IR 05000255/1989014
| ML18054A833 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/06/1989 |
| From: | Gardner R, Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18054A831 | List: |
| References | |
| 50-255-89-14, IEIN-83-41, IEIN-85-084, IEIN-85-84, IEIN-87-014, IEIN-87-14, IEIN-88-004, IEIN-88-056, IEIN-88-060, IEIN-88-064, IEIN-88-4, IEIN-88-56, IEIN-88-60, IEIN-88-64, NUDOCS 8907120210 | |
| Download: ML18054A833 (10) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-2S5/89014(DRS)
Docket No. 50-255 Licensee:
Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name:
Palisad~s Nuclear Generating Plant Inspection At:
Palisades Site, Covert, MI 49043 Inspection Conducted:
May 16-18 and June 9, 1989
,, *¥ 'Y7. t,~
Inspector:'(joseph M. Ulie
?.... ---~~*~
Approved By:
Ronald N. Gardner, Chie Plant Systems Section Inspection Summary -
License No. DPR-20 7-ic-~9 Date
.l-L-8r Date Inspection on May 16-1~ and June 9, 1989 {Report No. 50-255/89014(DRS))
Areas Inspected:
Routine, unannounced inspection to review the implementation of the licensee's fire protection program including a review of the fire protection organization; administrative controls; fire protection system surveillance.test program; fire protection features for specific plant areas; Information Notices; plant modifications and quality ass\\,Jrance (30703, 64704 and 92701).
- Results:
Of the seven areas inspected, one deviation was-identified (failure to seal Bus lC tn Switchg~ar Room 1-C to p~event an inadvertent spraying of the internal components with water_ and potentially cau?ing an equipment operability problem - Paragraph 6).
Three open items and one unresolved-item are identified in this repor The first open item regards a surveillance
- procedure task of deter~ining whethe~ a modification had occurred since the previous surveillance.* This task did nbt appear ach{evable with the g~idance provfded (Paragraph 4).
The second open item regards an evaluation by the licensee to determine the adequacy of the sprinkler head locations in the cable spreading room (Paragraph 4). * The third open item has two examples -
that regard a need for additional engineering detail to support the as-installed fire detection* system locati~ns for the sperit fuel pool area and the cableway tu_nnel (Paragraph 5).
The unresolved item regards design input checklists
lacking ~ccurati fire pr6tection criteria (Paragraph 7).
Overall, the implementatio_n of the licensee's fire protection program was determined to be in accordance with 'NRC requirement PDR ADOCK 05~)0255 G!
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DETAILS
~.
P~rsons Contacted Consumers Power Company (CPCo)
- S. C. Cote, Property Protection Superintendent
- E. Dorbeck, Fire Protection Engineer D. Eaton, Intern J. G. Lewis, Technical Director.
- D. J. Malone, Senior Nuclear Licensing Analyst R. D. Oroz, Engineering and Maintenance Manager
- T. J. Palmisano, Administrative and Planning Manager
- R. W. Philips, Jr., Fire Protection Supervisor
- W. L. Roberts, Supervisory Engineer
.
- G. Sle~peri Senior Engineer, Plant Projects The inspector also contacted other licensee employees during the course of the inspectio *
- Denotes those licensee personnel participating i~ the telecon exit meeting held on June 9, 198.
Fire Protection Organization The inspector interviewed two licensee personnel performing fire watch duties including a security officer conducting an hourly fire watch patrol and an individual acting as a fire watch durin~ hot ~ork activities. The inspector determined, after discussions with each of these individuals, that they were adequately trained. This determination was based on the fact that the fire watch individuals were able-to*
describe the required emergency actions which they would take upon spotting a fire conditio An unannounced fire drill was requested by the inspector and was stheduled by the licensee for May 17, 198 However, this drill was cancelled due to an electro-hydraul.ic fluid leak that required the attention of shift personnel who were also assigned fire brigade dutie.
