IR 05000324/1993008

Insp Repts 50-324/93-08 & 50-325/93-08 on 930222-26. Violation Noted.Major Areas Inspected:Implementation of Fire Protection/Prevention Program

ML20056C183
Person / Time
Site:	Brunswick
Issue date:	03/18/1993
From:	Branch M, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20056C180	List: IR 05000324/1993008 ML20056C179 ML20056C181
References
50-324-93-08, 50-324-93-8, NUDOCS 9303300207
Download: ML20056C183 (8)

Text

- - _ _ - _ _ - - -

tk# MCuy UNITED STATES

,

[p M, NUCLEAR REGULATORY COMMISSION REGION 11 3 o

-

$'

7 .$ 101 M ARIETTA STRE ET. ;. ~ f ATL ANT A, GEORGI A 30323

,....+m/ Wa 2 5 s Report No /93-08 and 50-324/93-08 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket Nos.: 50-325 and 50-324 License Nos.: DPR-71 and DPR-62 Facility Name: Brunswick Steam Electric Plant, Units 1 and 2 Inspection Conduc  : February 22 - 26, 1993 Inspector: @ s 3/ 7_3 G. R. Wiseman Date Sihned Approved by:

M. Branch, Kcting Section Chief

/7[93 Dafe Sicfned Test Programs Section, Division of Reactor Safety SUMMARY Scope:

This routine inspection was conducted to evaluate implementation of the plant's fire protection / prevention program. Activities reviewed included the ongoing fire barrier inspection program, maintenance of fire protection features, a fire brigade drill, results of a Nuclear Assessment Division (NAD)

QA fire protection audit, and modifications accomplished on the fire protection systems during the current plant outage.

I Results:

Within the area examined one violation was identifie The violation involved two examples of the specification of inappropriate post maintenance hydrostatic pressure test criteria for fire protection piping d replaced under Work Request / Job Orders (WR/J0s). (Paragraph 2.c.)

9303300207 930325 PDR ADOCK 05000324 G pop

_ - - _ _ _ - _ _ _ _ _ _ _ _ _ - _ -

._ _ _ _ _ _ _ _ _ _ _ _ _ _

.. .

. -

'

The following improvements and weaknesses were identified:

Improvements:

-

Fire Barrier Reinspection Program inspections by Nuclear Engineering Department (NED) were nearing completion for Unit This has been a positive initiative for self-identification and correction of numerous fire barrier deficiencie Fire brigade performance has improved. During observation of a fire drill, the brigade exhibited good command and control, fire ground tactics, and personnel rescue operation Weakness:

-

The plant Fire Protection Program implementing document, PLP-01, Fire Protection Program Document, dated November,- 13,.1986, has not been revised in recent history to update implementation of the fire protection program relative to the licensee's organizations; their responsibilities and interfaces, Appendix R fire protection features, and alternate safe shutdown methodology and equipment.

{

i l

l-l ______

- -

- _______-__ _--_-_____ _ __

l

.

l REPORT DETAILS 1 Persons Contacted Licensee Employees

• R. Anderson, Vice-President, Brunswick Nuclear Plant

• M. Bradley, Manager, Nuclear Assessment Division (NAD)

• J. Brown, Unit 2 Plant Manager

• S. Callis, On-site Representative, Licensing

• S. Hardy, Fire Protection Engineer, Nuclear Engineering Design I

• B. Hewett, Engineer, Technical Support

• M. Hunter, Technical Support Supervisor

• P. Mazzola, Manager, Support Training i

• G. Miller, Manager, Technical Support .j

• D. Moore, Unit 1 Maintenance Manager  !

• R. Morgan, Unit 1 Plant Manager

• T. Mull, Fire Protection Specialist, Operations

• R. Tart, Acting Manager, Radwaste/ Fire Protection

• E. Willett, Manager, Outage Management and Modifications Other licensee employees contacted included craftsmen, technicians, operators, mechanics, fire watch personnel, security force members, and office personne NRC Resident Inspectors

• R. Prevatte

• Attended exit interview Fire Protection / Prevention Program (64704)

The inspector evaluated the overall adequacy and implementation of the ;

licensee's Fire Protection Program. The fire protection program is j described in the Licensees' final Safety Analysis Report (FSAR). Fire Protection Program Implementation The inspector reviewed the onsite fire protection program implementing procedure, PLP-01, Revision 1, Fire Protection Program Document, dated November 13, 1986, and compared it to the program description of the FSAR. The review indicated that PLP-01 had not yet been revised to include a descriptions of the current fire protection staffing organizations, their responsibilities or interfaces: Appendix R safe shutdown procedures or equipment; and and policies for the operability of fire protection features, et This is considered a program weaknes _ ______-___ _ __ __

_ _ __ - _ _ _ _ __ _ __ ____ _ ____ ___ . _ _ . _ _ _ .

