IR 05000424/1987002

Insp Rept 50-424/87-02 on 870112-16.Violation Noted:Failure to Properly Implement Fire Protection Evaluation for Maint Work Orders Involving Removal of Radiant Energy Shields for Instruments PT-403 & LT-459

ML20211C304
Person / Time
Site:	Vogtle
Issue date:	02/05/1987
From:	Conlon T, Miller W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20211C276	List: IR 05000424/1987002 ML20211C271 ML20211C282
References
50-424-87-02, 50-424-87-2, NUDOCS 8702200063
Download: ML20211C304 (14)

Text

A HC UNITED STATES

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NUCLEAR RE2ULATORY CCZMISSION REGION il 101 MARIETTA STREET, N.W., SulTE 2900

'* ATLANTA. GEORGIA 30323

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Report No.: 50-424/87-02 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket Nos.: 50-424 License Nos.: CPPR-108 Facility Name: Vogtle Inspection Conducted: JanuaryTt-16 1987 Inspector: /

W. H. Miller, J fu f\ , 2-6'82 Date Signed Approved bf C #

T. E. Conlon, Chief

1. 7IS// # - SP- f7 Date Signed Plant Systems Section Engineering Branch Division of Reactor Safety SUMMARY Scope: This special, announced inspection was conducted in the areas of fire protection, followup on previously identified items, licensee identified items, and workers' concerns with regard to fire suppression system installation and removal of fire barrier energy shield Results: One violation was identified - Failure to Properly Implement the Fire Protection Evaluation for Maintenance Work Orders Involving Removal of Radiant Energy Shields for Instruments PT-403 and LT-459 - paragraph 6.b.

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REPORT DETAILS Persons Contacted Licensee Employees R. E. Conway, Vice President, Project Director

.S. D. Driver, Training, Supervisor-0perations

• L. R. Glenn, Manager, Quality Concerns Program

• T. Greene, Plant Manager

• E. D. Groover, QA Manager-Construction

• B. C. Harbin, Manager, QC

• C W. Hayes, Manager, QA

• G. A. McCarley, Project Compliance Coordinator

• A. H. Pinson, Vice President - Construction R. Sprankle, Senior Engineer - Fire Protection K. Rosanki, Assistant to Vice President of Project Engineering Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security force members, and office personne Other Organizations Bechtel

• F. B. Marsh, Project Engineering Manager

• B. Woodley, Fire Protection Coordinator Southern Company Services R. George, Project Engineering Manager J. Maddry, Fire Protection Engineer NRC Resident Inspectors

• H. Livermore J. Rogge

• Attended exit interview Exit Interview The inspection scope and findings were summarized on January 16, 1987, with thoe persons indicated in paragraph 1 above. The inspector described the areat, inspected and discussed in detail the inspection finding No dissenting comments were received from the license The following new items were identified during this inspectio .\

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2 Inspector Followup Item (424/87-02-01) - Fire Brigade And Other Opera-tional Employees Are Not Respirator Qualified - paragraph 5.b.(2). Violation (424/87-02-02) - Failure To Properly Implement The Fire Protection Evaluation For Maintenance Work Orders Involving The Removal Of Radiant Energy Shields For Instruments PT-403 and LT459 - paragraph The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.

4. Unresolved Items Unresolved items were not identified during this inspection.

5. FireProtection/PreventionProgram(64704) Status During this inspection, Unit I was in the pre-licensing phase with the low power licensee issued on January 16, 1987. All of the permanent plant fire protections and prevention administrative procedures required for fuel load operations were issued and being implemente The operational status of the suppression and detection systems and fire protection features were reported by the licensee to be as follows:

- Fire Pumps: Two of the three pumps were in service. This met the FSAR. The electric driven fire pump was out of service due to inoperative main power supply breake Water Tanks: Both tanks were in service with approximately 500,000 gallons out of 600,000 gallons available for fire protection. This met the FSA Automatic 123 systems were in service and 4 systems were Sprinkler out of service. Fire watch requirements of the System: FSAR were implemented for the plant areas in which the sprinkler systems were not in servic Fire 44 panels consisting of 220 fire zones Detection were in service and fire panels consisting of 25 System: zones were out of service. Fire watch requirements of the FSAR were implemented for the plant areas in which the detection system was not in servic ~

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- Hydrants / Hose Houses: All required hydrants and hose houses were in servic Interior Hose Stations: All Unit 1 stations were in servic Halon Systems: Three required systems were in servic Portable Fire Extinguishers: All Unit 1 extinguishers were installed.

