IR 05000315/1981011
| ML17319B130 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/30/1981 |
| From: | Grobe J, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17319B129 | List: |
| References | |
| 50-315-81-11, 50-316-81-14, NUDOCS 8201180498 | |
| Download: ML17319B130 (35) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-315/81-11; 50-316/81-14 Docket Nos. 50-315; 50-316 Licenses No. DPR-58; DPR-74 Licensee:
American Electric Power Service Corporation Indiana and Michigan Power Company 2 Broadway New York, NY 10004 Facility Name:
D.
C.
Cook Nuclear Plant, Units 1 and
Inspection At:
D.
C.
Cook Site, Bridgman, MI Inspection Conducted:
June 1-4 and August 13, 1981 Inspector:
. A. Gxobe Approved By:
C.
. Williams, Chief 7"4~
Plant Systems Section IZ 90 S Date Date Ins ection Summa Ins ection on June 1-4 and Au ust
1981 Re orts No. 50-315/81-11 50-316/81-14)
of the licensee's housekeeping and fire protection/prevention programs includ-ing review of fire fighting equipment and systems; fire protection, prevention and housekeeping administrative controls; and fire brigade, general employee, and contractor fixe protection/prevention training.
The inspection involved 43 inspector-hours onsite including seven inspector-hours offshift.
Results:
Of the four areas inspected, no apparent, items of noncompliance were identified in one area; eight apparent items of noncompliance were identified in three areas (missed surveillance requirements and/or equipment inoperability for the fire detection system, the fire water s'upply system, the fire spray and sprinkler system and fire barrier penetration seals - Paragraph 2; lack of ac-ceptance criteria on surveillance test procedure - Paragraph 2; material false statements concerning fire doors and administrative controls - Paragraphs
and 4; and incomplete fire brigade training - Paragraph 5); and one apparent deviation was identified in one area (inoperable fire rated doors for the diesel driven fire pump rooms - Paragraph 2).
8201180498 811231 PDR ADQCK 05000315 G
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DETAILS
1.
Persons Contacted Donald C.
Cook Nuclear Plant pe
- B
+-E.
+R.
R.
R.
D.
D.
"C.
"R.
%E D.
A.
J.
D.
M.
qAJ E.
D.
Shaller, Plant Manager Svensson, Assistant Plant Manager Townley, Assistant Plant Manager Begor, Staff Assistant to Plant Manager Keith, Operations Superintendent Stephens, Operations Senior Performance Engineer Krause, Operations Quality Control Implementation Draper, Operations Quality Control Implementation Murphy, Operations Production Supervisor Dudding, Maintenance Superintendent Smarrella, Technical Superintendent Duncan, Control and Instrumentation Supervisor Blind, Performance Supervisor Wojcik, Chemical Supervisor Nelson, Training Supervisor Brown, Training Instructor Stietzel, Quality Assurance Supervisor Morse, Quality Control Supervisor Hickcox, Quality Control Inspector Coordinator Coordinator American Electric Power Service Cor oration J. Castresana, Head, Nuclear Safety and Licensing J. DelPercio, Safety and Licensing Engineer
>'Denotes those present at exit interview on June 4, 1981.
+Denotes those present at exit interview on August 13, 1981.
2.
Automatic Fire Detection Su ression and Emer enc S stems The inspector examined the licensee's fire detection, suppression and emergency systems including fire suppression water supply system, spray and sprinkler systems, low pressure Cardox system, Halon 1301 system, detection system and penetration fire barriers including fire barriers for piping and cabling penetrations, doorways and ventilation ducts.
These systems were reviewed using the commitments and requirements in the "Fire Protection Safety Evaluation Report," dated July 31, 1979, the "Fire Hazards Analysis," dated March 31, 1977, the "Response to Appendix A to Branch Technical Position APCSB 9.5-1," dated January 31, 1977, and the fire protection systems Technical Specifications.
a.
