IR 05000247/1982008

IE Insp Rept 50-247/82-08 on 820503-07.No Noncompliance Noted.Major Areas Inspected:Fire Protection/Prevention Program,Completion of Fire Hazards Analysis Commitments & SER Commitments

ML20054F583
Person / Time
Site:	Indian Point
Issue date:	05/20/1982
From:	Paolino R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20054F580	List: IR 05000247/1982008 ML20054F579
References
50-247-82-08, 50-247-82-8, NUDOCS 8206170126
Download: ML20054F583 (6)

Text

. - - .

. .

U. S. NUCLEAR REGULATORY COMMISSION

REGION I

e

Report N /82-08 Docket N License N DPR-26 Priority --

Category C Licensee: Consolidated Edison Company of New York, In Irving Place New York, New York 10003 Facility Name: Indian Point, Unit 2 Inspection At: Buchanan, New York Inspection Conduc t May 3 - 7, 1982 Inspectors: d . .c n fNo fl

. olino, Reactor Engi eering Inspector ddte '

date

-

_T! date Approved by:

__. eo- c%

eckman, Chief, Plant Systems ff2d!st da t'e

'

Section Inspection Summary:

Inspection on May 3-7, 1982 (Report No. 50-247/82-08)

Areas Inspected: Routine, unannounced inspection of the fire protection /

prevention program including records review and observation of related work activity; completion of Fire Hazard Analysis commitments and Safety Evaluation Report commitments. The inspection involved 33 inspection-hours onsite by l one region based inspector.

j Results: No items of noncompliance were identified.

l I

.

i l

.

8206170126 820524 DR ADOCK 05000

-

--.- - -_ ~ - .

- _ _ . _ . - -- . _ - . - _ _ _ . . ._ . . - - _ . . - _ . - - - . -

. .

DETAILS Persons Contacted Consolidated Edison Company of New York, In *K. Burke, Director, Regulatory Affairs

• J. Daly, Fire Protection and Safety Administration

• J. Drexer, Fire Protection Engineer

• D. Rosh, General Manager - Technical Support

• M. Shatkowski, General Manager - Administrative services U. S. Nuclear Regulatory Commission i *P. Koltay, Resident Inspector

• denotes individuals present at exit meeting Facility Tour The inspector toured specific accessible vital and non-vital areas in the Indian Point Unit 2 facility to examine fire detection and alarm systems, aute:aatic and manual fixed suppression systems, interior hose stations, fire barrier penetration seals and fire doors. The inspector observed general plant housekeeping conditions and randomly checked tags /date stamps on portable extinguishers and hose stations for evidence of periodic inspections. No deterioration of equipment was noted. The inspection tags attached to extinguishers and date stamps on hoses indicated that inspections were performed'in accordance with established procedures.

No items of noncompliance were identifie . Fire Protection / Prevention Program The inspector reviewed the following documents to determine whether the licensee has developed adequate procedures consistent with the Fire Hazard Analysis, FSAR and Technical Specifications for the Fire

<

Protection / Prevention Quality Assurance Program:

- - Supplement 2 to Corporate Instruction CI-240-1, dated May 31, 1979

"QA Program for Fire Protection Systems".

- - Station Administrative Order, SA0-106, revision 2 dated March 27, 1981,

" Safety Policy".

- - SAO-104, revision 12 dated March 3, 1981, " Maintenance Work Request (MWR) Procedure".

>

r - - - , , - - r - -

. .

- - SA0-105, revision 7 dated March 27, 1981, " Work Permits".

- - SA0-114, revision 3 dated March 27,1981, " Fire Protection and Prevention".

- - SAO-116, revision 1 dated March 27, 1981, " Housekeeping Policy".

The inspector verified that the above procedures for the control of combustibles and fire hazards include: Special authorization for the use of combustible, flammable or explosive hazardous material in safety related area Prohibition on the storage of combustible, flammable or explosive hazardous material in safety related area Requirements for the removal of all wastes, debris, rags, oil spills or other combustible materials resulting from a work activity following completion of the activity or at the end of each work shift, whichever is soone Requirements that all wood used in safety related areas is flame retardant treate . Requirements for periodic inspection for accumulation of combustible Requirements that housekeeping is properly maintained in areas containing safety related equipment and component Requirements that transient combustibles are restricted and controlled in safety related area Work authorization, construction permit or similar arrangement is provided for review and approval of modification, construction l and mainenance activities which could adversely affect the safety of the facility.

i None of the above procedures contained organizational charts or functional descriptions which define organizational responsibilities or lines of communication for on-site fire protection management positions as outlined in NRC Branch Technical Position (BTP) No. 9.5.1 Guideilnes For Fire Protection of Nuclear Power Plants, Attachment No.1., Fire Protection Organization.