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Fire Barriers: All Unit 1 barriers were in servic Fire Barrier Penetrations:

Penetration Seals: Only approximately 20 mechanical /

electrical penetrations out of approximately 10,000 penetra-tions were not in servic *

Fire Dampers: .Approximately 99% were in service. Only three dampers were out of servic i Fire Doors: Of the 245 fire doors in Unit 1, approximately 204 were in service and 41 did not meet the design and installation criteria and were considered nonfunctiona Work is in process to correct these deficiencies.

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The fire watch compensatory measures of the FSAR had been implemented for those plant areas that contain fire barrier penetrations which were deficient or out of servic Fire Brigade (1) Organization The station fire brigade is composed of approximately 101 personnel from operations, radwaste, and maintenance organiza-l tions. Each shift brigade is composed of; a team leader plus two other members from operations or radwaste, and two members from the maintenance organization. The licensee stated that sufficient

[ personnel will be assigned to each shift to meet both the plant operational and fire brigade manning requirement This will be reviewed and verified during future NRC inspections of the fire protection program.

! (2) Training l

The inspector reviewed the training records for three brigade

, leaders and nine brigade members to verify that each of these had I completed the initial fire brigade training, fourth quarter 1986 I

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classroom training, practice session during 1986, fire brigade medical examination and were respirator " qualified." These records were satisfactory, except for the respirator qualification records. Of the records for 12 personnel reviewed, four had not received the required respirator training and 11 had not been respirator fit teste However, it was noted that respirator training was scheduled to be completed by late January 1987 and the fit tests were scheduled to be completed for a sufficient number of personnel prior to criticality which is presently scheduled for late February 1987. This is satisfactory, but will be verified during a subsequent NRC inspection and is identified as Inspector Followup Item (424/87-02-01), Fire Brigade and Other Operational Employees Are Not Respirator Qualified, Plant Tour and Inspection of Fire Protection Equipment (1) Inspection of Fire Brigade Manual Fire Fighting Equipment The inspector performed an inspection of the fire brigade equipment, consisting of fire hose, nozzles, tools, and miscel-laneous equipment, stored at the fire brigade equipment lockers located adjacent to the control room on Level 1 of the equipment buildin A total of eight sets of turnout gear (coats, boots, helmets, etc.),10 sets of self contained breathing apparatus, 20 spare air cylinders and miscellaneous equipment are stored at the fire brigade equipment responses locatio Based on this inspection, the designated fire brigade equipment appeared to be properly maintained and stored in a ready conditio (2) Outside Fire Protection Walkdown

The inspector verified that the two water storage tanks contained sufficient water to meet the requirements of the FSAR. The three fire pumps were inspected and two pumps were found to be in i service. This met the requirements of the FSA The following 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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1 2301U4116 l 1 2301U4113 1 2301U4112 1 2301U4095 l 1 2301U4096 l 1 230104391

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The following fire hydrants and fire hydrant equipment houses were inspected:

FHY-943 FHY-944 FHY-946 The equipment houses contained the minimum equipment requirement of that specified by NFPA-24, Private Fire Service Mains and Their Appurtenances, and the FSAR commitment The equipment appeared to be adequately maintaine A tour of the exterior of the plant indicated that sufficient clearance was provided between permanent safety-related buildings and structures and temporary buildings, trailers, and other transient combustible materials. The general housekeeping of the areas adjacent to the permanent plant structures was satisfactor (3) Permanent Plant Fire Protection Features