Areas of Ins ection
i'l
~
(1)
Procedures Number PMI 4030 1"OHP 4030.STP.120 Title Technical Specification Surveillance Fire Protection System-Water and Carbon Dioxide Dates Data/Signoff Sheet 6.1 Data/Signoff Sheet 6.2 Data/Signoff Sheet 6.3 Data/Signoff Sheet 6.4 Data/Signoff Sheet 6.5 Data Signoff Sheet 6.6 Data/Signoff Sheet 6.7 Fire Pump Operability Test - Weekly 4/2/81 through 5/21/81 (Weekly)
Turbine 6 Service Building Flow Path Verifications and Unobstructed Flow Test - Monthly 3/14/81, 4/14/81 Turbine and Service Building Flow Path Verification - Monthly 3/14/81, 4/14/81 Sprinkler and Deluge Valve Alarm and Flow Test - Monthly 3/14/81, 4/14/81 Auxiliary Building Water/CO Flow Path Verification -
2/27/81, 3/27/81, Monthly 4/27/81 Auxiliary Building Water Flow Path Verification -
2/27/81, 3/27/81, Monthly 4/27/81 C02 Flow Path Verification -
2/27/81, 3/27/81, Monthly 4/27/81 Data/Signoff Sheet 6.8 2-OHP 4030.STP.120 Water Flushing Connection Blowdown Verification-Monthly Fire Protection System-Water 3/14/81, 4/14/81 Data/Signoff Sheet 6.1 Data/Signoff Sheet 6.2 Fire Pump Operability Test -
4/2/81 through Weekly 5/21/81 (weekly)
Turbine Building Flow Path Verifi-cation and Unobstructed Flow 3/15/81, 4/15/81 Test - Monthly Data/Signoff Sheet 6.3 Turbine Building Flow Path Verification - Monthly 3/15/81, 4/15/81
~h
~la II
Number Title Date'a Data/Signoff Sheet 6.4 Data/Signoff Sheet 6.5 Data/Signoff Sheet 6.6 Sprinkle and Deluge Valve Alarm and Plow Test - Monthly 3/15/81, 4/15/81 Yard Piping Flow Path Verifi-cation - Monthly 3/20/81)
4/20/81" Yard Piping Flow Path Verifi-cation - Monthly 3/20/81, 4/20/81 Data/Signoff Sheet 6.8 Fire Hose Station Valve and Flow Check - Three year 3/14/81, 4/14/81 Data/Signoff Sheet 6.9 Data/Signoff Sheet 6.10 Charcoal Filter Spray System Operability Check - Yearly 3/20/81 Auxiliary Building Cask Handling and Drumming Area Sprinkler Systems Check - Yearly 3/20/81 1"OHP 4030.STP.121 Operation of Diesel Fire Pump-Data/Signoff Sheet 6.1 Data/Signoff Sheet 6.3 Operation of Diesel Pire 4/2/81 through Pump - Weekly 5/21/81 (weekly)
Diesel Fire Pump Flow Path 4/2/81 through Verification Valve Lineup -
5/7/81 (Weekly)
Weekly 5/21/81 2-OHP 4030.STP.121 Operation of Diesel Fire Pump-Data/Signoff
" Operation of Diesel Pire 4/2/81 through Sheet 6.1 Pump - Weekly 5/21/81 (Weekly)
Data/Signoff Sheet 6.3 Diesel Fire Pump Flow Path Verification Valve Lineup -
4/2/81 through Weekly 5/21/81 (Weekly)
12-OHP 4030.STP.122 Fire Protection Water Logic Pump Start Sequence Data/Signoff Sheet 6.1 12-OHP 4030.SP.11 Fire Protection Water I,ogic Pump Start Sequence
- 18 month 5/5/79, 4/7/81 Test Procedure for Reactor Coolant Pump Fire Water Spray and Auxiliary Building Spray August, 1981 12-(}HP 4030.STP.001 Surveillance Inspection of Safety Related Penetration January - March, Fire Barrier Silicone Seals 1981 4-
Number Title Date's 12-THP 4030.STP.225 Low Pressure CO Fire Suppression System Surveil-March - April, lance - 18 Months 1981 12-THP 4030.STP.223 Fire Protection Water System Test - 18 Months March, 1981 12-THP 4030.STP.224 Halon Fire Protection System Surveillance Test February, 1981 12-THP 6030.IMP.142 Fire Detection Instrumentation and Cardox System Surveil-November-lance Testing - 6 Months December, 1980 12-THP 6030.IMP.143 Halon System Surveillance Testing - 6 Months 5/20/80, ll/15/80F 5/1/81 1-THP 6030.IMP.151 Containment Fire Detection System 11/17/80 12-THP 6020.LAB.041 Emergency Diesel Fuel Oil-Quarterly (2)
Plant Tours 1/5/81, 4/6/81 The inspector examined automatic fire detection, suppression and emergency systems and equipment during tours of the fol-lowing plant areas:
Turbine Building Auxiliary Building Containment Electrical Penetration Area Circulating Water Pump and Screen House Plant Yard b.
