IR 05000237/1989013
| ML17202G481 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/08/1989 |
| From: | Gardner R, Holmes J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17202G480 | List: |
| References | |
| 50-237-89-13, 50-249-89-12, NUDOCS 8906200173 | |
| Download: ML17202G481 (11) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-237/89013(DRS); 50-249/89012(DRS)
Docket Nos. 50-237; 50-249 Licenses No. DPR-19; DPR-25 Licensee:
Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name:
Dresden Nuclear Power Station, Units 2 and 3 Inspection At:
Morris, Illinois Inspection Conducted:
April 3-7 and May 24, 1989 (\\JJA~
Jm Holmes Inspector:
~.~/
Approved By:
Ronald N. Gardner, Chief Plant System Section Inspection Summary JuNE. e) 1989 Date Date Inspection on April 3-7 and May 24, 1989 (Reports No. 50-237/89013(DRS);
50-249/890l2(DRS))
Areas Inspected: Routine, unannounced safety inspection conducted to review the implementation of the licensee's fire protection program including a followup of licensee action on previous inspection findings. This inspection was conducted in accordance with inspection procedures 64704 and 9270 Results:
Of the areas inspected, no violations were identifie One unresolved item and one open item was identified. The unresolved item concerned the need for the licensee to verify the shelf life of two types of fire fighting foam concentrate utilized for flammable liquid fires (Paragraph 3.e). The open item concerned the need to develop a six month functional test for linear detection (Paragraph 3.a). In addition, the inspector identified and discussed with the licensee the need to develop pre-fire plans for areas such as the main power unit transformer area and hydrogen storage tank areas (Paragraph 3.c) and a need to develop a maintenance program for the hydrogen storage equipment and piping (Paragraph 3.d).
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ADOCI< (15000237 F'ttC G DETAILS Persons Contacted Commonwealth Edison Company (CECo)
- C. Schroeder, Services Superintendent
- C. Allen, Performance Improvement Supervisor
- D. Barnett, Senior Quality Assurance Supervisor
- R. Black, Assistant Fire Marshal
- K. Deck, Quality Assurance Engineer
- ,#M. Dillon, Fire Marshal
- R. Falbo, Regulatory Assurance Assistant
- ,#L. Gerner, Production Superintendent
- T. Lewis, Regulatory Assurance
- ,#K. Peterman, Regulatory Assurance Supervisor
- D. Roberts, Fire Protection Engineer
- J. Silady, Nuclear Licensing Administrator
- E. Skoron, Technical Staff Engineer
- S. Stiles, Training Supervisor Sargent and Lundy (S&L)
- Brian Barth, Technical Staff Engineer Nuclear Regulatory Commission (NRG)
- S. DuPont, Senior Resident Inspector
- Denotes those attending the April 7, 1989 exit meetin #Denotes those participating in the May 26, 1989 exit meeting (telecon). Action on Previous Inspection Findings (92701) (Closed) Unresolved Item (237/85033-03(DRS); 249/85029-03(DRS)):
The licensee's surveillance procedure (SP 84-6-39) failed to incorporate appropriate test requirements to demonstrate that the sprinkler system was operable in accordance with NFPA 13 in that the procedure did not require flow from the two inch drain valve for wet pipe or dry pipe sprinkler system During the week of January 2, 1989, the licensee provided the inspector with an internal memorandum to E. Eenigenburg from R. Black that stated the following:
"The test flow discharges will be handled through pre-installed drain piping to the station storm drain On systems where pre-installed drain piping is nonexistent, a 1-1/2 inch maintenance hose will be use We believe a 1-1/2 inch hose provides adequate flow at our system pressure (125 psi) to ensure water supplies and connections are in orde The reactor building fire hose risers will be tested by connecting a 1-1/2 inch maintenance hose to the upper most hose station locations and test flowed to station storm drain It is our plan to complete the writing and get approvals of the surveillance by April 30, 1989 and perform the surveillance for the first time by June 30, 198 Additional surveillances will be done on an annual basis."