Administrative Controls While performing plant tours on May 16-18, 1989, the inspector examined licensee fire protection administrative control *procedure No. 7, Revision 5, dated October 17, 1988~
The inspector's review of the procedure determined that the procedure was well written and minimized the amount of combustibles that a designated *
vital area may be exposed to. During plant tours on May 16-18, 19$9, the inspector, accompanied by the fire protection supervisor and a senior engineer in plant projects, performed a walkthrough of designated vital 2 *
and non-vital areas including the control room, cable spreading room; Switchgear Rooms 1-C and 1-D, Diesel Generator Rooms 1-1, 1-2 and their respective day tank rooms, the intake structure, the east engineered safeguards (ESG) room (the west ESG room was inaccessible due to radiological,concerns), Battery Rooms A and B, charging pump room, engineered safeguards panel room, component cooling pump room, the north and south electrical penetration rooms, compactor area-track alley, spent fuel pool area, electric equipment room and yard are As a result, it was determined that these areas were being satisfactorily maintaine However, while touring the yard area, it was noted by the inspector that improved maintenance of the general area within the flammable hydrogen storage area was neede This issue was considered to be of minor safety significance and prompt licensee action was initiated at the time of the inspectio Fire Protection System Surveillance Test Program The inspector reviewed, in part, the licensee's fire protection system surveillance test program as required by Technical Specifications (TS).
This review consisted of an examination of completed surveillance packages, a selected sampling of specific surveillance test areas and discussions with licensee staf No witnessing of surveillance tests occurred since the licensee indicated that none were scheduled during the inspection perio The inspector's review included the following: Fire Sprinkler Systems The most recent 18 month surveillance check of the fire sprinkler system to determine that each sprinkler head spray pattern was not obstructed was conducted by review of the system functional test results and by visual observation during plant tour The inspector was provided the completed surveillance test package dated May l, 1988, documenting that this functional test was performed satisfactorily as required to meet TS Surveillance Requirement 4.17. Step 5.1 of the applicable TS surveillance procedure (No. R0-51)
specifies that a check be performed to ensure that a sprinkler head spray pattern has not been obstructed since the last surveillance due to a modificatio However, since certain plant areas such as the cable spreading room ceiling area are congested by ventilation ductwork, layered cable trays, and other miscellaneous equipment, it was not readily apparent that an auxiliary operator (AO) performing this procedure on a frequency of once every 18 months could determine whether a modification had occurred since the last surveillance. An alternative would involve having the modification change process ensure, following the completion of the modification work~ that the sprinkler head spray patterns have not been obstructe This is considered an open item (255/89014-0l(DRS)) pending licensee review to ensure that the task required of the AO during the surveillance procedure is achievable.
Due to the congestion of cab 1 e trays, ventilation ductwork, and other miscellaneous equipment near the ceiling level of the cable spreading room, the in spec.tor que'st i oned whether a rev'i ew had been performed sin.ce the original safety evaluation (SE) was iss.ued on September 1, 1978, to determine the p6tenti~l for sprinkler head ~pray pattern obstructions in accordance with the applicable fire cod The NRC issued this fire protection SE based on a review of licensee submitted information.* According to the Property Fire Protection Supervisor, an analysis had been performed since 1978 but was not available during the inspectio On June 2~ 1989, the licensee provided the inspector with an analysis to support exceptions to the National Fire Protection Association (NFPA) code criteri However, the stated NFPA exceptions to the Standard for Installation of Sprinkler Systems" did not specifically addres~ sprinkler head spray pattern obstruction Consequently, following review of the licensee submitted.information, the inspector suggested that the licensee perform an evaluation to determine the adequacy of the sprinkler head locations in the present cable spreading room configuration. This is considered an open item (255/890i4-02(DRS)).
The inspettor also noted that sprinkler systems for Charging Pump Rooms 104, 104A, and 104B, Switchgear Room 1-C, and the north cable penetration room have been added sin~e the original fire protection review but were not.listed in TS However, the licensee provided plant Standing Order No. 54, dated April 20, 1989, that specified these locations as supplementary TS areas which were to be regarded in the same manner as those in approved TS According to the licensee 1s staff, plans have been initiated to tr~nsfer specific fire protection sections into the FSAR by July 31,.198 Therefore, since the above sprinkler systems are receiving the same level of surveillance and review as are TS designated area sprinkler systems, and since each of these rooms will be incorporated into the FSAR administrative procedure, no further action by the licensee was deemed necessar b~
Fire Suppression Water System Valve Alignment The most recent monthly surveillance chetk of the fire suppression water system to determine that each valve was in its correct position was performed by review of the system functional test results and by visual observati~~s during plant tours~ The inspector was given the completed surveillahce test procedure (No. M0-26) which had been completed on April 19, 1989, and P&ID Drawing No. M-216, Revision 4, dated August 5, 198 During a plant tour on May 17, 1989, the inspector,* accompanied by licensee personnel, selectively sampled both inside and outside fire water valves and _determined that, with the.
