ML17261A811
| ML17261A811 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 12/21/1988 |
| From: | Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17261A809 | List: |
| References | |
| 50-244-88-24, NUDOCS 8901120402 | |
| Download: ML17261A811 (22) | |
See also: IR 05000244/1988024
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report
No.
88-24
Docket No.
50-244
License
No.
18
Priority
Category
C
Licensee:
Rochester
Gas
and Electric Company
Facility Name:
Ginna Nuclear Station
Inspection at:
Ontario,
NY
Inspection
Conducted:
November
15 - 17,
1988
Inspector:
Krasopoulos,
Reactor
Engineer
Aris
d'
Approved by: D
Cl
ford J. Anderson,
Chief
Plant Systems
Section
Date
Ins ection Summar:
Inspection
on November
15 - 17,
1988 (Report 50-244/88-24)
~I:
i
i
- i
h
Fi
Prevention
program including:
Program administration
and organization;
adminis-
trative controls of combustibles;
administrative controls of ignition sources;
other administrative controls;
equipment
maintenance
inspection
and tests; fire
brigade training; periodic inspections
and quality assurance
audits
and facility
tours.
Results:
Two violations were identified.
They are:
failure to provide the
required
number of drills to the fire fighters and failure to provide adequate
separation
to safe
shutdown
components.
Cl
DETAILS
1.0
Persons
Contacted
1. 1
Rochester
Gas
and Electric
RG&E
" S. Spector,
Station Superintendent
- D. Gent,
Results
and Test Supervisor
" J. Hotchkiss, Modification Project
Manager
- R. Carroll, Training Manager
" G. Meier, Division Training Manager
.
- M. Cavanaugh,
Fire protection
Engineer
" T. Harding, Modification Project Engineer
" J. Widay, Superintendent
of Production
" S.
Adams, Technical
Manager
" K. Hart, Supervisor Instructor and Office Services
" R. Biddenbach,
Safety Coordinator
" E. Smith, Fire Protection
Engineer
1.2
U.
S Nuclear
Re viator
Commission
NRC
~ C. Marshall, Sr. Resident
Inspector
~ N. Perry,
Resident
Inspector
- Denotes
those present at the exit interview
2.0
Follow-U
Of Previous
Ins ection Findin
s
2. 1
Closed
Unresolved
item
50-244/80-02-06
Halon
s stem
ressure
au es
not calibrated
The
NRC identified the concern that the pressure
of the Halon system
may
not be properly surveilled because
the
on the Halon cylinders
are not calibrated.
Halon system, pressure
surveillance is
a Technical
Specification requirement.
The licensee
explained that system pressure
is
verified by using the cyclinder's weight and temperature
to calculate
the
pressure.
This method of verifying the pressure
and cylinder contents is
acceptable.
The inspector
reviewed the- procedure
PT-13.4.33 titled:
Station
Halon
systems bottle weighing and air flow test,
Revision 7, to verify, that the
.
survei llances
are being performed.
This item is resolved.
4S
I
P
'Ginna
2.2
Review of fire
rotection concerns
from the Inte rated
Performance
Assessment
Team
IPAT
ins ection
Re ort No. 88-15.
The IPAT identified the following fire protection concerns:
The licensee
does not universally provide internal
seals to electrical
conduits to ban the passage
of smoke
and hot gases.
This is an issue
currently under review by
NRR because
several
other licensees
do not
provide internal
seals to conduits.
This is because
industry tests
have indicated that these
seals
may not be required.
The inspector
was assured
by the licensee
that this issue is being followed and
when
NRR completes
the review they w'ill act accordingly.
The licensee
may not have adequate
water supplies
to provide cooling
to the
Emergency Diesels for a fire in the Screen
House.
This concern
was generated
because
the 'IPAT observed that there is
a possibility
that the city water which is relied
upon to provide cooling'to the
diesels
may not be reliable.
The city water is the alternative cooling
water source to the service water that supplies
the diesel
cooling
needs.
The inspector,
upon
a closer examination of 'the concern,
concluded that the city water supply is reliable.