Based on the licensee's commitment to conduct the drain test, this item is considered close (Closed) Open Item (237/85033-06(DRS); 249/85029-06(DRS)):
The licensee was requested to provide appropriate acceptance criteria for filling breathing air supply cylinder The licensee provided the inspector with the procedure titled "Use of the Cascade Recharging System for Filling Self Contained Breathing Apparatus Bottles," DRP 1310-11, Revision The inspector reviewed the procedure and no discrepancies were identified. Based on the inspector's review of this procedure, this item is considered close (Closed) Open Item (237/85033-0l(DRS); 249/85029-0l(DRS)):
The inspectors observed deficiencies on the main carbon dioxide storage tank located on the first floor of the turbine buildin The deficiencies included the following:
(l) The access door to the tank compressor motor was missin (2)
The glass cover to the tanks mercoid switch located inside the access door was missin During the Appendix R inspection that ended in December 1988, the inspector had observed that the licensee had taken corrective actions to replace the access door and glass cover to the mercoid switc Based on the licensee's actions, this item is close (Closed) Open Item (237/88010-05(DRS); 249/88012-05(DRS)):
The pre-discharge alarm for the diesel room carbon dioxide system is only an audible alar The licensee was requested to verify that the audible alarm is sufficient to warn personnel that may be in the area with the diesel operatin The licensee provided the inspector with an internal document dated January 31, 1989, from R. Black, Assistant Fire Marshal to the Fire Protection File. The document indicates that on December 23, 1988, during the performance of DFPP 4145-1; "Cardox System Semiannual Maintenance Test," which was modified for a running diesel, the audible alarm was heard by the occupants in the roo *
Based on the licensee 1 s actions, this item is considered close (Closed) Violation (237/88010-06(DRS); 249/88012-06(DRS)):
The licensee failed to meet the requirements of their approved fire protection program by permitting the storage of twenty 55-gallon drums of lube oil in a safety-related are The licensee provided the inspector with the 11Control of Transient Combustibles 11 procedure that has been revised to include the following:
For medium fire loading of an area (5-25 gallons for flammable liquid, 55-120 gallons for combustible liquid) and high fire loading of an area (25 gallon for flammable liquid, 120-240 gallons for combustible liquid) a transient combustible permit signed by the fire marshal or his designee is require In addition, compensatory measures are required prior to introducing combustibles into the plant. The fire marshal is also required by the procedure to review the fire hazards analysis for the fire area of concer The basis for acceptance of a high fire load includes the consideration of equipment and combustibles presently in the area and any suppression or detection system Compensatory measures are then establishe Based on the review of the updated procedures, this item is considered close.
Routine Fire Protection Program The Dresden fire protection program utilizes the defense-in-depth concept against hostile fires to ensure that safe shutdown capability is not impaire The Dresden fire protection program philosophy of defense-in-depth consists of: Fire Prevention Detection and Suppression Mitigation of Fire Damage The inspector reviewed, on a sample basis, the licensee 1s administrative procedures and fire protection surveillance The inspector also walked down several fire protection system The results of the inspector 1s review are as follows: Fire Protection System Surveillances The licensee*s fire protection program requires that the licensee test fire protection equipment and systems that are included in regularly scheduled station operating surveillance procedure The inspector selected a.sample of the licensee*s completed surveillance procedures for revie During the review, the inspector determined the following:
( 1)
Weekly Unit 1 Diesel Fire Pump Operability Surveillance The licensee 1s Unit 1 diesel fire pump weekly operability surveillance, DFPP 4123-1, Revision 8, includes the
( 2)
verification that the fire pump batteries are provided with proper electrolyte level and specific gravit In addition, the procedure verifies that the battery charger is operating and that proper oil level is provided in the engine case and right angle gear driv The inspector reviewed the Unit 1 diesel fire pump weekly operability data sheet dated March 28, 1989, and found the results to be satisfactor Quarterly Auxiliary Electric Equipment Room Halon Damper Test The auxiliary electric equipment room halon damper test, DFPP 4195-3, Revision 2, verifies that dampers required to close prior to discharge are operating as designe The auxiliary electric equipment room halon damper test results dated March 14, 1989, were found to be satisfactor (3)