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A general plant tour was made by the inspector. The fire / smoke detection systems, manual fire fighting equipment (i.e., portable extinguishers, hose stations, etc.) and the fire area boundary walls, floors and ceiling were inspected. These systems were in the process of being placed in service to meet the level of fire protection specified by the FSAR for fuel load and low power testing opertions. The maintenance of these systems will be reviewed during future NRC inspection The plant tour verified that the licensee was implementing the fire prevention administrative procedures. The control of combustibles and flammable materials, liquids and gases, and the general housekeeping were found to be very good in the areas inspected for a plant undergoing the transition from the construc-tion to the operational phas Within the areas inspected, no violations or deviations were identifie . Workers' Concerns Fire Protection Sprinkler Systems Not Engineered Properly (1) Concern The NRC resident inspector received an allegation on December 23, 1986, that the automatic sprinkler systems at Vogtle were not properly designed. These concerns included the following:

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Invalid fire protection system hydraulic calculation Improper cable tray fire protection system coverag Inadequate piping system desig Deviation reports were not being publishe (2) Findings The automatic sprinkler system contractor's contract with GPC has been terminate This contractor left the site on December 16, 198 Another contractor will perform the installation for Unit The inspector reviewed the licensee's investigation file (GPC No. 86V-0862) on this ite Each of these concerns had been reviewed by the licensee. These findings are as follows:

- Invalid fire protection system hydraulic calculation The automatic sprinkler system installation code for Vogtle is National Fire Protection Association (NFPA) Standard No.13, Standard for the Installation of Sprinkler Systems, 1983 Edition. The worker's concern was that excessive velocity existed in the sprinkler system piping. Histori-cally, the maximum velocity flow in sprinkler piping has been limited to a maximum flow of 32 feet per second since flow above this rate will result in excessive friction loss. However, the 1983 Edition of NFPA-13 does not restrict the velocity flow to less than 32 feet per second but states that velocity pressure may or may not be used in the calculations at the discretions of the designe However, the systems must be designed to meet the available water pressure and flow rates. The licensee's A&E has reviewed this item and determined that not considering the velocity pressure will not produce an inadequate system and that the design of the systems meet NFPA-13. Based on the inspector's

. review of the installed systems, this assumption appears correct. Therefore, this concern is not vali Improper cable tray fire protection system coverag The sprinkler systems at Vogtle do indeed deviate from the

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coverage requirements of NFPA-1 However, all systems have

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been reviewed by the licensee's Fire Protection Finalization Program (Procedure FP-3) and any identified sprinkler system which deviated from the FSAR and NFPA-13 code requirements were documente These deviations were reviewed by a registered fire protection engineer and were either approved

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or deviations were corrected where neede There reviews have verified that the sprinkler systems should limit fire damage and provide reasonable assurance that sufficient protection will be provided such that one shutdown train will be maintained free from fire damage and that the plant can be shutdown in the event of fire. The systems appear to meet the FSAR commitments. Therefore, although this concern is true, the design and installations meet the FSAR commitments and NRC guidelines and are acceptabi The concern that the pre-action sprinkler systems at Vogtle are not provided with a " test pipe" and that the systems are not provided with air exhausters is true. However, the 1983 Edition of NFPA-13 does not require these feature Therefore, this concern is not applicable to Vogtl Deviation reports not published The employee had a concern that the sprinkler system contractor refused to publish some of the deviation reports i written to define the improperly designed fire protection system The licensee investigated this concern and identified a number of deviations. These deviation reports also initiated the necessary connective actio It is possible that this concern may be true; however, since the contractor is no longer on site, GPC does not plan any further action on this item. Also, since all of the systems were inspected and reviewed in detail by the licensee's Fire Protection Finalization Program, all serious code deviations should have been identified. The inspector concurs that no further action is required on this ite No Plans or Procedures Provide to Control Removal and Replacement of Fire Barrier Wraps (1) The NRC Resident Inspector received an anonymous allegation on January 13, 1987, that a fire barrier wrap had been removed during maintenance operations from pressurizer level located within the containmen Following these maintenance operations, someone identified that this wrap was necessary. A maintenance work order (MW0) was issued to replace this wrap. The MWO was accomplished by a site construction contractor due to the lack of certified

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individuals assigned to the operations group do perform the work.

1 The alleger's concerns were as follows:

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(a) Concern No procedures or plans are available to control the removal r and replacement of fire barrier wrap.