exception of one valve, each of these valves was properly positione One post indicator valve (No, MV-FP-178) was found in a partially closed positio This valve isolates the underground fire main to the Service Building and Project Management Building area According to the licensee, neither of these buildings have any vital equipment located in them.* Therefore, no violation of NRC requirements had occurre Howeveri licensee ~ttention to this matter was promptly initiated prior to the inspector 1s departure from the sit **
- Also, to demonstrate that the fire water and auxiliary feedwater (AFW) system crosstie valves were being maintained, the licensee provided the inspector with the completed surveillance test package (No. Q0-21) which-was completed on March 9, 198 No discrepancies were noted during this revie During a plant tour, the inspector also verified that the crosstie valve was. in the proper positio Fire Hose Station The most recent monthly surveillance check of the fire hose stations to assure that this fire equipment is available and ready for use was performed by review of the test results and by visual observations during plant tour The inspector was given the completed surveillance test procedure (No. M0-26) which was completed on April 19, 198 During plant tours on May 16 and 17, 1989, the 1nspector, accompanied by licensee personnel, selectively sampled vital area hose stations and determined each of these stations to be in satisfactory conditio Fire Detection. System The-most recent semi-annual functional test of the fire detection system outside containment was provided for inspector revie The completed surveillance test package, No. SI-7, Revision 7, dated June 8, 1987, was completed on April 26, 1989. The package indicated that this functional test was performed satisfactorily in accordance with TS 4.17..
Verification of Fire Protection Features for Specific Plant Areas The inspector selectively examined fire protection modifications described in the NRC 1s Fire Protection Safety Evaluation -(SE) of Palisades facility dated September l, 1978, to determine whether licensee was maintaining the required fire protection feature plant tours conducted.on May 16-18, 1989, the inspector observed status of fire protection features in the following areas:
the the During the Control Room The control room contains safety-related control cabinets and consoles including all the systems required for normal plant shutdow The inspector confirmed that ionization type smoke detectors wer~
installed in the control room walk-in cabinets located within the primary control pane The inspector also confirmed that a three-hour fire door was iristalled in the stairwell opening between the contro room and Switchgear Room 1-Cable Spreading Room This area contains 480 V transformers, switchgear, tables for power, in~trumentation and control for vital and non-vital systems, and other equipment related to safety-related AC and DC power supplie ** *
The inspector confirmed that ionization type smoke detectors were instailed in the cable spreading roo Also, as required, it was confirmed that a ladder dedicated for manual firefighting capability was positioned in this roo Additional-comments regarding fire protection features located in the cable spreading room are discussed in Paragraph 4 of the repor Switchgear Rooms There are two redundant 2.4 kV switchgear rooms (lC and 10).
Each room contains the switchgear for one of the redundant divisions of safe shutdown equipment and its associated cable A tunnel which contains cabling of one safety division leads from Switchgear Room 1-D to the associated penetration are *
The inspector confirmed that the following fire protection features were installed in Switchgear Rooms 1-C and 1-D:
(1) ionization type smoke detectors; (2) sprinkler system in each room; (3) a fire rated door between the penetration opening separating Switchgear Room 1-D and the cable spreading room; and (4) sealed wall cable perietration However, in the cableway tunnel that leads from Switchgear Room 1-D to the north penetration room, no detector is installed in the south end of the cableway tunnel where changes in the ceiling height occu No analysis was available for review during the inspection which addressed the acceptability of this desig On June 2, 1989, the licensee provided the inspector with an analysis to support exceptions to the NFPA code criteri I accordance with Generic Letter 86-10, dated April 24, 1986, the licensee had conducted an evaluation encompassing the location and spacing of the installed fire detection syste However, the inspector requested the licensee to provide the detailed information which was used to support the licensee's conclusion that the fire detection system meets the full intent of NFPA 72E for this are This is considered an open item (255/89014-03(DRS)) pending receipt and review of this informatio An additional concern was raised by the inspector regarding the potential for water to enter Bus lC in Switchgear Room 1-C at floor level due to the switchgear being floor mounted, the absence of floor drains, and no special instructions being included in the fire pre-plans or elsewher On June 2, 1989, the licensee provided the inspector with both a specific analysis to support no floor drains or the need for curbing in Switchgear Room 1-C and general analyses addressing the issue of inadvertent fire suppression system actuation affecting a plant safety syste The specific evaluation postulates a total loss of all equipment in the room and still having the ability to safely
.