18 Month Operating Fire Stop/Break Surveillance The operating fire stop/break surveillance, DFPP 4175-2, Revision 5, verifies by visual observation that the fire stop/break is intac The fire stop/break surveillance dated February 29, 1988, was found to be satisfactory *
(4)
Annual Auxiliary Electrical Equipment Room Fire Resistive Structural Steel and Cable Coating Surveillance The auxiliary electrical equipment room fire resistive structural steel and cable coating surveillance, DFPP 4175-4, Revision 1, requires visual verification of the integrity of the auxiliary electrical equipment room fire resistive structural steel and cable coatin In the surveillance dated January 18, 1989, the licensee identified several areas where structural steel fire proofing was found degraded and initiated a DV Based on the licensee's actions to correct the degraded fire proofing, the surveillance was found to be acceptabl (5)
Monthly Fire System Yard Loop Inspection The fire system yard loop monthly inspection, OAP 11-2, Revision 15, checks equipment such as fire hydrants, hose houses, fire hose reels, fire main valves and other fire equipmen The fire system yard loop monthly inspection dated March 10, 1989, was reviewed and found to be satisfactory *
(6)
Monthly Fire System Inspection For Unit 2 The Unit 2 monthly fire system inspection, DFPP 4114-2, revision 9, visually inspects equipment such as hose reels, fire main valves, fire equipment carts, carbon dioxide systems and other fire equipmen The Unit 2 monthly inspection results dated March 27, 1989, were reviewed and found to be satisfactor (7)
Six Month Fire Detection Test The licensee's smoke detector semiannual maintenance test, DFPP 4185-2, revision 6, verifies the response of the fire detection syste The inspector requested the last six month channel functional tests conducted for Unit 2 fire zones 1. 1.2. 1 (elev. 476 1 -6 11 ),
1.1.2.2 (elev. 517 1-6 11 ), 1.1.2.3 (elev. 545 1-6 11 ), and Unit 3 fire zones 1.1.1.1 (elev. 476 1-6 11 ), 1.1.1.2 (elev. 517 1-6 11 ),
and 1.1.1.3 (elev. 545-6 11 ). Fire zones 1.1.2.1 and 1.1.1.1 are provided with linear thermal detectio The inspector requested the six month functional test for these area However, the licensee had not yet developed a six month channel functional test for the linear thermal detectors in these area In discussion with the licensee, the licensee indicated that a recent audit had identified the same concern and that the surveillance was in the process of being develope The licensee indicated to the inspector that the surveillance will be completed by July 21, 198 This is considered an open item (237/89013-0l(DRS); 249/89012-0l(DRS)) pending NRC 1 s review of the surveillance procedur The inspector reviewed the last six month channel functional test dated January 1989 for Fire Zones 1. 1.2.2, 1. 1.2.3, l.l.1.2, and 1. 1.1.3. The functional test performed did in some cases identify minor problem The licensee wrote a work request to address those concern Based on review of the surveillance test results and the licensee's actions, the surveillance was found to be acceptabl Personnel Required for Safe Shutdown and Fire Fighting Activities In the event of a disabling fire which requires evacuation of the Unit 2/3 Common Control Room when both units are operating, it would be necessary to provide sufficient personnel to shutdown the operating reactors and provide manual fire fighting capabilitie ( 1) Safe Shutdown Personnel The licensee has developed alternative safe shutdown procedure EPIP 200-20, titled "Control Room Evacuation/Safe Shutdown," Revision 6, dated February 198 The licensee's staff required to implement the alternative safe shutdown procedure requiring the evacuation of the control room is as follows:
Shift Engineer (SE)
Station Control Room Engineer (SCRE)
Unit 2 Shift Foreman (SF)
Unit 3 Shift Foreman (SF)
Engineer Assistant (EA)
Center Desk Nuclear Station Operator (NSO)
Unit 2 Nuclear Station Operator (NSO)
Unit 3 Nuclear Station Operator (NSO)
Unit 1 Level 1 Operator/Equipment attendant Unit 2 Level 1 Operator/Equipment attendant Unit 3 Level 1 Operator/Equipment attendant Utility Level 1 Operator/Equipment attendant (2)
Fire Brigade Personnel The licensee also has developed "Fire Fighting" procedure EPIP 200-4, Revision 5, dated December 1987, which describes the organization of the fire fighting brigade and delineates the duties of the fire brigade. This procedure indicates that the composition of the fire brigade for all shifts is as follows:
Shift Foreman - Fire Chief High Voltage Operator - Fire Fighter Radwaste Roving Operator - Fire Fighter Unit 2/3 Max Recycle Operator - Fire Fighter Rover - Fire Fighter (3)
