IR 05000352/1985039
| ML20136D818 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/07/1985 |
| From: | Anderson C, Pullani S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20136D792 | List: |
| References | |
| 50-352-85-39, NUDOCS 8511210374 | |
| Download: ML20136D818 (9) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-352/85-39 Docket No.
50-352 License No.
NPF-39 Priority Category C
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Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:
Limerick Generation Station, Unit 1 Inspection At:
Limerick, Pennsylvania Inspection Conducted-ctobeF 7 M, 1985 Inspector:
/ OUI /aM/
// 07'65 37V.Pulla[i, FirerotectionEngineer date Approved By:
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a C. J. An# rson, Chief, Plant Systems Section date Inspection Summary:
Inspection on October 7-11, 1985 (Report No. 50-352/85-39)
Areas Inspected:
Routine unannounced inspection of the Fire Protection /
Prevention Program including:
program administration and organization; administrative control of combustibles; administrative control of ignition sources; other administration controls; equipment maintenance, inspection and tests; fire brigade training; periodic inspections and quality assurance audits; and facility tour. The inspection involved 44 inspector-hours on site and 9 inspector-hours in office by one region based inspector.
Results: Of the eight areas inspected, no violations were identified.
Two item remained unresolved at the end of the inspection (see Section 2.6.2 for details).
8511210374 851115 ADOCK 0%y2 PDR O
Region I Form 12 (Rev. February 1982)
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DETAILS 1.0 Persons Contacted 1.1 Philadelphia Electric Company (PECO)
- C. Endriss, Regulatory Engineer
- G. Leitch, Plant Manager
- A. Mount, Fire Protection Assistant
- J. Rubert, QA Supervisor
- V. Warren, Test Engineer 1.2 Nuclear Regulatory Commission (NRC)
J. Beall, Project Engineer, RI
- T. Johnson, Senior Resident Inspector (Peach Bottom)
- Denotes those present at the exit interview.
2.0 Fire Protection / Prevention Program 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 Fire Hazard Analysis (FHA), Final Safety Analysis Report (FSAR), and Technical Specifications (TS). The documents reviewed, the scope of review, and the inspection findings for each area of the program are described in the following sections.
2.1 Program Administration and Organization The inspector reviewed the following licensee documents:
Technical Specifications, Section 6, Administrative Controls
A-92, Plant Fire Protection Program Responsibilities, Revision 0
The scope of review was to ascertain that:
Personnel were designated for imple'menting the program at site; a.
and b.
Qualifications were delineated for personnel designated to implement the program.
No unacceptable conditions were identifie _ _
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2.2 Administrative Control of Combustibles The inspector reviewed the following licensee documents:
A-12.2, Control of Combustible Materials, Revision 0
A-30, Administrative Procedure for Plant Housekeeping, Revision 2
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The scope of review was to verify that the licensee had developed administrative controls which included:
a.
Special authorization for the use of co,bustible, flammable or explosive hazardous materials in safety-related areas; b.
Prohibition on the storage of combustible, flammable or explosive hazardous material in safety-related areas; c.
The removal of all wastes, debris, rags, oil spills or other
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combustible materials 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 inspection for accumulation of combustibles;
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Transient combustibles to be restricted and controlled in safety-related areas; and
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Housekeeping to be properly maintained in areas containing
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safety-related equipment and components.
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No unacceptable conditions were identified.
2.3 Administrative Control of Ignition Sources The inspector reviewed the following licensee documents:
A-12, Ignition Source Control Procedure, Revision 1
A-30, Administrative Procedure for Plant Housekeeping, Revision 2
The scope of review was to verify that the licensee had developed
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administrative controls which included:
a.
Requirements for special authorization (work permit) for activities i
i involving welding, cutting, grinding, open flame or other ignition sources and that they are properly safeguarded in areas contain-ing safety-related equipment and components; and
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Prohibition on smoking in safety-related areas, except where
" smoking permitted" areas had been specifically designated by plant management.
No unacceptable conditions were identified.
2.4 Other Administrative Controls The inspector reviewed the following licensee docuaents:
Technical Specifications, Section 6, Administrative Controls
A-14, Procedure for Control of Plant Modifications, Revision 2
SE-8, Special Event Procedure - Fire, Revision 2
Quality Assurance Plan, Volume III, Operations Phase, Revision 4
The scope of review was to verify that the licensee had developed administrative controls which included:
a.