Based
on interviews
of long time licensee
personnel
and the
NRC resident staff, it was
determined that in the last
few years there
were only a few instances
of low water pressure
to the plant.
The duration of these
low pres-
.
sure episodes
was relatively short.
The inspector
concluded that
the simultaneous
occurrence
of a fire in the screen
house
and the
loss, of off site power when the city wat'er supply to the plant is
diminished or turned off is
a low probability event.
3.
The licensee
may not have provided adequate fire protection
separation
to conduits required for safe
shutdown.
This concern
was identified
when the
IPAT observed that conduits required for shutdown were not
completely wrapped with the I hour rated fire proofing blanket
when
crossing certain conduit supports..
In addition the
IPAT observed that
the installation of the fire wrap was not performed in accordance
with the design
document which requires that the wrap be continuous
and that the wrap extends
4" over any conduit supports.
The design
document in particular is Procedure
no. 8400. 104, .titled, "Repair and
installation of the
INSULCO/HEMYC protective wrap system
around
interferences
and obstructions."
The inspector
observed
a few examples of inadequately installed wrap
in the Intermediate building Elevation 253'-6".
The conduit observed
was
No.- R975.
Loss of this conduit could cause
the loss of steam
generator
pressure
indication.
This is
a parameter
required to be
monitored during shutdown.
Other conduit wraps similarly
installed'ere
on conduit no.
L400 and
L398 located in the Auxiliary building
fire area
ABBM.
These conduits are
power feeds to charging
pump
1A.
This
pump is relied
upon for primary coolant
make
up in the event of
a fire in this area.
Thus,
a fire in this area
has the potential
for
damaging
the conduits
and could affect the safe
shutdown capability.
Ginna
10 CFR 50, Appendix R, Section III.G, requires
the enclosure of the
cables
and equipment of one redundant
safe
shutdown train in a fire
barrier having
a one hour rating.
The areas of inadequately
installed fire
wrap do not have
a one hour fire rating.
This represents
a violation
of the above requirement
because
a fire in the intermediate building
elevation 253'-6" or a fire in the Auxiliary building fire area
ABBM
could cause
the loss of redundant
safe
shutdown equipment,
The equip-
ment that could be lost is the
pressure
indication
and charging
pump lA.
Because
during the time of this finding, the
licensee
had neither
an approved
exemption
request
from the above
mentioned
requirements
nor did they have
an analysis to justify the
adequacy of the installed fire wrap this is a violation.
(88-24-01)
To address
this concern,
the licensee
stated
the following:
(a)
It is their intention to correct the fire wrap installation
so
that it conforms to the design details.
This work is scheduled
to be performed
by the end of the next refueling outage.
(b)
To assure
that in the interim it is safe to operate with a
degraded fire barrier they performed
an analysis.
This analysis
concluded that,
although the fire wrap was not installed in ac-
cordance with the design details
and therefore is not
a one hour
rated fire barrier, it would offer adequate
protection to the
affected conduits.
The analysis
was performed using heat transfer
calculations.
These calculations
demonstrated
that given the
amount of combustibles
in the area
and the exposure of the
conduits to the fire hazard
the conduit would survive without
fire damage.
A cursory review of this analysis
by the inspector
did not identify any unacceptable
conditions.
3.0
Fire Protection
and Prevention
Pro
ram
The inspector
reviewed several
documents
in the following areas
of the
program to verify that the licensee
had developed
and
implemented
adequate
procedures
consistent with the Technical Specification
requirements,
license conditions
and
FSAR commitments.
The documents,
scope of review and the inspection findings for each area of the program
are described
in the following sections.
3. 1
Pro
ram administration
and Or anization
The inspector
reviewed the following licensee
documents:
Technical Specification,
Section
6, Administrative Controls
Ginna station administrative
and engineering staff responsibilities,
procedure
A-201, Revision
20
Ginna Fire Protection
Plan Revision
0
ltS
Ginna
The scope of review was to ascertain
that:
Personnel
were designated
for implementing the fire protection
program at
the plant and the qualifications of these
persons
were delineated.