.

The licensee indicated that a Technical Support organization initiative was underway to update the fire protection commitment documents and the fire protection program plan implementing documents, including PLP-0 b. Fire Barrier Reinspection Program The licensee has performed a detailed review and inspection of fire barriers and penetrations seals during the current outag These licensee inspections were initiated by NED utilizing Design Guide IV.0020, revision As a result of this effort approximately 170 Work Requests / Job Orders (WR/J0) have been issued to correct the fire penetration seal and barrier configurations. The inspector reviewed a computer listing and description of the WR/J0s issued for fire barriers and concluded that the work had been appropriately prioritized. About 48 work items have not been completed for Unit 2 areas and are identified against LCOs associated with generic fire barrier or penetration seal conditions. The inspector verified that compensatory measures consisting of roving fire watches were in place for those outstanding work items in the diesel generator and control buildings. Based on this review, the inspector concluded that the licensees actions conformed to NRC guidelines and adequate measures were in place for proper control of fire barriers and penetration seals located in Unit 2 plant areas. The. licensee has committed to complete the inspections and repairs of deficiencies for the fire barriers by the end of each affected Unit's next refueling outag c. Material Condition of Unit 2 Fire Protection Features During this outage the licensee has performed a detailed review of the material condition of the fire protection systems. As a result of this effort, approximately 300 Work Requests / Job Orders (WR/J0) had been issued for Unit 2 to correct the fire protection features deficiencies. The inspector reviewed a computer listing and description of the WR/J0s issued for Unit 2 fire protection systems and concluded that the work had been appropriately prioritized. As of this inspection, some 147 work items had not been completed for Unit 2 areas. A review of these items found that most of the identified conditions involve corrosion removal,-

painting, and repair of fire system valve packing leaks. Based on this review, no safety issues were -identified involving the scope of Job Orders not yet completed for fire protection features located in Unit 2 plant area The inspector reviewed the work packages associated with WR/J0s 92-AXCLI and 92-BEUPI written to repair fire protection sprinkler and hose standpipe piping leaks through the Service Water Building elevation 2' wall. The repair work activities were assigned and scoped by the Outage Maintenance and Modification (OM&M)

organization. The repairs consisted of replacing the piping from

-___ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ __-_-_ __-

_ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.. .. .

V

the system actuation valves located in valve pits #3 and #4 through the service water building wall to existing pipes inside

'

the buildin The inspector questioned the difference between the post i maintenance test hydrostatic test pressure and hold time values specified and used in Attachment 1, Hydrostatic Test Data Sheet (actual pressure gauge readings of 145 psig for 10 minutes) of the work package, and those required in the associated NFPA Standards' 1 to which the licensee is committed. NFPA Standard 13, Installation of Sprinkler Systems, section 8-2.2, requires, in part, that all piping subjected to system working pressure shall by hydrostatically tested at 200 psig and shall maintain that pressure for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The inspector was informed that in November  ;

1992, the OMiM modification engineer defined the post maintenance j test requirements in the repair instructions and was then unaware of the applicable NFPA Standard The inspector also reviewed the following procedures governing the maintenance process for fire protection systems:

-

Maintenance Management Manual, Procedure Number OMMM-003, Corrective Maintenance (Automated Maintenance Management System), Revision 16

-

Plant Operating Manual, Outage Management / Modifications Work i

Procedures, Number WP-123, OM&M Initiation and

! Implementation of Work Request / Job Orders, Revision 002

-

Specification for Installation of Piping Systems, BSEP l Specification Number 248-117, Revision 9 Procedure OMMM-003, section 5.3.H., indicated that a WR/JO involving fire protection (Fire field is "Y") should be planned with consultation of the Fire Protection (FP) Engineer. Procedure WP-123, section 2.0, references OMMM-003, but has no requirement or references to use NFPA fire protection standards. BSEP Specification Number 248-117, section 5.3.1, requires fire protection piping to be pressure tested in accordance with applicable NFPA Codes and Standard CFR 50 Appendix B, Criterion V,. Instructions, Procedures, and Drawings, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawing Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining

_ __ _

- _ _ _ _ _ _ _ _ - _ _ _ __

.