Work authorization, construction permit or similar arrangement is provided for review and approval of modification, construction and maintenance activities which could 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.
Fire protection / prevention program is included in the licensee's QA Program.
No unacceptable conditions were identified.
2.5 Equipment Maintenance, Inspection and Tests The inspector reviewed the following randomly selected documents to determine whether the licensee had developed adequate procedures which established maintenance, inspection, and testing requirements for the plant fire protection equipment:
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- ST-6-022-251-0, Fire Suppression Water System Motor Drives Pump
Flow Test, Revision 2
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- ST-6-022-252-0, FSWS Diesel Driven Pump Flow Test, Revision 2
- ST-6-022-450-0, Fire Suppression Water System Valve Lineup
Verification, Revision 6
- ST-6-022-451-0, Low Pressure CO Lineup Verification, Revision 4
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- ST-6-022-453-0, Halon System Lineup Verification, Revision 2
- ST-7-022-925, Fire Door Closing Mechanism Inspection, Revision 2
ST-7-022-953, Hose Cart Visual Inspection, Revision 3
In addition to reviewing the above documents, the inspector reviewed the maintenance / inspection / test records of the items identified by an asterisk (*) to verify compliance with Technical Specifications and established procedures.
No unacceptable conditions were identified.
2.6 Fire Brigade Training 2.6.1 Procedure Review The inspector reviewed the following licensee procedures:
A-92, Plant Fire Protection Program Responsibilities,
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Revision 0
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A-50, Procedure for Conduct of Station Training,
Revision 0 and its Appendix E, Revision 0 The scope of review was to verify-that the licensee had developed administrative controls which included:
a.
Requirements for announced and unannounced drills;
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Requirements for fire brigade training and retraining at prescribed frequencies; c.
Requirements for at least one drill per year to be
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performed on a "back shift" for each brigade; i
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Requirements for local fire department coordination and training; and e.
Requirement for maintenance of training records.
No unacceptable conditions were identified.
2.6.2 Records Review The inspector reviewed randomly selected training records of fire brigade members for calendar year 1985 to ascertain that they had successfully completed the required quarterly training / meeting, semiannual drill, and yearly hands-on fire extinguishment practice.
No unacceptable conditions were identified, except as follows:
a.
Quarterly Meeting for Fire Brigade Members Facility Operating License Condition 2.c.(3) requires that the licensee maintain all provisions of the approved fire protection program as described in the Fire Protection Evaluation Report (FPER) through Revision 6.
The FPER, Revision 6, Section 3.2, commits to 10 CFR 50, Appendix R, Section III.I.
10 CFR 50, Appendix R, Section III.I, Paragraph 1.d requires that regular planned meetings shall be held at least every 3 months for all brigade members to review changes in the fire protection program and other subjects as necessary. The licensee regularly holds the quarterly meetings as required. However, of the 8 fire brigade members whose training records were reviewed (total of 59 fire brigade members in the plant), none attended all 3 quarterly meetings in the first three quarters of calendar year 1985 (5 attended only 1 meeting and 3 attended none).
Although the licensee met the requirements by holding the quarterly meetings as required, the intent of such meetings is not met if a significant number of people do not attend the meetings.
The licensee indicated that due to differing shift rotation among the fire brigade members and due to vacation and other leave considerations, it will be impractical to require every fire brigade member to
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attend every scheduled meeting. However, the licensee
committed to immediately (and regularly thereafter)
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- review the training records of all fire brigade members and arrange makeup meetings for those who missed the scheduled meetings.
If a makeup meeting is not prac-ticable, they will be required to review the minutes of the meeting, view the videotape of the meeting or complete an acceptable alternative training. The licensee promptly initiated a revision of Administra-tive Procedure RT-7-022-981-0, Quarterly Fire Brigade Meeting Review, Revision 0, to reflect the above com-mitments. The licensee further committed to complete the above actions by December 31, 1985.
This is an unresolved item pending completion of the licensee action and its review by NRC (50-352/85-39-01).
b.
