IR 05000416/1986024

Insp Rept 50-416/86-24 on 860811-15.Violation Noted:Failure to Rept Inoperative Fire Hydrants & Inadequate Fire Watch Program

ML20214U684
Person / Time
Site:	Grand Gulf
Issue date:	09/09/1986
From:	Conlon T, Miller W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214U655	List: IR 05000416/1986024 ML20214U652 ML20214U673
References
50-416-86-24, NUDOCS 8610010376
Download: ML20214U684 (11)

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REGION 11 g ,j 101 MARIETTA STREET, *

2 ATLANTA, GEORGI A 30323

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Report No.: 50-416/86-24 Licensee: Mississippi-Power and Light Company Jackson, MS 39205 Docket No.: 50-416 License No.: NPF-29 Facility Name: Grand Gulf Inspection Conducted: August 11-15, Inspector: -

[ f 8- 86 W. H. Millfr Date Signed Approved by:Nv [/ M ff3 8 9- fg6 T. E. Conlon,'Chie'f, fhtht Systems Section Date Signed Engineering Branch Division of Reactor Safety SUMMARY Scope: This . routine, announced inspection was conducted in the areas of fire protection / prevention and followup on previously identified inspection item Results: Two violations were identified - Failure to Report Inoperative Fire Hydrants - paragraph 5.c(5); and, Inadequate Fire Watch Program - paragraph No deviations were identifie .

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REPORT DETAILS Persons Contacted Licensee Employees

• J. D. Bailey, Compliance Coordinator

• T. E. Barnett, Nuclear Plant Engineering (NPE)-Electrical

• W. Brown, Assistant Fire Protection Coordinator

• L. F. Daughtery, Compliance Superintendent

• G. A. Ellis, Security Superintendent

• J. O. Fowler, Nuclear Licensing

• B. Hicks, Assistant Fire Protection Coordinator

• V. Holmberg, Fire Protection Coordinator S. Hutchins, NPE-Frinciple Electrical Engineer

• B. C. Lee, Quality Assurance Audits Supervisor

• L. B. Moulder, Operations Superintendent

• A. McCurdy, Manager, Operations

• L. A. Patterson, NPE-Mechanical

• W. A. Russell, Operations D. Wiles, NPE-Electrical

• M. J. Wright, Manager, Plant Support Other licensee employees contacted included engineers, technicians, operators, mechanics, security force members and office personne Other Organizations

• R. Cumbest, Middle South Services - Fire Protection Supervisor NRC Resident Inspector R. Butcher

• Attended exit interview Exit Interview The inspection scope and findings were sumarized on August 15, 1986, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting coments were received from the license Violation (416/86-24-01), Failure to Report Inoperative Fire Hydrant -

paragraph 5.c(5). Violation (416/86-24-02), Inadequate Fire Watch Program - paragraph __ _ _ _ . _ _ - _ - _ _ . _ _.___ _

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2 Inspector Followup Item (416/86-24-03)* Installation of Additional Fire Detectors - paragraph The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters (0 pen) Unresolved Item (416/85-16-01), Structural Steel Supports for Cable Raceway Fire Barriers are not Provided with a Fire Resistant Rating Equivalent to the Rating of the Barrie This item is being reviewed by NRR and will remain open pending completion of this evaluatio (0 pen) Unresolved Item (416/85-16-03), Licensee's Unreviewed Fire Protection Program. The licensee's 1984-1985 reanalysis for meeting the safe shutdown and fire protection requirements of 10 CFR 50.48 and 10 CFR 50, Appendix R is being evaluated by NRR. This reanalysis identified a number of items which did not conform to the provision of Appendix Justifications for a number of items not meeting the literal provisions of Appendix R were sent to the NRC for review by