F~indin e
(1)
Violations Noncompliance (50-315/81-11-01; 50-316/81-14-01):
Technical Specification 3.3.3.7 for Unit 1 and 3.3.3.8 for Unit 2 states in part,
"As a minimum, the fire detection instrumentation for each fire detection zone...shall be OPERABLE...whenever equip-ment in that fire detection zone is required to be OPERABLE...
With the number of OPERABLE fire detection instruments less than required...within one hour, establish a fire watch patrol to inspect the zone(s) with the inoperable instrument(s)
at least once per hour."
gl I Technical Specification 4.3.3.7.2 for Unit 1 and 4.3.3.8.2 for Unit 2 states in part,
"The NFPA Code 72D Class B supervised circuits supervision associated with the detector alarms of each of the above required fire detection instruments shall be demonstrated OPERABLE at least once per six months."
Contrary to the above, the inspector found, on June 3, 1981, that these fire detector supervisory circuits had not been demonstrated OPERABLE since this requirement was initiated in Amendment No.
22 to License No. DPR-58 effective January 12, 1978 for Unit 1 and in License No. DPR-74 effective December 23, 1977 for Unit 2.
During this three and one-half year time period, equipment in all fire detection zones had been required to be OPERABLE.
Due to inadequate management controls, the licensee was apparently not aware of this missed OPERABILITY test require-ment.
Consequently no action had been taken to satisfy the Technical Specification Limiting Condition for Operation by fulfillingthe Action Statement requirements.
On June 4, 1981, licensee management was formally informed of this violation.
On June 9,
1981, the inspector contacted the licensee to verify compliance with the Technical Specification Limiting Condition for Operation, and found that the hourly fire watch patrol requirement of the Action Statement.
had not been satisfied and that the supervisory circuits had not been demonstrated OPERABLE.
The licensee subsequently satisfied the Action Statement requirements one hour after this contact from the inspector on June 9,
1981.
Additionally, the licensee failed to submit the report required by Technical Specification 6.9 concerning this violation.
When the OPERABILITY test of the supervisory circuits was completed on June 9, 1981, four supervisory circuits were found inoperable due to malfunctioning relays:
(a)
(b)
(c)
(d)
1 - HV-1 " HV-1 " HV "
System 1 " HV-System CPR Containment Pressure Relief System Fan CPIX Instrument Room Purge Exhause Fan CFT -
1 Containment Auxiliary Charcoal Filter
- Cleanup Unit 1 CFT - 2 Containment Auxiliary Charcoal Filter
- Cleanup Unit 2 These circuits were repaired and demonstrated OPERABLE on June 10, 1981.
While these supervisory circuits were in-operable, the ability of the detection system to detect fires was not impaired, but the system capability to annunciate internal malfunctions was degraded.
The detection systems associated with the inoperable supervision circuits were found to be OPERABLE.
This OPERABILITY test of the super-visory circuits has now been incorporated into the routine testing program.
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Noncompliance (50-315/81-11-02; 50-316/81-14-02):
Technical Specification 4.7.9.1.l.e.4 for Units 1 and 2 states in part,
"4.7.9.1.1 The fire suppression water system shall be demon-strated OPERABLE...
(e)
At least once per 18 months by performing a system functional test which includes simulated automatic actuation of the system throughout its operating sequence, and...
4.
Verifying that each high pressure pump starts (sequentially) to maintain the fire suppression water system pressure~100 psig."
Contrary to the above, the fire suppression water system was not demonstrated OPERABIE within this specified time period including the additional 25 percent grace period provided in Technical Specification 4.0.2 for Units
and 2, and the licensee did not satisfy the associated Action Statement.