Operations Department Organization The licensee has developed operations department organization procedure OAP 7-1 which identifies the staffing normally required for operating shifts 1, 2, and The inspector verified that the minimum number of personnel for safe shutdown and fire fighting was included in the procedur (4)
Conclusion The inspector requested records to demonstrate that the 12 personnel required to implement the control room evacuation procedure and the 5 personnel required for fire fighting activities were available for three shifts on April 13, 1989, and April 26, 198 The inspector was provided with copies of the appropriate sections of the shift 1s engineers and center desk book * In cases where names were inadvertently left out of the logs, the licensee provided backup documentation to demonstrate that these personnel were availabl The inspector verified, based on the licensee 1 s documentation provided, that the appropriate personnel for the 12 positions were available to implement the control room evacuation safe shutdown procedur The inspector also verified that in addition to the staff required for safe shutdown, the licensee provided a 5 member fire brigade consisting of a fire chief and four fire fighter Based on the inspector 1s review of the licensee 1s documentation, the inspector determined that on April 13 and 26, 1989 (all shifts), the licensee provided sufficient personnel for safely shutting down the reactors and to support any required fire fighting activitie Pre-Fire Plans The licensee has developed pre-fire plans for fire in safety-related areas as described in the fire hazard analysi The pre-fire plans indicated important parameters for each fire area such as access, hazards, fire protection equipment, ventilation, communications, exposures (safety-related equipment), construction, guidelines for attack, et In addition, the licensee has provided a schematic for each fire area which also indicates location of fire fighting equip-ment, communication, access points, etc. It appears that the licensee has developed good fire pre-plans for fighting fires in safety-related areas within the plan However, the inspector identified that pre-fire plans did not exist for areas such as the hydrogen storage area and main power transformers for Unit 2 and Unit Both of these are non safety-related area The licensee was informed that it would be prudent to develop pre-fire plans for all areas with high combustible loading and/or where special precautions may be required to prevent injury to fire fighting personnel or damage to the plan The licensee acknowledged the inspector 1s concern and indicated that plant areas not addressed in the fire hazard analysis such as the main power unit transformers and hydrogen storage areas will be reviewed and pre-fire plans developed by December 31, 198 Hydrogen Storage The tank farm and the hydrogen injection storage are two areas at the Dresden site that currently store hydrogen for normal plant operation to provide hydrogen cooling for the turbine generator and also to prevent intergranular stress corrosion cracking in primary piping and equipmen Both of these hydrogen systems are non safety-relate (1)
Tank Farm According to the licensee, the tank farm was installed in 1968 and is provided with fifty fixed storage vessels capable
of storing 35,000 standard cubic feet (scf) of hydrogen at 1250 pounds per square inch (psi). The extra heavy red brass piping from the tank farm to the regulator is pressurized to approximately 1250 psi. After the hydrogen is stepped down by the regulators to a line pressure of 70 psi, the hydrogen then enters into 150 carbon steel pip The underground pipe for this system is provided with cathodic protectio The system has been designed for automatic operation and is provided with a high flow supply line trip. This hydrogen system has also been provided with alarms such as gas purity, gas pressure, high flow, low flow, low main bank pressure and hydrogen storage reserve bank low pressur The inspector toured the hydrogen tank farm and observed that the piping from the relief valves was rusty and was not provided with plastic cap (2)
Hydrogen Injection Storage There are two hydrogen supply trailers, each with a total capacity of 125,000 scf. This system has been designed for automatic operation and is provided with trips resulting from reactor scram, low feedwater, low offgas, hydrogen high area alarm, local panel shutdown switch and control room shutdown swttc The piping installed from the hydrogen storage trailers to the plant is 304 stainless steel pipe and is provided with cathodic protectio The pipe installed inside the building is 300 carbon steel pip The inspector toured the hydrogen storage trailers and noted that the pressure regulator cabinet that steps down the pressure from the trailer tanks to the system piping was not securely mounted or protected from trucks that deliver hydroge In addition, the inspector observed that the trailers were not provided with chocks to secure the wheels to prevent movemen The licensee acknowledged the inspector's concerns and indicated that the pressure regulator cabinet would be secured, barrier protection for the pressure regulation cabinet would be installed and that chocks would be provided for the wheels to prevent movemen (3)