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(b) Concern Operations has no certified personnel to install or repair

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damaged fire barrier wrap.

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(2) Findings- "

j The inspector reviewed two recent MW0, Nos. 18621678 and 18624536, i issued on November 10, 1986 and December 3,1986, respectivel These MW0s required maintenance work on reactor coolant system pressure transmitter IPT-403 and pressurizer level transmitter

ILT-459 along with several other instrumentation devices located within the Unit 1 containment. Transmitters IPT-403 and ILT-459 i are required to be enclosed in a 3-hour fire rated radiant energy -

shield to provide separation for these transmitters from adjacent redundant components and cabling required for plant shutdown in the event of a fir These barriers ensure that the components

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of at least one shutdown train will be maintained free from fire damag However, the work required by these MW0s did not specify

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] that the fire barrier energy shield was to be removed and replaced i

and the shield for ILT-459 was not scheduled to be replaced.

i GPC Procedure 00350-C, Maintenance Program, establishes the i i procedures for the control of maintenance activities so as not to compromise the safety of the plant. Section 3.4.14 of this i procedure requires a fire protection work evaluation to be i performed by qualified personnel on all work orders. Procedure l- 20050-C establishes the means of processing work orders within the

, maintenance work planning group. Section 4.16 of this procedure l requires a Fire Protection Checklist (Figure 4) to be completed i for all maintenance wor Instructions for completing the

! checklist are described in Procedure 92026-C.

! A review of the Fire Protection Checklist attached to the i

above MW0s indicated that the fire protection evaluations were i inadequate in that the MW0s did not specify that the work involved would impair the fire separation features of the radiant energy shields for transmitters ILT-459 and IPT-403. This is identified  ;

as Violation (424/87-02-02), Failure to Adequately Implement the  :

l Fire Protection Evaluation for Maintenance Work Orders Involving

! Removal of Radiant Energy Shields for Instruments IPT-403 and .

i 1LT-459.

! Subsequent to the completion of the above MW0s, the licensee i

, conducted the surveillance inspection required of all fire barriers by using Procedure 92445-C, Fire Barriers and Fire PenetrationSeals(18monthvisualinspection). This surveillance inspection identified the missing fire barrier shields for 1LT-459 (

! and IPT-403. Subsequent investigation indicated that a MWO to ,

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repair the shield to IPT-403 had been issued but no MWO had been l

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issued for ILT-459. Therefore, the fire barrier shields for both of these instruments were scheduled to be repaired before fuel loa However, if the MW0s had been accomplished after the surveillance inspection, it appears that the plant would probably have gone operational without the shields for both of these instruments in plac As a result of this review, the inspector's evaluation of the allegations is as follows:

- No procedures or plans are available to control the removal and replacement of fire barrier wra The concern is not valid. Procedures are available to require a fire protection evaluation of all maintenance work on Unit 1. The purpose of this evaluation is to identify any work which will impair or modify any of the plant fire protection features. A fire protection checklist is required to be filled out for each MWO. This checklist specifically lists radiant energy shields as one of the features which must be considered in the evaluation. Upon completion of any MWO which has defeated or modified any fire protection feature, the plant fire protection engineer is required to verify that the impairment has been corrected. However, as noted above these procedures were not fully implemente Operations has no certified personnel to install or repair damaged wra This concern is true. However, all repairs to damaged fire barrier wraps and radiant energy shields are accomplished by one of the contractors on sit This construction firm installed the fire shield material for Unit 1 and is to provide this installation for Unit The contractor is scheduled to remain on site up to the Unit 2 fuel load and a part of his contract is to train site personnel in the installation of this materia After Unit 2 becomes operational, qualified site personnel should be available to perform any necessary new installation or repairs to any *

l damaged fire barrier raceway' wraps or radiant energy shield.

This approach is considered acceptable. Therefore, this

. concern is not valid.

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j Except as noted above, no additional violations or deviations were identi-i fled.