No unacceptable
conditions were identified.
3.2
Administrative Controls of Combustibles
The inspector
reviewed the following'document:
Bulk storage
of combustible materials
and their use,
Procedure
A-804, Revision 7.
The scope of review was to verify that the licensee
had developed
administrative controls which included:
a.
Special authorization for the
use of combustible,
flammable or other
hazardous
material
in safety related areas;
b.
Prohibition
on the storage
of combustible,
flammable or other
hazardous
material
in safety related areas;
c.
The removal of all waste,
debris,
rags, oil spills or other
combustible material resulting
from the work activity or at the
end
of each work shift, whichever is sooner;
d.
All wood used in safety related
areas
to be treated with flame
retardant;
e.
Periodic inspections
for accumulation of combustibles;
f.
Transient combustibles
to be restricted
and controlled in safety
related
areas;
and
g.
Housekeeping
to=be properly maintained
in areas
housing safety
related
equipment
and components.
No unacceptable
conditions were identified.
3.3
Administrative Control of I nition Sources
The inspector
reviewed the following licensee
document:
Open flame, welding and grinding permit,
Procedure
A-905, Revision
13.
The scope of review was to verify that the licensee
had developed
administrative controls which included the following:
Ginna
a.
Requirements
for special
authorization. (work permit) foi activities
involving welding, cutting, grinding,
open flame or other ignition
sources.
Requirements -that these activities are properly .
safeguarded
in areas
containing safety related
equipment
and
components;
and
b.
Prohibition
on smoking in safety related areas,
except where
"smoking permitted"
areas
have
been specifically designated
by
plant management.
No unacceptable
conditions
were identified.
3.4
Other Administrative Controls
The inspector
reviewed the following licensee
documents:
Technical Specification Section
6, Administrative Controls
Fire Protection
Program
Plan
The scope of the review was to verify that the licensee
had developed
administrative controls which require that:
a.
Work authorizatio'n,
construction
permit or similar arrangement .is
provided for review and approval of modification, construction
and
maintenance activities which would adversely affect the safety of
the facility;
b.
Fire brigade organization
and qualifications of brigade
members
are
delineated;
c.
Fire reporting instructions for general
plant personnel
are
developed;
d.
Periodic audits are to be conducted
on the entire fire protection
program;
and
e.
The fire protection/prevention
program is included in the licensee's
gA program.
No unacceptable
conditions
were identified.
3.5
E ui ment Naintenance
Ins ection
and Tests
The inspector
reviewed the following selected fire program related
documents
to determine
whether the licensee
had developed
adequate
pro-
cedures
which established
maintenance,
inspection
and testing
requirements
for the plant fire prot'ection
equipment:
r
8
Ginna
~
7
Procedure
PT-13.4.29,
Halon system te'sting, relay room,
Procedure
PT-13.4.26,
Multimatic valve testing,
suppression
system
S-29, control
room wall auto spray,
Procedure
PT-13.4.20,
Flood-valve testing,
suppression
system S-09,
relay room
SE Manual deluge,
Procedure
PT-13.4. 11, Multimatic valve testing,
suppression
system
S-05 cable tunnel auto deluge,
Procedure
PT-13.4.5
Flood valve testing,
suppression
system
S-13,
1B diesel
generator
preaction
system,
Procedure
PT-13.3,
Fire
pump electrical
equipment surveillance,
Procedure
PT-13.2,
Diesel fire pump standard
protection test,
Procedure
PT-13, Fire
pump operation
and system alignment.
The inspector also reviewed the inspection/test
records,
to verify
compliance with the Technical Specifications
and established
procedures.
No unacceptable
conditions were identified.
In addition to the above the inspector
requested
the results of tests
to
verify damper operability under air flow conditions.'he
inspector
wanted to verify that the fire dampers
can close if a fire occurs
when
the air supply and return fans are running.