!!P&L letters, dated May 7 and 18, -June 14 and 18,1985, and July 24, 1986. NRR is to review and issue a Safety Evaluation Report (SER) on the justifications to these Appendix R exceptions by early 198 Plant modifications are being performed on the remaining items to bring the plant into compliance with the Appendix R requirements. A total of 21 Design Change Packages (DCP) were prepared to accomplish the required modification work. Construction work on four DCPs is complet Two DCPs were determined not to be required and the DCPs have been cancelled. Work is in process on the remaining 15 DCPs. A significant portion of the work for these modifications involved cable raceway fire barrier enclosures. The licensee estimates that this work is approxi-mately 75% complete and that most of the work will be completed by December 1986. All modifications are scheduled to be completed by the second quarter of 1987. Upon issuance of the SER by NRR and completion of the modifications, NRC Region II will perform a reinspection of Grand Gulf to verify compliance to Appendix This item remains ope (0 pen) Violation (416/84-45-02), Inadequate Fire Brigade Trainin Procedure 10-S-03-7, Fire Protection Training Program, has been issued to define and implement the fire brigade training program. Two assistant fire protection coordinators have been added to the plant staff. A program for tracking the fire brigade member's qualifications was implemented by February 10, 198 However, a new tracking system for qualified emergency worker and fire brigade members was initiated in March 1986 at which time Radwaste Operations personnel were added to the brigade roste The new or current tracking program does not include a review of quarterly classroom training and fire brigade drill s. To further complicate the training and drill schedule, the

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Operations group has six shifts and the Radwaste group has five shift As a result, the training for a number of Radwaste personnel is defi-cient, but these personnel are included on the list of qualified personnel for emergency worker and fire brigade duties. The licensee is to review and revise the existing tracking program as needed to assure that only qualified personnel are included on the qualified emergency worker and fire brigade list. Therefore, this item remains ope (Closed) Unresolved Item (416/84-45-03), Inadequate Plant Training For Off-site Fire Department Personnel. On September 9,1985, the Claiborne County Fire Department, including the fire chief and two on duty fire fighters, responded to a plant fire drill and training exercis The adequacy of the training of the off-site fire depart-nents is outside the scope of the NRC Region II fire protection program review and, this item is close . Unresolved Items Unresolved items-were not identified during the inspectio . Fire Protection Prevention Program (64704) Fire Prevention / Administrative Control Procedures The inspector reviewed the following Fire Prevention / Administrative Procedures:

Procedure N Title 10-S-03-1 Fire Protection System Impairment (Rev. 6)

10-S-03-2 Response to Fires (Rev. 8)

10-S-03-3 Fire Prevention: Control of Ignition Sources (Rev. 5)

10-S-03-4 Fire Prevention: Control of Combustible fiaterials (Rev. 5)

10-S-03-7 Fire Protection Training Program (Rev. 2)

Based on this review, it appears that the above procedures meet the NRC Guidelines of 10 CFR 50 Appendix R - Fire Protection Programs for Nuclear Power Facilities, NUREG-0800, Section 9.5.1, " Standard Review Plan - Fire Protection Program", or the licensee's commitments in the letters to the NRC, dated July 22, 1985 and January 27, 198 Fire Protection Surveillance Procedures The inspector reviewed the following Fire Protection System Surveillance Procedures:

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Procedure N Title 06-0P-SP64-A-0004 Fire Protection System Valve Stroke Test 06-0P-SP64-A-0005 Diesel Driven Fire Pump A Functional Test 06-0P-SP64-A-0006 Diesel Driven Fire Pump B Functional Test 06-0P-SP64-A-0007 Motor Driven Fire Pump Functional Test 06-0P-SP64-M-0011 Fire Protection System Valve Lineup Verification 06-0P-SP64-R-0002 10 Ton Co2 System Puff Test 05-0P-SP64-SA-0018 Fire Protection System Post Indicator Valve Stroke Time The above surveillance procedures were reviewed to determine if the-various test outlines and inspection instructions adequately implement the -surveillance requirements of the plant's Fire Protection Technical Specifications. In addition, these procedures were reviewed to deter-mine 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 on this review, it appears that the above procedures are satisfactory, c. Fire Protection System Surveillance Inspections and Tests The inspector reviewed the following surveillance inspection and test records for the dates indicated:

(1) Fire Protection System Valve Stroke Test, 06-0P-SP64-A-0004 Annual tests conducted between August 21, 1983 and September 10, 198 (2) Diesel Driven Fire Pump A Functional Test, 06-0P-SP64-A-0005

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Annual tests conducted between July 8, 1983 and August 28, 198 (3) Diesel Driven Fire Pump B Functional Test, 06-0P-SP64-A-0006

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Annual tests conducted between. July 9, 1983 and August 31, 198 (4) Motor Driven Fire Pump Functional Test, 06-0P-SP64-A-0007 Annual tests conducted between June 15, 1983 and August 28, 1985

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(5) Fire Protection System Valve Lineup Verification, 06-0P-SP64-M-0011 Monthly surveillance conducted between November 22,1985 and June 27, 1986. Records for April 28 and May 29, 1985 surveillance were not reviewed since this data was not yet on fil The surveillance of December 26, 1985, found valve F053 closed. This closed valve resulted in fire hydrant No. D024 being inoperative since no water was available to the hydran Incident report No. 85-12-11 reviewed this discrepancy and found that the system met the provisions of Technical Specification 3.7.6.1, Fire Suppression Water System, with the valve closed and thus, this discrepancy was not reported to the NRC. However, the licensee apparently failed to consider Technical Specification 3.7.6.6, Yard Fire Hydrants and Hydrant Hose Houses, which required this hydrant to be in servic The failure to report this licensee identified item is identified as Violation (416/86-24-01), Failure to Report Inoperative Fire Hydran (6) 10 Ton CO 2System Puff Test, 06-0P-SP64-R-0002 Surveillance conducted June 17, 198 (7) Fire Protection System Post Indicator Valve Stroke Time, 06-0P-SP64-SA-0018 Semiannual surveillance conducted February 9,1985 to February 27, 198 The surveillance test record date and testing frequency associated with the above fire protection system surveillance tests / inspections were found to be satisfactory with regard to meeting the requirements of the plant's Fire Protection Technical Specifications except as noted abov d. Fire Protection Audit The most recent audit reports of the fire protection program were reviewed. These audits were:

(1) Triennial Fire Protection Audit - APO-84/0700 of September 14, 198 (2) Annual and 24 Month Fire Protection Audit - MFPP-8G-01 of March 3-14, 1986.

l These audits identified several fire protection program discrep.ancies

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and unresolved items, and recommended several program improvement The licensee has either implemented the corrective actions associated with these audit findings or a scheduled date for completion of the correction - lons had been established. The licensee appears to be taking the appropriate corrective actions on these audit finding Refer to paragraph 7.d for information on the fire detection syste . -- .-_. - _ __ -

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e. Fire Brigada (1) Orgar;ization The f tre brigade is composed .of approximately 85 personnel from the operations staf The brigade leader is normally one of the licensed nuclear operators and the remaining fire brigade nembers are composed of unlicensed nuclear operators or radwaste personne The inspector reviewed the " List of Qualified Personnel for Emergency Worker and Fire Brigade through 11-08-86" and verified that sufficient qualified fire brigade personnel were assigned to each shift to meet the provisions of Technical Specification 6.2.2. However, the training for the radwaste personnel assigned to the fire brigade was not up to dat Refer to paragraph for detail (2) Training The inspector reviewed the training and drill records for three brigade leaders and eight brigade members for 1985 and the first two quarters of 1986. These records indicated that each leader and member had received an annual medical review, attended the required training and participated in the required number of drills, except the training and drill attendance for a number of radwaste personnel was deficien Refer to paragraph for detail The inspector also verified that a fire brigade drill had been conducted each quarter of 1985 and for the first and second quarters of 1986 for each shift. The fire brigade training records which were inspected were found satisfactory, except as note (3) Fire Brigade Equipment The inspector performed an inspection of the fire brigade equip-ment, consisting of fire hose, nozzles, tools, and miscellaneous equipment stored at the fire brigade equipment response locations located on 113', 133' and 166' elevation of turbine building, 139'

elevation of auxiliary building and 118' elevation of radwaste buildin A total of 22 sets of turnout gear (coats, boots, helmets etc.)