-

.

that important activities have been satisfactorily accomplishe Contrary to these requirements, work packages 92-AXCL1 and 92-BEUP 1 accomplished in November 1992 were inadequate in that the hydrostatic test pressures and hold times specified to test replacement piping in two fire protection suppression systems to the Service Water Building were not in accordance applicable procedures and design documents. This matter is identified as a violation, 50-325, 324/93-08-01, Inappropriate Post Maintenance Test Requirements Specified for Fire Protection System Fire Drill A fire brigade drill (No. FD-93-C-004) was conducted on February 25, at 1:00 p.m. which was witnessed by the inspecto l The drill scenario involved burning lubrication oil at the 1-C RHR 1 Service Water Booster Pump on the 50' elevation of the Unit 1 Reactor Building which threatened safe shutdown cabling in the overhead areas. The reactor building, 50' elevation normal lighting was turned off for the exercise to simulate low / emergency light condition Response to the fire consisted of five fire brigade members, along with Health Physics, Security, and Emergency Medical personnel. The fire brigade responded in full protective clothing within 14 minutes with appropriate fire fighting equipment, properly deployed the hose lines, established a command post and effectively used the plant PA telephone communications. The fire brigade successfully located, treated, and rescued a simulated injured individual-from the fire floor are Following the drill, a critique was held with the participants and drill evaluators to discuss the good points and items that could ,

be improve Overall response to the fire drill and the exercise i critique were considered by the inspector to be good and an improvement over previously observed exercise i' Fire Protection Quality Assurance Audits The inspector reviewed Audit B-FP-92-01, Triennial Fire Protection Audit, which was performed by the Nuclear Assessment Division (NAD) and completed on October 2,1992. This audit included participation by an outside fire protection consulting firm in the audit activities. The audit appeared to be a thorough review and evaluation of the plant's fire protection material condition. The j

.i inspector considered the NAD audit adequat The.NAD audit considered the Fire Protection Program satisfactory; but, four i items of concern, a weakness, and a number of comments and !

suggested areas in need of improvement were identified. The following issues were addressed: an apparent lack of management attention to fire protection operations; a deteriorating condition of the fire protection water supply system; fire pump flow testing was not in accordance to NFPA Codes and Standards; a lack of clear i understanding by fire protection personnel as to their  ;

__ ___

.

_ .. -

T T

.

S responsibilities and overall accountability for the Fire Protection Program; and problems with configuration control and design of the fire protection water supply. These items are being reviewed'by the licensee to determine the appropriate actions required, Plant Tour A general plant walkdown inspection was performed by the inspector to verify: acceptable housekeeping; compliance with the plant's fire prevention procedures such as " Hot Work" permits and transient combustibles; operability of the fire detection and-suppression systems; and, installation and operability of fire barriers, fire stop and penetration seals (fire doors, dampers,

.

!

'

electrical penetration seals, etc.).  !

Within the areas inspected, the general housekeeping was i satisfactory, considering that the units have been in extended I outages and major maintenance and repair activities have been I

,

ongoing. The housekeeping for areas.containing potential  ;

lubrication oil and diesel fuel leaks, such as the diesel i generator rooms, appeared to be controlled. The licensee made use i of oil absorption materials to catch and soak up the oil from the ;

leaks associated with diesel generator pedestal seal  ;

modifications. The oil absorption materials were being replaced j at appropriate intervals. The control of other combustible and *

!

hazardous materials and flammable and combustible liquids and gases was also satisfactor ,

t

Three in-process " Hot. Work" operations, involving welding and !

l grinding, were observed. These operations were being performed in the Turbine Building. A " Hot Work" permit had been issued for l each operation and the appropriate fire prevention controls were i

'

established and implemente ;

,  !

The station fire pumps, fire protection water supply tank, and

,

associated distribution piping and valves were inspected and found

'

to be in servic Several trouble tags were noted on fire system .

valves indicating valve packing leakage problems which have been >

,

identified during ongoing plant fire protection component reviews .

and walkdowns. Otherwise, the fire equipment appeared to be !

satisfactorily maintaine ;

1 ,

-

3. Exit Interview  !

'

The inspection scope and findings were summarized on February 26, 1993, ;

with those persons indicated in paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results. No '

dissenting comments were received from the license ;

i

!

.

i f

, .- .

-

- _ - - c

..

- -

,

i

The licensee did not identify as propriethry any of the materials provided to -f or reviewed by the inspector during this inspectio Item Number Description and Reference  :

t 50-325,324/93-08-01 Violation - Inappropriate Post Maintenance Test Requirements *

Specified for Fire Protection Systems :

'

(Paragraph 2.c.)

'

t

>

h i

l

,

i a

!

,

i r

!

l

!

,

l

l t

l

'

I i

l

. . _ .

I