This is
a concern
brought to
the NRC's attention
by Ruskin Inc.,
a damper manufacturing
company,
via a
letter required
by 10CFR 21.
The specific concern is that dampers
may
not close
under air flow conditions.
The licensee
stated that although they are familiar with this concern
these tests
have not been
performed.
The licensee
stated that they did
not receive this letter.
The inspector verified that the licensee did
not receive this letter and stated that this letter will be attached
to
the inspection report.
Enclosure
1 of this report is
a copy of the
letter sent to the
NRC by Ruskin.
The licensee
committed to review the
letter for applicability and act accordingly.
This is an unresolved
item
(88-24-02).
3.6
Fire Bri ade Trainin
The inspector
reviewed training documents
and procedures
to verify that
the training given to the fire fighters includes:
a
~
b.
C.
Requirements
Requirements
Requirements
frequencies;
d."
Requirements
"back shift"
e.
.Requirements
for initial classroom
and "hands
on" training;
for announced
and unannounced drills;
for fire brigade training and retraining at specified
for at least
one drill per year to be performed
on the
for each brigade;
for maintenance
of training records.
Ginna
The documents
reviewed were:
Procedure
A-103.9 Fire brigade training:
Lesson
plan - Fire brigade initial training,
LP.
No.
FFB19C.
Lesson
plan
Hazardous materials,
LP. No.
FFB17C
In addition to the above listed documents
the inspector
reviewed the
training records to verify that the fire fighters receive all required
training.
This review identified the following unacceptable
condition:
The licensee's
operating license requires that preplanned fire drills be
conducted
at quarterly intervals for all shift brigades.
This
requirement
has
been
imposed
by license condition C.3 which requires that
the fire brigade training is as described
in the
NRC Safety Evaluation
dated
February
14,
1979.
The inspector
observed that the licensee is
crediting shift brigades with drill attendance
when the brigade
responds
to a fire alarm.
The records
review determined that during the first
quarter of 1988, four out of five shifts did not participate
in a
preplanned drill, two out of five shifts in the
second quarter
and three
out of six shifts in the third quarter did not participate in preplanned
drills,
This practice to credit the brigades with drill attendance
when
responding to
a fire alarm is contrary to the license
requirement
which
stipulates that fire drills be preplanned,
post critiqued
and
be
conducted with established
training objectives.
This is a violation of
the license condition (88-24-03).
With regard to this violation, the licensee
assured
the inspector during
the exit interview that during the fourth quarter of 1988 all shift
brigades will participate in preplanned drills.
An additional
concern
regarding training was raised
by the inspector
when it was noted that the
licensee
gives three different types of initial training to perspective.
brigade
members.
Some fire fighters attend
the Niagara
Mohawk fire train-
ing school for training that lasts four days,
others attend the Rochester
Fire Academy for one day of training and others. attend
the licensee's
own
initial training program which also lasts
one day.
The latter training is
composed of four hours of classroom training and four hour s of practical
experience.
The inspector
expressed
the concern that four hours of hands
on practice
may not be adequate
training for individuals with no prior.
fire fighting experience
to enter
a burning building.
3.7
Periodic Ins ections
and
ualit
Assurance
Audits
The inspector
reviewed the following audits:
Audit of the Ginna Fire Protection
program, Audit No. 86-30
Ginna station triennial fire protection audit, Audit No. 87-35
Audit of the Ginna station fire protection
program, Audit No. 88-27
r
Y
8
I
~
Ginna
The
scope of review was to verify that the audits were conducted
in
accordance
with the Technical Specification 6.5.2.8.g,
h and i.
This
TS
requires that the fire protection
program
be audited every twenty-four
months,
every twelve months
and every thirty-six months.
The inspector
observed that the audit plans
and execution
could have
been
better documented.
This observation
was based
on the fact that the plans
and audit findings were
hand written and not easily understood.
In
addition,
some findings were corrected at the
scene
by plant personnel
accompanying
the auditors.
These findings were not included in the final
audit report.
Therefore,
the opportunity for trending
and learning from
the audit findings can
be lost.