and 22 sets of self contained breathing apparatus, are stored at the fire brigade equipment responses location Additional equipment, plus a 1,000 gpm Ford / Pierce fire cpparatus pumper with 450' of 21", 500' of li" and miscellaneous equipment, is stored in the fire equipment building located south of auxiliary buildin Based on this inspection, the designated fire brigade equipment stored at the fire brigade equipment response locations appeared to be properly maintained and stored in a ready conditio . . _ - --

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(4) Fire Brigade Drill During this inspection, the inspector witnessed an unannounced

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fire brigade dril The drill fire scenario was a simulated fire within a heat trace panel in Division I switchgear Room 1A30 Nine fire brigade members responded to the pending fire emergenc The brigade assembled outside switchgear room 1A309 in full protective fire fighting turnout- clothing and self contained breathing apparatus. An initial size-up of the fire condition was made by the fire brigade leader and two li inch fire attack hose lines were advanced to the switchgear room. The fire attack utilized halon extinguishers with hose lines available for backu The fire was placed under control in 10 minutes. In addition, the fire brigade initiated fire search and rescue operation ; The fire brigade utilized adequate manual firefighting methods and i reacted to the fire drill scenario in an effective and efficient manner, f Fire Watch Program The licensee has a hourly roving fire watch program covering approxi-mately 70 rooms or plant areas. This program is required to meet the

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action statement of Technical Specification Section 3.7.7 due to a i large number of licensee identified deficient fire barriers (walls,

, floor / ceiling, cable tray enclosures, etc.). These barriers separate fire areas or redundant systems important to safe shutdown within a fire area and/or involve inoperable or deficient fire barrier pene-tration seals (fire doors, fire dampers, etc.). This program requires i

a minimum of three fire watch personnel per shift. A total of 15 people are assigned to the fire watch progra A fire watch check sheet is provided to indicate the rooms or plant areas which are required to be including in the fire watch program.

Room and plant numbers are added to the list as inoperative fire

barriers or penetrations are identifie However, the list is not arranged by elevation, building, or fire watch patrol route to assure that all areas receive the required surveillance. Also, there does not appear to be an audit program or any other controls to verify that all required areas received the required surveillance once each hou The inspector selected six rooms, OC214, OC215, OC302, OC402, OC702, and 1D302, which were included in the fire watch program and were provided with a security key card. The times that the roving fire watch entered these rooms on August 8 and 13,1987, during the night shift (0 to 8 AM) were reviewed. On August 8, the watch entered two rooms, OC402 and 1D302, each hour, but missed two hours for 0C214, four hours for 0C215, three hours for 0C302, two hours for 0C702. On

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August 13, the watch entered room OC402 each hour,.but missed one hour

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for 0C214, one hour for 0C215, three hours for 0C302, two hours for 0C702 and one hour for 1D30 Also, the time between the many of the surveillance patrols exceeds the specified one hour tim Therefore, based on this review, it appears that the fire watch program is deficient. This is identified.as Violation (416/86-24-02) Inadequate Fire Watch Progra g. Plant Tour (1) Outside Fire Protection The inspector verified that the two water storage tanks contained sufficient water to meet the requirements of the Technical Speci-fications and that all three fire pumps were in servic The 10 ton CO, system tank was inspected and found to be 80% full of C02 at a pressure of 300 psi and the main supply valve was locked in the open po,sition. Fire hydrants and equipment house Nos. D-009, D-023, D-024 and D-025 were inspecte Each equipment house was found to contain 250' of 21" and 100' of 11" fire hose, two 21" and two 11" nozzles, two hydrant wrenches, four spanners, fire axe, bar, handlight and hose gaskets. These fire protection features appear to be adequately maintaine (2) General Plant Tour A tour was made by the inspector of general plant areas. The following safe shutdown related plant areas and their related fire protection features were inspected in detail:

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Upper Spreading Room, OC702

- Motor Generator Instrument Room, OC407

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Division II Switchgear Room, OC215

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Division I Emergency Diesel Generator, 10310

- Division I Switchgear Room 1A309 The inspector visually inspected the fire / smoke detection capa-bilities, the manual firefighting equipment (i.e. , portable extinguishers, hose stations, etc.) and the fire barrier walls associated with the above plant area In addition, the inspector visually inspected the sprinkler protection associated with upper spreading room OC702 and emergency diesel generator room 1D31 Based on the visual inspection, it appears that the fire protection features associated with the above plant areas were properly maintained and fully functiona However, the licensee has identified a number of fire protection deficiencies within these area such as open fire barrier penetrations and the lack of Appendix R type cable raceway fire barriers. A roving fire watch was provided for these areas to meet the action statement of the Technical Specificatio t

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The plan tour also verified the licensee's implementation of the fire prevention administrative procedure The control of combustibles and flammable materials, liquids and gases and the 3eneral housekeeping was found to be very good in the areas inspected. All of the clean and contaminated protective clothing for use in various radiation areas of the plant were stored within metal drums equipped with lids arranged to be self closing in the event of fir Two welding operations were observed on 166'

~levation c of the turbine building and on the 139' elevation of the auxiliary building. An approved " Hot Work" permit had been issued for each of the welding sites and the operations and fire preven-tion / protection practices met the licensee's fire prevention procedure requirement Within the areas inspected, no violations or deviations were identifie . Inspector Followup Items (IFI) (0 pen) IFI (416/85-16-02) Review of Licensee's Actions to Provide Total Enclosures for Appendix R Safe Shutdown Cable Raceway Fire Barrier Work is in process to correct these construction discrepancies. This work is scheduled to be completed by late 1986 and remains ope (0 pen) IFI (416/85-16-04), Inadequate Number of 8-hour Emergency Lighting Unit The installation of the 8-hour emergency lighting units is in progress and is scheduled to be completed by late 198 This item remains ope (Closed) IFI (416/84-45-01), Review of Licensee Identified Appendix R Discrepancies. This item was reviewed during the Region II May 20-24, 1985 inspection of Grand Gulf. Refer to NRC Report 416/85-16 for details. This item is close (Closed) IFI (416/84-45-04), Review of corrective Action Taken on Triennial Fire Protection Audit Finding Appropriate corrective action has been taken on the audit findings except for the item related to the inadequate number of fire detectors. These deficiencies are identified by MP&L's Report MNCR 264-85 and are to be corrected by work package DCP 75/404 The installation of the additional detectors is scheduled to be completed by late 198 This item is closed, but the installation of the detectors will be verified during a future NRC inspection and is to be tracked by Inspector Followup Item (416/

86-24-03) Installation of Additional Fire Detector _ ~

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10 Licensee Identified Items .

(Closed) Licensee Event Report (LER) 85-037-0, Control Room Remote Indication for Fire Detector Inoperabl On September 20, 1985, one of the smoke detectors in the control building failed to' annunciate the control room fire detection computer console during a surveillance test. Subsequent investi-gation revealed that the remote indication for this smoke detector had been inoperable since a utility engineer had entered an erroneous zone description into the computer data base on June 20, 1985. To prevent future occurrence, the licensee has prepared and issued procedure 07-S-03-42, Computer Data Base Control, to control changes to computer data bases. This item is close _

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