shutdown through the use of the alternate shutdown procedure During the telecon exit of June 9, 1989, the inspector indicated that further consideration by the licensee was pruderit to limit the extent of -
postulated water damage so as to avert the loss of any vital equipmen * Diesel Generatoi Rooms The diesel generators are each.housed in separate rooms, separated from each other by 3-hour fire-rated wall The safety-related equipment in each room is the diesel generator and electrical equipment associated with the same division of safety-equipment as the generato The inspector confirmed that the doors between the diesel generator rooms and the vestibule are fire-rated three hour door It. was also ver1fied that a curb was installed at each of these doors to prevent oil from seeping under the doo Intake Structure. Safety-related equipment in this area includes three service water pump Also in this area are the three fire pumps, two diesel*
driven and one electric motor driven, and the diesel fuel oil transfer pump The inspector confirmed that, as required, the fire pump diesel fuel oil day tanks have been relocated to another enclosed room with a diked enclosur Battery Rooms The two redundant safety-related batteries are each housed in individual enclosure The inspector confirmed.that each battery room has an installed ionization type smoke detecto Charging Pump Room The charging pump room contains the three charging pump The adjacent haTlway contai"ns.power and control l:abling for the charging
- pumps, *and cabling for the engineered *safeguards pane lhe inspector confirmed that :the c*harging pump room has installed ionization type smoke detectors. *Also, a curb ha.s been provided**
"between -l:ll.ll!Tp 'A and ~the other pumps to prevent the :spr.Ead nf an oi 1 fir Saf.eguartis Area This area has two f i re.2ones, *ea.ch. of which. contains the con ta. i nme n t spray, low pressure safety injection, and high pressure safety i njcti OTI pumps of *each di visio * The inspector confi-rmed that ionization type smoke det-ctors have been installed in the east safeguards ar£ The west safe~uards ara was not inspected due to ratiiulogical conce~n * * Component Cooling Pump Area Safety-related equipment in this area includes the three component cooling pumps and heat exchanger The inspector confirmed that ionization type smoke detectors have been installed on the 590 1 elevation of this area where the three component cooling pumps and heat exchangers are locate Refueling and Spent Fuel Pool Area Safety-related equipment in this area include the new and spent fuel pools, fuel storage racks, and fuel handling equipmen The inspector confirmed that smoke detectors have been installed in this location over the tool crib are However, the inspector questioned the ability of these dete~tors to sense a fire initiated due to ordinary combustible fire hazard The bases for the jnspector's concern were the spatial separation between the sensing device and the fire hazard and the potential for stratification of the products of combustio On June 2, 1989, the licensee provided the inspector with additional informatio One section of this information included an analysis to support exceptions to the NFPA code criteri In accordance with Generic Letter 86-10, dated April 24, 1986, the licensee had conducted an evaluation encompassing the location and spacing of the installed fire detection syste However, the inspector requested the licensee to provide the detailed information which was used to support the licensee's conclusion that the fire detection system meets ~he full intent of NFPA 72E for this are This is considered another example of open item (255/89014-03(DRS.))
pending receipt and review of this informatio Cable and Penetration Rooms There a re separated barrier redundant two cable penetration areas into containment totally from each other by distance and a number of fire Each area contains cables for safety-related equipment to the other are The inspector confirmed that smoke detectors and sprinkler systems have been installed in the north and south penetration area Information Notices The inspector examined the licensee's responses to the following Information Notices (IENs):
(1) IEN No. 85-84, "Systems Interaction Event Resulting In Reactor System Safety Relief Valve Opening Following a Fire Protection Deluge System Malfunction," response dated January_6, 1986; (2) IEN No. 87-14, "Actuation Of Fire Suppression Causing Inoperability Of Safety-Related Ventilation Equipment, 11 response dated May 29, 1987; (3) IEN No. 88-04, "Inadequate Qualification and Documentation Of Fire Barrier Penetration Seals, 11 response dated April 20,
~--
~--- ----*----
- I988; (4) !EN No. 88-56, 11Silicone Foam. Penetration Seals, 11 response extension requested October 25, I988; and (5) !EN No. 88-64, 11 Reporting Fires In Nuclear Process Systems At Nucle.ar Power Plants, 11 response dated October 26, I98 A review of the first !EN found the response to be icceptabl However, the second !EN re~ponse, although related in part to the first !EN, did not address the broader generic problem involving operator errors and single and common-cause failures that initiate fire suppression systems and cause the inoperability of safety-related systems. An unsealed penetration opening into electrical equipment in an area protected by a fire suppression system could be of concern if water ingress could potentially affect equipment operabilit During the course of an inspector walkdown of plant safety related areas on May I7, i989, the inspector, accompanied by licensee personnel, observed an unsealed opening in the top of a cable entry point 1n the Bus iC cabinet above breaker I52-I08 (Switchyard Auxiliary Power).