The inspector interviewed the auditor who performed the latest fire
protection
program audit.
The auditor did not use the guidance
issued
by
NRC in Generic Letter 82-21 Subject:
Technical Specification for fire
protection audits.
The interview was conducted
because
the inspector
could not find evidence that the fire protection audits included reviews
for all areas
described
in the fire protection
gA program
and to which the
licensee is committed.
For instance,
the audits did not contain
a review
of design controls or a review of the controls for purchased
material.
The auditor stated that audits in the engineering
and purchasing
areas
perform these
reviews.
The auditor stated that future fire protection
program audits
wi 11 address
point by point the areas
indicated in the
Generic Letter.
No other
unacceptable
conditions
were identified.
3.8
The inspector
examined fire protection water systems,
including fire
pumps, fire water piping and distribution systems,
post indicator valves,
hydrants
and the contents of hose
houses.
The inspector toured
accessible
vital and non-vital plant areas.
He examined fire detection
and alarm systems,
automatic
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 of portable extinguishers for evidence of periodic
inspections.
No deterioration of equipment
was noted.
The inspection
tags indicated that periodic inspections
were performed
on
a monthly
basis.
The tour identified the following conditions that require additional
attention
by the licensee:
In certain plant areas,
housekeeping
can
be
improved.
For instance,
the inspector
observed
wooden pallets
on the
turbine building floor.
The licensee
personnel
stated that the pallets
will be removed.
The inspector
observed that the licensee
has placed the
gasoline
and diesel
fuel storage
tanks in an area that is sufficiently
removed
from the plant buildings to prevent
a fire hazard.
This is ac-
ceptable;
however,
consideration
should
be given to diking this area to
Ginna
10
contain
any fuel spills.
In addition, the inspector
observed that the
tanks were placed close to each other, possibly
impeding fire fighting
efforts.
The need for a dike and the minimum spatial distance
between
fuel storage
tanks is specified in the National Fire Protection
Association
(NFPA) guidance.
The inspector also observed that the fire door between
the Turbine
building and Technical
Support Center would not always close
automatically.
The licensee
stated that this concern
has
been previously
identified and the problem is the pressure differential that exists
between
the two buildings.
The licensee is currently looking for a
permanent
solution to this concern.=
During the plant tour, the inspector
examined the
scene of a fire that
occurred
on November
15,
1988.
The fire was the result of a faulty trans-
former in an electrical cabinet in the security uninterrupted
power supply
area.
The fire did not affect safety related or safe
shutdown
equipment.
A concern with this event
was that the Halon system failed to activate
because
of an improperly installed detection system.'or
the Halon system
to activate, it requires
two out of two detectors
to alarm.
Only one of
the detectors
alarmed,
therefore
the Halon system did not activate.
The
reason
the
second detector did not alarm was that it was improperly
located.
The detector
was placed
away from the vent path of the air
exhaust
vent and the rising column of the products of combustion
was
directed toward the vent, therefore,
the detector
would not detect
the
fire.
The licensee
stated that two more detector s will be installed in
this room to prevent reo'ccurrence.
The licensee
also stated that this was
the only area
where there were only two detectors.
They indicated that
this was
an isolated incident not likely to reoccur elsewhere
in the
plant.
With the exception of the items requiring additional consideration
described
above,
no unacceptable
conditions were identified.
4.0
Unresolved
Items
Unresolved
items are matters requiring additional
information in order to
determine
whether they are acceptable,
violations or deviations.
Section
2 of this report provides the resolution to
a previously identified
unresolved
item.
Unresolved
items disclosed
during the inspection
are discussed
in section
3.5 and 3.6 of this report.
Ginna
5.0, Exit Interview
The inspector
met with the licensee
management
representatives
(see
section
1.0 for attendees)
at the conclusion of the inspection
on,
November
17,
1988.
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 information.
The licensee
agreed that the report
may be placed in the public document
room without prior licensee
review for proprietary information
At no time during the inspection
was written material
provided to the
licensee
by the inspector.