IR 05000293/1992027
| ML20126L876 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/29/1992 |
| From: | Bettenhausen L, Blumberg N, Finkel A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20126L842 | List: |
| References | |
| 50-293-92-27, NUDOCS 9301080143 | |
| Download: ML20126L876 (9) | |
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{{#Wiki_filter:..... - _ - - - .- . -.. -- -_ - . _ d .[ .. U.S. NUCLEAR REGULATORY COMMISSION -
REGION I
REPORT NO.
50-293/92-27 DOCKET NO.
50-293 . LICENSE NO.
DPR-35 LICENSEE: Boston Edison Company RFD # 1 Rocky Hill Road Plymouth, Massachusetts 02360 ., FACILITY: Pilgrim Nuclear Power Station INSPECTION AT: Plymouth, Massachusetts INSPECTION DATES: November 2 - 6,1992 .. . 27 /f/ M LEAD INSPECTOR: - A'. Finkel, Sellior Reactor Engineer Date ' Performance Programs Section !h j 2-{L1/9 L ' [ <, REVIEWED BY: - Norman J. Ilumberg, Chief / Date.-
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Performance Programs Section ' Operations Branch, DRS. APPROVED BY: _ Y= M /2/A9/fL -- M H. Betteiihausen, Chief Date Operations Branch Division of Reactor Safety _ INSPECTION SUMMARY: Inspection on November 2 - 6,1992 (Inspection Report No.
50-293/92-27) , Areas Inspected: Announced safety inspection of the Fire Protection Program and its. ~ 9301000143 921230 PDR ADOCK 05000293 G PDR . __ .1._ - _ 2.
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. _ _.. -_. .. ... ... - -_-.- - -. - -. -....-. - - -. -. -. ,4 . , ._ 2- ' implementation in the areas of Administrative Controls, Training and Drills,= Fire Watches, Combustibles Controls and Work Order 11acklogs, Surveillances and Audits, _ , Results: The inspector verified that the fire equipment was in'workirig order, surveillance -- tests were performed on schedule, and that fire brigade training was given as required by the Technical Specification. The inspector determined that the fire protection audit program was well performed with findings notified to management for action; however, one violation was identified.- The violation with two examples dealt with the fire protection program identifying fire design dcficiencies that were not acted upon by. management in a timely.
- _ _ manner. - The lack of fireproofing material on structural steel in various locations within the ' reactor building ceiling was identified in 1984 and the installation of the fire diesel day tank sight glass not in accordance with the NFPA code was identified in 1988 with no corrective action taken on either item.
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DETAILS 1.0 - PEllSONS CONTACTED Attachment 1 provides a listing of persons contacted during the inspection.
2.0 FiltE PitOTECTION PROGitAM (64704)' 2.1 Introduction An inspection was performed to assess the adequacy of the licensee fire protection program and associated implementing procedures. The inspection included verincation of procedure implementation, technical adequacy of procedures and programs, inspection of plant facilities, adequacy of Gre brigade training and qualification and review of previous licensee audit findings. Surveillance tests, routine tests, and procedures related to Gre protection were reviewed with respect to administrative requirements for an effective fire protection program.
2,2 Plant Tour During the plant tour, the inspector walked down accessible vital and nonvital areas of the-plant and visually _ inspected the fire protection water systems, fire pumps, fire water piping and distribution systems, post-indicator valves, hydrants, and contents of yard fire station houses. The inspection included area fire detection and alarm system, automatic and manual fixed suppression systems, interior hose stations, fire barriers, penetration seals, and fire L doors. The inspector also observed general housekeeping conditions and randomly checked L location of portable fire extinguishers to verify that the required monthly surveillance inspections were performed, and that the specified type of extinguishers were at their-identified location. The inspector observed that fire hoses had the proper color code for the latest test cycle; battery-powered lights were working; fire doors were closing and latching; L firefighting clothes and equipment were in an acceptable' condition; and the diesel fire pump: l day tank was verified full.
