revision 4

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- ST 16.20, Battery Room Ventilation air flow detector functional Revision 2

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- ST 16.20-A, Visual inspection of SBST "A" train deluge sys'.em nozzles and piping, Revision 5

! - ST 16.7.2, Visual inspection of encapsulated electrical raceways,

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Revision 1

! - ST 16.7.18-3, Visual walk around inspection of Fire Barriers, Revision 0

- ST 16.38, Operability test of the linear heat detection system above the control room, Revision 2

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- ST 16.28, Surveillance test for non technical specification testing Revision 2

! - ST 16.36, Functional test of water deluge sprinkler system supervisory circuit, Revision 0

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j - ST 16.7.1B Visual walk around inspection and Fire Barriers, Ravision 0 i

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- ST 16.7.1A, Detailed visual inspection of Penetration Seals, Revision 0

- ST 16.7.1C-2, Detailed visual inspection of Penetration Seals, Revision 0 In addition to reviewing the above documents, the inspector reviewed the maintenance, inspectirn and test records for the items, to verify compliance with Technical Specifications ai.d estanlished procedures No unacceptable conditions were identifie w

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. .2 Periodic Inspections and Annual Audit Quality Assurance Audit The inspector reviewed the report of the following annual audit:

AP87-177PL The scope of review was to ascertain that the audit was conducted in accordar.ce with the Technical Specifications and that the audit findings were being resolved in a timely and satisfactory manne No unacceptable conditions were identifie .3 Facility Tour The inspector examined fire protection water systems, including fire pumps, fire water piping and distribution systems, post indicator valves, hydrants and contents of hose house The inspector toured accessible vital and nonvital plant areas and examined fire detection and alarm systems, automatic and manual fixed suppression systems, interior hose stations, fire barrier penetration seals, and fire door The inspector observed general plant housekeeping conditions 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 performe No unacceptable conditions were identifie .0 Unresolved Items Unresolved items are matters about which more information is required to ascertain whether they are acceptable items, violations or deviation One unresolved item disclosed during the inspection is discussed in Section .0 Exit Interview The inspector met with licensee management representatives (see Section 1.0 for attendees) at the conclusion of the inspection on October 3, 1983. 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 informatio The licensee agree that the inspection report maybe placed in the Public Document Room without prior licensee review for proprietary infortnatio (10 CFR 2.790).

At no time during this inspection was written material provided to the licensee by the inspector.