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7. Inspector Followup Items (IFI) (Closed) IFI (424/84-34-01), Removal of All Combustible Scaffolding, Planking and Temporary Construction Structures Required Prior to

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Licensing. The licensee stated that all combustible construction material, scaffolding and temporary structures were removed from the plant areas before these areas were turned over to operations. Any new combustible materials which enter these areas must be approved by Procedure 92015, Control of Transient Combustibles. Furthermore, weekly inspections conducted using Procedure 92010-C, Weekly Fire Inspections, will identify any new combustibles and should implement the necessary action to remove these combustibles or authorize these materials by permit. During the plant tour, the inspector did not identify any unauthorized combustible materials. This item is close (Closed) IFI (424/86-13-03), Engineering Analysis, Testing and Justification for Non-Standard Penetration Seal Configurations. The licensee provided additional information to the NRC/NRR staff by letter, dated October 24, 1986, and during a meeting on November 4, 198 This information included a test report on a penetration fire barrier seal of similar design to the oversized penetrations at plant Vogtle. NRC's Supplemental Safety Evaluation Report (SSER) No. 4, Appendix Q stated that the oversized penetrations seals at Vogtle had been reviewed and were acceptable. This item is close (Closed) IFI (424/86-64-03), Prefire Plans Fail to Properly Identify Adequate Fire Brigade Strategies. Fire brigade strategies have been issued for 68 plant areas which contain equipment or components required for fuel load operations. . These strategies meet the NRC guidelines and identify the fire hazards within the area, shutdown equipment, smoke removal and ventilation procedures and special considerations such as fires within charcoal filter units and available exterior or yard fire protection equipmen Drawings attached to each fire fighting strategy identify the available fire protection equipment and location for the fire area, major plant equipment, cable raceway fire barriers / shields and the access route to the fire area. Strate-gies for the remainder of Unit 1 are to be completed by April 30, 1987. This item is close (Closed) IFI (424/86-64-04), Automatic Sprinkler Systems do not Meet FSAR Design Commitment FSAR Amendment 28 states that the sprinkler systems in safety-relaud areas are either in compliance with NFPA-13 or have been specifically evaluated by a fire protection engineer and found to provide an acceptable level of protection. The sprinkler system design criteria was reviewed by the NRC/NRR staff and as documented by SSER 4, Appendix Q, found acceptable. For the unsuper-vised valve to the water float alarm, the licensee is to drill a hole in the control valve to the water flow pressure switch and seal this valve in the open positio This corrective action is identified by Deficient Report 1-87-318 which will close this ite *

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e. (Closed) IFI (424/86-64-06), Licensee to Provide Design and Test Data for Fire Barrier Penetration Seals. Refer to IFI (424/86-13-03). This item is close f. (Closed) IFI (424/86-64-07), Fire Detection System for Main Control Room Complex Fails to Comply With SSER1 and FSAR Commitments. The FSAR has been revised by Amendment 28 to indicate that the detectors are not mounted on the control room suspended ceiling but in the concealed space above the ceiling due to the design of the ventilation system This was reviewed by the NRC/NRR staff and as documented by SSER-4 found acceptable. Therefore, this item is close g. (Closed) IFI (424/86-81-01), Resolve Conflict between FSAR Fire Protection Comitments and As-Built Plant Conditions. The FSAR was revised by Amendment 28 and the descriptions of the fire protection installation features were changed to conform to the as-built plant conditions. These revisions were reviewed by the NRC/NRR staff and as documented by SSER-4 found to be acceptable. This item is closed, h. (Closed) IFI (424/86-88-01), Verification of Installation of Access ,