Semi-Annual Drills for Fire Brigade Members 10 CFR 50, Appendix R, Section III.1, Paragraph 3.b, requires that drills shall be performed at regular intervals not to exceed 3 months for each shift fire brigade.
Each fire brigade member should participate in each drill, but must participate in at least two drills per year.
Therefore, the minimum requirement is two drills per year for each fire brigade members. Although this minimum requirement could be met by each member participating in any two drills during the year, the affectiveness of the training would be compromised if the two drills are too close together. The licensee understands this position.
It was noted that, of the 8 fire brigade members whose training records were reviewed, 2 did not receive any drills during the first +,hree quarters of calendar year 1985. As stated before, the minimum requirements for these two members could be met by having them participate in 2 drills during the remaining 3 months of calendar year 1985. However, the effectiveness of the training could be compromised. To increase the effectiveness of the training, the licensee committed to immediately (and regularly thereafter) review the training records of all fire brigade members to ensure that they receive the 2 minimum required drills suf-ficiently spread apart during any year.
The licensee promptly initiated a draft Administrative Procedure RT-7-022-983-0, Fire Brigade Drill Review, to adminis-tratively control the routine review of the training records and ascertain that the drill requirements were
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met and that the 2 minimum required drills are in different halves of the year.
For those fire brigade members who had not already completed 2 minimum re-quired drills during the current year, the licensee will conduct the drills as soon as practical but before the year is over.
The licensee also committed to complete all related actions by December 31, 1985.
This is an unresolved item pending completion of the licensee actions and their review by NRC (50-352/
85-39-02).
2.7 Periodic Inspections and Quality Assurance Audits 2.7.1 Annual Audit In accordance with TS 6.5.2.8.1, an independent fire pro-tection and loss prevention inspection and audit shall be performed at least once per 12 months utilizing either qualified offsite licensee personnel or an outside fire protection firm. As the Operating License (fuel load and low power testing) was issued on October 26, 1984, the first such audit will be due on October 26, 1985.
The licensee has plans to conduct such an audit during October 15-17, 1985.
The inspector brought to the attention of the licensee that NRC Generic Letter 82-21, dated October 26, 1982 and addressed to all licensees and applicants of nuclear power reactors, provides guidance on annual, biennial and triennial audits required by the TS and discussed in Sections 2.7.1, 2.7.2 and 2.7.3 of this report.
No unacceptable conditions were identified.
2.7.2 Biennial Audit The inspector reviewed the report of the following audit:
AL84-81 PL, performed on October 25-November 29, 1984
The review was to verify that the audit was performed in accordance with TS 6.5.2.8.h. and the audit findings were being resolved in a timely and satisfactory manner.
No unacceptable conditions were identifie.
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2.7.3 Triennial Audit In accordance with TS 6.5.2.8.j, an inspection and audit of the fire protection and loss prevention program shall be performed by an'outside qualified fire consultant at inter-vals no greater than 36 months. As the Operating License was issued on October 26, 1984, the first such audit will be due on October 26, 1987. The licensee has established plans to conduct such audits as contained in their Fire Protection Plan, Revision 0, Section 8.5.2.
No unacceptable conditions were identified.
2.8 Facility Tour l
The inspector examined fire protection' water systems, including fire pumps, fire water piping and distribution systems, post indicator valves, hydrants and contents of hose houses. The inspector toured accessible vital and nonvital plant areas and 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 cnecked tags of portable extinguishers for evidence of periodic inspections.
No unacceptable conditions were identified.
3.0 Unresolved Items Unresolved items are matters about which more information is required to ascertain whether they are acceptable items, violations or deviations.
Unresolved items disclosed during the inspection are discussed in Section 2.6.2.
4.0 Exit Interview The inspector met with licensee management representatives (see Section 1.0 for attendees) at the conclusion of the inspection on October 11, 1985.
The inspector summarized the scope and findings of the inspection at that time.
The inspector discussed with the licensee the contents of this inspection report and confirmed that it does not contain any proprietary information.
The licensee agreed that the report may be placed in the Public Document Room without prior licensee review for the proprietary information (10 CFR 2.790).
At no time during this inspection was written material provided to the H
licensee by the inspector.
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