I The Fire Protection / Prevention Program has been administered by only

! one person, resulting in difficulties in meeting program development i

i

!

x

-

. .

and implementation requirements. The licensee has recently added two full-time fire protection staff members. The licensee advised the inspector that, with the addition of these staff members, these procedure deficiencies would be corrected within about ninety days as part of other program improvement plan This item is unresolved pending NRC review of licensee corrective action. (50-247/82-08-01)

4. Qualification / Training The inspector reviewed the following documents to determine whether the licensee has developed adequate procedures for the qualifications and training of Fire Brigade members and other plant personnel:

-- SAO-108, revision 5 dated March 27, 1981, " Training Policy"

-- IP-2 Training Manual (Sections 1, 4 and 15)

The inspector verified that these procedures provide indoctrination in fire protection and fire reporting instructions for all plant personnel and visitors. The training program includes classroom instruction in fire protection / prevention, practice in fire fighting and fire drill Fire fighting strategies for all safety related areas and areas which present a hazard to safety related equipment ha.ve not been develope The inspector reviewed the fire fighting strategies developed for the 480V switchgear room and the cable spreading room and determined the procedures to be inadequate based on the guidelines outlined in BTP-9.5.1 Attachment No. 5. The licensee stated that, with additional fire protection staff manpower now available, adequate strategies for all applicable pl.nt areas would be developed within about ninety day This item is unresolved pending NRC review of licensee actio (50-247/82-08-02)

5. Equipment Maintenance, Inspection and Tests The inspector reviewed the following documents to determine whether the licensee has developed adequate procedures which establish mai-tanance and testing requirements and inspection frequencies for the plant's fire protection systems and fire brigade equipment:

-- Technical Specifications, Section 3.13, Fire Protection and Detection Systems, and Section 4.14, Surveillance Testing of Fire Protection Systems and equipmen Procedure No. TM-14, revision 4, Monthly Portable Fire Extinguisher Inspectio Procedure No. PT-R49, revision 0, Refuel Cycle Halon System

'

Functional Test.

!

i

- _

_. _ . . _ _ ~

_

. .

--

Procedure No. PT-SA13, revision 1, Semi-annual Halon System Surveillance Tes Procedure No. PT-R41, revision 1, Refuel Cycle -Inspection of Fire Barrier Seals between Control Room Floor and Cable Spreading Roo Procedure No. PT-R37,' revision 1, Refuel Cycle Check of Main Fire Pump Capacity and System Flow Chec Procedure No. PT-A18, revision 2, Annual Check of Valve Cyclin Procedure No. PT-SA12, revision 3, Semi-Annual Test of Ionization Type smoke detector In addition, the inspector verified implementation of the above procedures through 1981 and/or the last Refueling Cycl No items of nonconpliance were identifie . Fire Protection / Prevention Training Records The inspector reviewed training records for Fire Brigade members and plant personnel to determine whether the records reflect the current status of Fire Brigade member and general employee fire protection /

prevention training and drill The inspector noted that the computerized plant personnel records only listed individual participation in classroom fire protection instructio Fire drill participation by brigade members is recorded only on the drill critique shee In order to determine participation by brigade

! members in the minimum requirement of two (2) drills per year, all

! brigade drill critiques must be reviewed and participating brigade

'

members and the total number of drills for each member individually extracted. As a result the licensee does not track individual brigade i member participation. The drill critique alta provides an assessment of fire alarm effectiveness and brigade response. However, assessment of each brigade member's conformance with established plant fire fighting procedures and u.s of fire fighting equipment was not eviden A sample of individual brigade members showed that the two drill per year requirement was, however, being met.

Discussions with the licensee and the review of available records I indicate the licensee's fire protection program for assessment of each l brigade members knowledge of his role in fire fighting and maintenance of individual records of training for each member does not conform with the guidelines of BTP-9.5.1 Attachment No. 2, Sections 3 and 4, for individual records and assessments for each brigade membe The licensee stated that the BTP 9.5.1 commitment would be reviewed and appropriate corrective action would be taken within about ninety days. This item is unresolved pending NRC review of licensee evaluation and corrective action. (50-247/82-08-03)

,

, .

1 Audits The inspector reviewed the results of of the licensee's annual fire protection audit the by corporate staff, the 24 month audit by licensee's QA organization and the 3 year audit conducted by a consulting fir The inspector determined that the audits were performed in accordanca with written procedures and by personnel not having direct responsibilities in the areas being audite The inspector verified that followup action'was taken and reaudit of deficient areas was performe No items of noncompliance were identified.

< Loss Prevention Report The inspector reviewed the two (2) property loss prevention reports by the .icensee's insurer, M & M Protection Consultants, for 1981. The reports list recommendations in accordance with the Nuclear Mutual Limited Property Loss Prevention Standards.

'

The licensee's response to Insurer's recommendation was adequate and positiv None of the items identified were determined to be reportable to the NR . Unresolved Items-Unresolved items are matters about which more information is required to determine whether they are acceptable, violations or deviations.

,

Unresolved items are discussed in Details, Paragraph 3, 4 and 6.

i 10. Exit Interview The inspector met with licensee representatives denoted in Details, Paragraph 1 at the conclusion of the inspection on May 7, 1982. The inspector summarized the scope of the inspection and the findings as discussed herein.

i

, -

. _ - _ _ , - -- - -. _ , _ _ _ - - -. - - , .