Additionally, the licensee failed to submit the report required by Technical Specification 6.9 concerning this violation.
Operations Head Procedure 12-OHP 4030.STP.122, Data/Signoff Sheet 6.1, "Fire Protection Water Iogic Pump Start Sequence,"
is written to satisfy the 18 month testing requirement con-tained in Technical Specification 4.7.9.1.l.e.4.
This test procedure was completed on May 5, 1979, and con-sequently was due to be completed again on November 5, 1980.
The test was not performed until April 7, 1981.
The time period between these two tests, twenty-three months and two days, exceeds the specified time period including the addi-tional twenty-five percent grace period (twenty-two and one-half months).
Due to inadequate management controls, the licensee was unaware of this overdue operability test, so no actions were taken to satisfy the Technical Specifi-cation Limiting Condition for Operation by fulfillingthe Action Statement requirements in Section 3.7.9.1 which states in part, "Establish a backup fire suppression water system within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and submit a Special Report in accordance with Specification 6.9.2..."
This Action Statement was applicable between March 20, 1981 and April 7, 1981.
Noncompliance (50-315/81-11-03; 50-316/81-14-03):
Technical Specification 3.7.9.2 for Units 1 and 2 states in part,
"The spray and/or sprinkler systems located in the areas shown in Table 3.7-5 shall be OPERABLE...whenever equipment in the spray/sprinkler protected areas is required to be OPERABLE...
With one or more of the above required spray and/or sprinkler systems inoperable, establish a continuous fire watch with
backup fire suppression equipment for the unprotected area(s),
within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />."
Technical Specification 4.7.9.2 for Units 1 and 2 states in part, "4.7.9.2 Each of the above required spray and/or sprinkler systems shall be demonstrated to be OPERABLE:
a.
At least once per 12 months by cycling each testable valve in the flow path through at least one complete cycle of full travel.
b.
At least once per 18 months:
1.
By performing a system functional test which includes simulated automatic actuation of the system, and; a)
Verifying that the automatic valves in the flow path actuate to their correct positions on a test signal, and b)
Cycling each valve in the flow path that is not testable during plant operation through at least one complete cycle of full travel."
Contrary to the above, on January 3,
1980, the licensee identi-fied that the following spray and/or sprinkler systems listed in Technical Specification Table 3.7-5 had not been demonstrated OPERABLE since these Technical Specification requirements were initiated in Amendment No.
22 to License No. DPR-58 effective January 12, 1978 for Unit 1 and in License No.
DPR-74 effective December 23, 1977 for Unit 2:
1-HV-AES-1 Charcoal Filters 1-HV-AES-2 Charcoal Filters 2-HV-AES-1 Charcoal Filters 2-HV-AES-2 Charcoal Filters 12-HV-AFX Charcoal Filters 1-HV-CPR-1 Charcoal Filters 2-HV-CPR-1 Charcoal Filters 1-HV-CIPX-1 Charcoal Filters 2-HV-CIPX-1 Charcoal Filters 1-HV-ACRF-1 Charcoal Filters 2"HV-ACRF-1 Charcoal Filters Auxiliary Building Cask Handling Area (Shared system by Units 1 and 2)
Auxiliary Building Drumming Area (Shared system by Units
and 2)
During this two-year time period, all of the spray and/or sprinkler protected equipment had been required to be OPERABLE.
Due to inadequate management controls, the licensee was unaware
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that these 12 month and 18 month OPERABILITY demonstration tests were overdue.
Consequently, no efforts were made prior to January 3,
1980, by the licensee to satisfy the Limiting Condition for Operation by fulfillingthe Action Statement requirements.
Also, licensee management stated that no efforts were made to satisfy the Action Statement requirements between the time the violation was identified on January 3, 1980, and the time the OPERABILITY tests were completed on February 6, 1980 for the Charcoal Filter protection systems and March 3, 1980 for th'
Auxiliary Building Cask Handling and Drumming Area protection
,systems.
When these tests were completed, the spray and/or sprinkler systems were found to be OPERABLE and the OPERABILITY tests were incorporated into the routine testing program.
Additionally, the licensee failed to submit the report required by Technical Specification 6.9 concerning this violation.