During the tour of the reactor building 23-foot level, the inspector observed sections of tireproofing material were' missing from approximately ten structural steel ceiling locations; i Also, while inspecting the pump house, the ingaar determined that the diesel fire pump - fuel oil storage timk sight gage instaMon was not designed in accordance with the NFPA 20 p code for this type of insts'.iation. Safety Evaluation Report (Amendment No. 35) stated that - L fireproofing material would be installed on the Reactor lluilding steel ceiling while the fire _ program endorsed the NFPA No. 20 for the installation of the fire diesel _ oil day tank. These-- items are further discussed in paragraphs 2,2.1 and 2.2.2.
l I 'The parenthetical notation following the paragraph title denotes the NRC. inspection procedure that was used by the inspector in conducting this inspection. - The procedure title is , L " Fire Protection / Prevention Program."
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2.2.1 Fire Proofing Mnterint On Structural Supports NRC Fire Protection Safety Evaluation Peport (SER Amendment No. 35, December 1978) directed the licensee to provide Greprot.ng on structural steel in certain areas of the reactor building. The inspector noted that site management was notified of the lack of fireproofing material in various locations of the Reactor Building ceiling during fire and quality audit inspection reports issued in 1984. This deGeiency was also documented in Quality Asurance Deficiency (QAD) Report 1306, which was issued on October 24,1984. The above QAD was tracked in the quality control system via Maintenance Corrective Action Report No.
(MCAR 88-001a). This item was identified again in the licensee's audit report No. 90-30, " Fire Protection Program Triennial Audit," December 5,1990. This same QAD No.1306 was also highlighted in the " Annual and Biannual Audit No. 91-45." The repair of the Reactor Building ceiling began on. November 6,1992. The inspector observed a repair to one of the ceiling locations. The work was done to an approved maintenance work order with quality inspection hold poims identified. The failure to repair the fire proofing ceiling material since first being identified in 1984 is a violation for failure to take prompt corrective action as required by 10 CFR Part 50. Appendix B,-Criterion XVI, Corrective Action (50-293/92-27-01). This is example No. One of this violation. Example No. Two is discussed in paragraph 2.2.2.
2.2.2 Diesel Fire Pump Fuel Oil Storage Tank The diesel fire pump fuel oil storage tank is equipped with a glass sight gage tube that had been used to determine the oil level in the tank. National Fire Protection Association (NFPA) Code No. 20 states that, "Means other than sight tubes shall be provided for determining the amount of fuel in each storage tank."
The fire protection engineers issued a request to have this condition corrected and the item brought into code requirements as documented in 1988 by Engineering Report (ESR) 88-407.
During the " Fire Protection Program Triennial Audit," No. 90-30, the lack of meeting the NFPA code was identified to licensee management as Observation No. 2 in this audit. The audit also referenced 1988 Maintenance Reports (MRs 88-33-51 and 88-33-161) that described design problems with this installation. The inspector noted that this de6ciency is scheduled to be corrected by the end of December 1992. The verification that the fire diesel fuel oil tank is Olled is performed by operations personnel on each shift. The diesel Gre fuel pump is run until a tank high alarm is received in the control room indicating that the tank is full. This test is performed per the requirements of Procedure 8.B.1, " Diesel Engine Fire Pump Day Tank Fuel Transfer." The present installation had a sight glass mounted on the front of the day tank to indicate the oil level. This sight glass was continuously being broken; to prevent oil leakage, the licensee has valved it out of the system. Verification that the tank is full of fuel oil is performed by the operations personnel as described above.
The failure to correct the diesel fire pump fuel oil storage tank design to meet NFPA Code No. 20 requirements since 1988 is considered a violation to take prompt corrective action as _
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required by 10 CFR 50 Appendix II, Criterion XVI, Corrective Action (50-293/92 27-01).
This is example No. Two.
3.0 FIRE PROTECTION PR( ..AM PLAN The present fire protection plan, NOP83FP1, July 1,1988, as required by the Technical Specification (TS), Final Safety Analysis Report (FSAR) and the Quality Assurance Program , complies with these documents in the management of the program and the technical-performance of the fire design and system operation. A recent revision to the fire protection plan organization has the fire protection personnel reporting to a Balance of Plant (BOP) Lead System Engineer who reports to the Mechanical Systems Engineering Division < Manager. Other than the above organizational change, the fire protection plan requirements of NOP83FPI dated July 1,1988, remains the same.