Conclusion In discussions with the licensee, it was identified that no regular maintenance had been performed on the hydrogen tank farm since it was installed in 196 The licensee indicated that there is no regular inspection or maintenance for pressure
' regulators, relief valves, interlocks, et For the hydrogen injection storage area which is a relatively new addition, the licensee also indicated that no periodic inspection or maintenance has been established for interlocks,
- pressure regulators, relief valves, et The licensee concurred that an evaluation should be performed for the hydrogen tank farm and hydrogen injection system to develop an appropriate maintenance progra Plant Tour The inspector toured several areas of the Unit 2 and Unit 3 reactor building and turbine building. During this tour, the inspector visually observed several hose stations, extinguishers, sprinkler valves, carbon dioxide valves, emergency lights, and housekeepin The inspector observed that the equipment was in an apparently well maintained condition. Housekeeping, in general, was goo The inspector informed the licensee that the placement of reflective tags identifying appropriate switches for Appendix 11R 11 safe shutdown equipment (for example, at the 250 vdc bus) would be beneficial to the operato The licensee indicated that the station is currently assessing the use of reflective tags for identifying appropriate switches for Appendix 11R 11 safe shutdown equipmen The inspector also indicated to the licensee that the overall outside housekeeping needed to be improve The licensee concurred with the inspector and indicated that housekeeping will be improved in conjunction with the decontamination efforts. During the tour, the inspector also observed the 750 gallons per minute deluge gun (located in the 2/3 cribhouse) which may be used to assist in fighting a main power unit transformer or hydrogen tank fire. The deluge gun (monitor nozzle) is provided with mechanical gears which allow the operator to change the nozzle elevatio The inspector identified that it was difficult to change the elevation of the deluge gu The inspector suggested that the deluge gun be included in a preventive maintenance progra The licensee concurred with the inspector and indicated that the two deluge guns at the plant would be disassembled and inspected. After the results of the inspection are known, long term cpntinuing maintenance will be establishe The licensee indicated that the inspection for the deluge gun would be completed by April 30, 1989. Also during the tour, the inspector observed that the licensee stored Rockwood 6% foam concentrate (1981)
and Ansul AFFF 3% foam concentrate (1981) in five gallon cans in the waste water treatment facility. The licensee maintains approximately 50 gallons of foam concentrate at the waste water treatment facilit The inspector questioned the licensee regarding the shelf life of the foam concentrates. The licensee was not aware of the shelf life of the foam concentrate and the licensee indicated that the foam
- -
concentrate is not sent out for testing to determine if it will perform as intende The licensee indicated that fire fighting foam concentrate shelf life will be verified and if testing is required, it will be scheduled, or the foam concentrates will be replaced by May 31, 198 The shelf life of the foam concentrate is considered an unresolved item (237/89013-02(DRS); 249/89012-02(DRS))
pending review of the licensee's action The inspector informed the licensee that it would be prudent to use one type of foam concentrate and that the foam concentrate should be rotated such that the older foam concentrate, if needed, can be used during fire fighting trainin The licensee acknowledged and concurred with the inspector's comment.
Open I terns Open items are matters that have been discussed with the licensee, that will be reviewed further by the inspector, and that involve some action on the part of the NRC, the licensee, or bot Open items disclosed during the inspection are discussed in Paragraph.
Unresolved Items Unresolved items are matters *about which more information is required in order to ascertain whether they are acceptable items, or items of noncompliance or deviation An unresolved item disclosed during the inspection is discussed in Paragraph 3.e. Exit Meeting The inspector met with the licensee representative on April 7, 1989 and also held a conference call with the licensee on May 26, 198 The inspector discussed the likely content of this report and the licensee did not indicate that any information discussed during the inspection could be proprietary in natur