Ladder and Platform to Fire Zone 73. The inspector verified that the ladder and platform to this area (FCR No. C-FCRB-20, 823) had been installed. This item is close . (Closed) IFI (424/86-88-02), Review of the Installation of Additional Smoke Detection for Fire Zone 80. The inspector verified that the additional defectors (FCR No. E-FCRB-18, 403) for the area above Zone 80 had been installed. This item is close j. (Closed) IFI (424/86-88-03), Review of Surveillance Procedures for Fire Area Boundaries Required for Safe Shutdown Cable Separatio Procedures 92424-C, Fire Doors, Semi-Annual Inspection and 92445-C, Fire Barrier and Fire Barrier Penetration Seals - 18 month visual inspection, have been revised to include the barriers required for separation of shutdown cables and components. This item is close k. (Closed) IFI (424/86-88-11), Verify Acceptance of Non-Dedicated Steam Generator Pressure Indication On Remote Shutdown Panel B. This item was approved by the NRC/NRR in SSER-4 and therefore, is close . (Closed)IFI(424/86-88-12), Review Access Plan for 125VDC Distribution Cabinet The inspector verified that the locks previously on these panels had been removed. Therefore, this item is closed, m. (Closed) IFI (424/86-88-14), Eight-Hour Battery Powered Emergency Lighting Units are Not Provided for Control Room and Exterior Routes to l Safe Shutdown Components. The lighting for these areas were reviewed by NRC/NRR and as documented by SSER-4 found acceptable due to the dedicated handlights located at designated areas, security perimeter lighting powered by a diesel generator, and redundant diesel powered emergency lighting for the control room. This item is closed.

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12 (Closed) IFI (424/86-88-15), Verify Isolation of Sound Powered Telephone System from Control Room for a Control Room Fir The inspector verified that the isolation switch installed to isolate the control room shutdown sound powered telephone system (FCR No E-FCRB-18, 231 and E-FCRB-18, 232) had been installed and that the use of this switch had been incorporated into Procedure 18038-1, Operation From Remote Shutdown Panels. This item is closed, (Closed) IFI (424/86-88-16), Area Smoke Detectors are not Provided within Containment as Stated by FSAR. The FSAR has been revised by Amendment 28 to indicate that general area fire detection has not been provided for the containment because detection systems are provided for the major hazard areas. This was reviewed by the NRC/NRR and approved by SSER-4. Therefore, this item is close (Closed)IFI(424/86-124-01), Disposition of Incomplete Fire Protection Features Identified During Area Turnovers. The inspector's original concern was that a large number of fire protection features would not be operational at the time of licensing and that an excessive number of fire watches would be required. However, as noted in above paragraph 5.a. most of the fire protection systems and features are operationa The licensee estimated that a maximum of ten fire watches per shift is required. This appears reasonable. Therefore, this item is close (Closed) IFI (424/86-124-02), Abnormal Single Ground Fault Condition Test Requirements to be Incorporated Into Fire Detection System Preoperational Test In Accordance with NFPA-720. All of the fire detection systems in the Unit 1 and common plant areas have been tested under both open and ground fault conditions by work order Nos. A-86-05142 and 05158 and 1-86-23393, 23709, 23513, 23514, 23665, 23673, and 23899. This item is close . Licensee Identified Item Construction Deficiency Report (CDR)

- (Closed) CDR-86-M132, Containment Purge System Resister Dampe On November 17, 1986, the licensee informed NRC Region II of a potentially reportable condition concerning a loose damper in the exhaust damper of the containment normal purge system. On December 16, 1986, the licensee determined that this condition was reportable and submitted a summary of their evaluation. The inspector reviewed the licensee's evaluation and corrective actions. The work for Unit 1 is complete and the work for Unit 2 will be completed commensurate with the Unit 2 construction schedul The damper registers for the containment purge system are designed for nonseismic, nonsafety applications. The Register Damper installations were modified by the addition of pop rivets or tack welds to secure the dampers to the registers (M-FCRB 15730 10/23/86). Engineering and

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Pre-0p test personnel implemented the pop rivet optio Further, M-FCRB 16362 of December 5,1986, clarified welding requirements and provided for fillet welds only based on the results of confirmatory calculation X4C1506V02 Rev. 0, (December 5,1986) for future applica-tion of that design detail. The FCRs were converted to Unit 1/ Unit 2 drawing change notices. Field work was completed under MWO 1861672 In addition to the above, a confirmatory QC inspection (MWO 18701061, January 16,1987) was performed by the licensee to verify the instal-lation. Ten of - the twelve dampers were in full compliance with FCR requirement The remaining two dampers had four pop rivets; however,

'he configuration differed from the FCR. Engineering evaluated the

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as-built condition for these two dampers and confirmed their technical adequacy. This item is close .

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