4.0 FIRE IIRIGADE TRAINING AND DRILLS i Fire department training procedures and attendance records for brigade member are maintained by the training school. The inspector verified that the fire brigade members listed on the 1992 roster have attended their required hands-on training programs as well as completed their required classroom courses as described in Procedure No.1.4.23, " Fire 13rigade Training Drill," November 17, 1989, Revision 12.
Fire drills are conducted on a quarterly basis so that each fire brigade member participates m ' two drills per year. The inspector selected three drills from the 1991 and 1992 drill list for review. During a review of the drill critique sheets from 1991, the inspector noted that the. _ three security members of the five member fire brigade took 17 minutes to respond (Drill date 1/8/91) and two security members of the five member brigade took 15 minutes to respond (Drill date 2/28/91) while the rest of the fire brigade was at their required location within the licensee's ten minute time frame. A ten minute time limit for brigade response is
- is discussed in the fire training program but is not specified in any fire program'
documentation.
The fire brigade chief, on the January 8,1991, drill, determined that he and the deputy could attack the fire without the three security members of ths fire brigade being there. The fire brigade chief, on the February 28,1991, drill determined that the deputy and one security-L guard would fight the fire withoiit the presence of the other two security guards, in each of the above drills, the Fire Drill Evaluation sheets identified that the guards were: not on time to assist the fire brigade leader in meeting the drill objectives. Corrective
( actions were implemented by the fire protection personnel to insure that the security guards arrived within their assigned drill times to support the fire brigade.
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5.0 FIRE WATCil PROGRAM The fire watch program is described in Procedure 8,b.14, " Fire Watch." A Gre watch person is required to. verify, on an hourly basis, the areas listed in the fire watch log. ~ Each day, the fire watch log listing is updated with fire zones identified and the required duties listed.-
During the site tour, the inspector encountered four fire watch persons. In each case, the fire watch personnel were knowledgeable of their area requirements and knew what actions to take if they encountered a problem during their rounds.
, The inspector reviewed the control room log from July 1992 through November 5,1992. No ' safety signincant fires were reported in the control room log or in the fire protection history.
fiics. The control room log identified a minor fire on October 4,1992, at approximately.
12:30 hours. The Gre was located in a computer room surge suppressor power connector that was used to protect the computer equipment. The fire brigade was not activated to extinguish this fire. The fire extinguished itself with the loss of power to the surge suppressor and no fire fighting equipment was required. The results of this fire were well documented in the Fire Protection documentation system. No safety system was involved in the area that the - fire took place.
6.0 COMilUSTIllLE MATERIAL / MAINTENANCE WORK ORDER CONTROLS The combustible loading for each nre zone within the site has been compiled and is updated in the " Updated Fire Hazards Analysis" report No. 89XM 1.ER-Q. The inspector, following the requirements of Procedure 8.B.20, " Combustible Loading Inspection," inspected various areas of the plant and determined that the licensee's fire program was meeting the - requirements of this procedure. A maintenance work order (M*0) computer listing is issued weekly. This listing has the fire protection MWO listed under i.cc system cede 33. The. inspector reviewed system 33 open MWOs and conducted discussions of the listed items with the Fire Protection Engineer. Of the 10 maintenance work orders reviewed with the Fire Protection Engineer (FPE), the inspector determined that the FPE was knowledgeable of the g impact these MWOs had on the fire system configuration and he had ensured that, for these items reviewed, no additional fire protection was required. The backlog of fire protection: system related MWOs appears to be well controlled by the Fire Protection Engineer and not-excessive at this time. - A review of approved MWO documentation verified that the Fire ~ Protection Engineer had reviewed and signed the documents as part of the review cycle;
Findings identified in fire protection and quality assurance audit reports have been resolved in a timely manner except for the audit findings described in paragraph 2.2.1 of this report.