According to Paragraphs D.3, E.3, and F.5 of the Fire Hazards Analysis, dated March 3I, I977, all switchgear top cable penetrations are sealed with flammastic to prevent water ingress from the room fire suppression system.* Therefore, this is considered a deviation (255/89DI4-04(DRS)) from an NRC commitment as described in the Notice of Deviatio On June 2, I989, the licensee provided the inspector with nuclear work order request No. I4I334 which initiated work to seal the top of Bus IC to remove the potential for water ingres Based on the unsealed opening being found in the top of Bus IC, further review by the licensee of other equipment that may be exposed to the inadvertent spraying of the internal components with water that could result in an equipment operability problem appeared appropriate (reference e.g. IEN's 83-4I, 87-I4 and 88-60).
The third and fourth IENs are related to penetration fire seal The licensee's technical review of each was still ongoin This area will need to be reviewed further during a future inspectio The last !EN review found the licensee evaluation to be consistent and meeting NRC guideline.
Plant Modifications The inspector reviewed Administrative Procedure No. 9.03 entitled, 11 Facility Change-Minor, 11 Revision 6,- dated November I98 Section 8, *
11 Fire Protection Requirements" of Attachment 4 of the design input checklist, lists intended applicable design criteria for various design discipline This document specifically references thirteen of the sections of IO CFR Part 50, Appendix R,Section II Nine of these sections do not specifically apply to the Palisades site and other criteria which does apply was not liste Based on the errors/omissions identified in this procedure, the inspector questioned the adequacy of the licensee's desi_gn review which verified that the appropriate regulatory requirements and licensee commitments were incorporated in the licensee's modification design review This is considered an unresolved item (255/890I4-05(DRS)).
9 Quality Assurance The inspector requested the licensee to provide the last audits performed to satisfy TS Sections 6.5.2.8.g, h, and i. The licensee provided Audit Report No. QT-86-21, dated October 8, 1986; No. QT-87-21, dated September 29, 1987; and No. QT-88-22, dated October 14, 1988. A review, in part, of each audit report indicated that the licensee performed the scheduled audits as required and verified a selected sample of fire protection program aspects of the in-place progra The inspector concluded that the licensee was satisfying the fire protection TS requirement.
Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the.part of the NRC or licensee or bot Open items disclosed during the inspection are discussed in Paragraphs 4 and * /
1 Unresolved Item An unresolved item is a matter-about which more information is required to ascertain whether it is an acceptable item, a deviation, or a violatio An unresolved item disclosed during the inspection is discussed in Paragraph. Deviations A licensee 1s failure to satisfy a written commitment or to conform to the provisions of applicable codes~ standards, guides, or accepted industry practices when the commitment, code, standard, guide, or practice involved has not been made a legally binding requirement by the Commission, but is expected to be implemented. A deviation from a written licensee "Commitment is discussed in Paragraph ~ Exit Interview Th~ inspector held a telecon exit interview with licensee representative (denoted in Paragraph 1) at the conclusion of the inspection on June 9, 1989, and summarized the scope and findings of the inspection. The inspector also discussed the likely informational content of the inspection report with regard to documents reviewed by the inspector during the inspection. The 1 icensee_ did not identify any of the documents as proprietar On June 13, 1989, licensee technical representatives contacted the inspector to provided additional technical details for issues that remained open at the time of the June 9, 1989 exit intervie The inspector acknowledged the licensee's planned resolution of these issues and requested the licensee to document the evaluation criteria and result