' 7.0 SURVEILLANCE TEST (ST) REVIEW L - The nre ;)totecdon m-illance testine schedules are maintained as described in the Fire . l Protection Plan, NOP83FP1, July 1,1988, and proceaures listeu m um ih PMdm Index. In reviewing selected procedures and the test results associated with these documents, . the inspector was able to verify that the surveillance testing that was performed on the fire l l l- > __ __ _ _ _ - _ ~ . .
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._ _ _ _ _. _. _ .._ ._ .. . c. <: ..: 7~ . protection equipment was determined to be acceptable as required by..the site technical specification. The inspector verified that the weekly tests were performed on the diesel engine driven fire pump and the electric fire pump. In reviewing the test results of Procedure 8.B.1, " Fire Pump Test," and Procedure 8.B.15, " Fire Pump 150% Capacity Test," the ' inspector determined that the fire equipment met its procedure and Technical Specification requirements.
8.0 EXIT MEETING The inspector met with licensee personnel (denoted in Attachment 1) at the conclusion ~of the inspection, on November 6,1992, at the Pilgrim Nuclear Power Station. The inspector summarized the scope of the inspection and the inspection findings at that time.
Attachments: 1. Persons Contacted 2. -Fire Protection Documentation Reviewed , i
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8 NITACIIMENT 1 Persons Contacted-Iloston Edison Company .
- G. Basileco,-Senior Compliance Engineer
- J. Bellefeuille, Technical Section Manager
- S. Bibo, Quality Assurance Division Manager
- S. Burke, Senior Mechanical Engineer
- P. Burrows, Fire Protection Program Engineer
- P. Cafarella, Mechanical Systems Engineering Division Manager
- R. Cannon, Compliance Division Manager
'E. Kraft, Jr., Plant Manager
- R. MacKinnon, Fire Protection Engineer
- C. McMorrow, Senior fire Protection Engineer
- H. Oheim, Manager of Regulatory Affairs
- D. Pierce, Lead System Engineer
- W. Rothert, Director, Nuclear Engineering
- J. Sulllivan, Senior Quality Assurance Engineer United States Nuclear Regulatory Commissinn J. MacDonald, Senior Resident Inspector
- D. Kern, Resident Inspector
- Denotes those at the exit meeting held on November 6,1992.-
During the course of this inspection, the inspector contacted other members of the licensee's a Technical, Quality Assurance, Fire Protection, and Training staffs.
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ATTACllMENT 2 Fire Protection Documentation Reviewed Fire Protection Procedures NOP83FP1, Revision 3, " Fire Protection Program" 8.B.13.1, " Hydrostatic Testing of Fire Hose" M-505, " Structural Steel Fire Proofing" M-570, " Fire Barrier Penetration Seal System" M 506, " Fire Door Systems" 1.4.3, " Storage of Flammables and Combustibles" -- 1.4.23, " Fire Brigade Training Drill" 3.M.4-72, " Diesel Fire Pump Engine Maintenance" 8.B.14, " Fire Watch (and LCO Guidelines)" 8.B.20, " Combustible Loading Inspection" 8.B.1, " Diesel Engine Fire Pump Day Tank Fuel Transfer" 5.5.1, " General Fire Procedure" 8.B.1, " Fire Pump Test" 8.B.15, " Fire Pump 150% Capacity Test" Fire Audit Reports QAD-92-019, " Audit Report No. 91-55 Annual and Biennial Fire Protection," October - December 1991 No. 90-30, " Fire Protection Program Technical Audit," December 5,1990 _ General Documentation Fire Equipment MR Backlog Status - Report No MWD 15012 Fire Watch Reports - T-001 QAD No.1306,1985 MCAR No. 88-00la ESR No. 88-407 MR Nos. 88-33-51, 88-37, 88-33-161, and 90-33-171 NRC Regulatory Guide 1.8, May 1977, " Personnel Selection and Training" American. Nuclear Society Institute (ANSI) N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel" Technical Specification Section 6.0 NRC Safety Evaluation Report (SER), Amendment No. 35, December 1978 _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ ____ - __ _ _ _ - _ _ _ }}