Noncompliance (50-315/81-11-04;50-316/81-14-04):
CFR 50 Appendix B, Criterion V, states in part, "Activities affecting quality shall be prescribed by documented...procedures...and shall be accomplished in accordance with these...procedures.
Procedures...shall include appropriate quantitative or quali-tative acceptance criteria."
Plant Manager Instruction, PMI 2010, "Plant Manager and Department Head Instructions, Procedures and Associated Indexes,"
implements these requirements of 10 CFR 50 Appendix B, Criterion V.
PMI 2010 states in part, "Accept-ance criteria shall include the specific requirements that must be obtained before a Procedure can be considered as having been properly completed."
Contrary to the above, Operations Head Procedure, 1-OHP 4030.STP.120, Data/Signoff Sheet 6.5, "Auxiliary Building Water/C02 Flow Path Verification," does not include any acceptance criteria for determining the proper completion of the procedure.
Consequently, the Data/Signoff Sheet 6 '
completed on February 27, 1981 contained erroneous data that the licensee could not duplicate.
This data invalidated the test, but because there were no acceptance criteria, the test was approved as being satisfactorily completed.
The recorded data did not indicate that the equipment was inoperable.
The tests in January, 1981 and March, 1981 contained accept-able data indicating that the equipment was OPERABLE.
Noncompliance (50-. 315/81-11-05;50-316/81-14-05):
Technical Specification 3.7.10 for Units 1 and 2 states in part, "All penetration fire barriers protecting safety related areas shall be functional...
At all times,"
Technical Specification 4.7.10 for Units 1 and 2 states in part,
"Each of the above required penetration fire barriers shall be verified to be functional by a visual inspection...
at least once per 18 months."
The Bases for Technical Specifications 3/4.7.10 states in part,
"The functional integrity of the penetration fire barriers ensures that fires will be confined or adequately retarded from spreading to adjacent portions of the facility.
This design feature minimizes the possibility of a single fire rapidly involving several areas of the facility prior to detection and extinguishment."
Contrary to the above, at the time of this inspection, the licensee had not verified that fire doors and fire dampers protecting safety related areas were functional since this requirement was initiated in Amendment No.
22 to License No. DPR-58 effective January 12, 1978 for Unit 1 and in License No. DPR-74 effective December 23, 1977 for Unit 2.
The inspector identified during a plant tour that the six fire door assemblies protecting the Unit 1 and 2 Turbine Driven and Motor Driven (East) Auxiliary Feedwater Pumps were not functional due to either inoperable closure and/or latching mechanisms or obstruction.
At the time of this observation, Unit 1 was shut down for refueling and Unit 2 was operating at power.
On June 4, 1981, licensee management was formally informed of this violation and the degraded fire barriers in the'uxiliary Feedwater Pump areas.
The licensee did not satisfy the Limiting Condition for Operation by fulfillingthe Action Statement requirements which state in part, "With one or more...penetration fire barriers non-functional, establish a
continuous fire watch on at least one side of the affected penetration within one hour."
The licensee did assign per-sonnel to inspect and repair the closure and latching mechanisms on these doors and remove any obstructions.
This activity was accomplished by 0730 on June 5, 1981.
The licensee failed to submit the report required by Technical Specification 6.9 concerning this violation.
On August 28, 1981, the licensee identified twelve additional fire door assemblies in the plant that were not functional because the doors were not rated for fire resistance.
The licensee did not take adequate actions to satisfy the Action Statement requirements.
The licensee takes issue with this item of noncompliance based on statements in the discussion section of the Safety Evaluation Report supporting the issuance of these Technical Specifications'0-
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The Safety Evaluation Report dated December 12, 1977 supporting Amendment No.
22 to License No. DPR-58 stated in part,
"The equipment and components currently existing at this facility included in the scope of these Technical Specification requirements are...piping and cabling penetra-tion fire barriers...
The functional integrity of the penetration fire barriers provides protection to confine or retard fires from spreading to adjacent portions of the facility."
The licensee interpreted this stat'ement to indicate that it is not necessary to perform visual inspections of fire doors and fire dampers to verify their functional integrity.
Consequently, the licensee did not develop a surveillance inspection program for fire doors and fire dampers and did not consider the Limiting Condition for Operation to be applicable to these penetration fire barriers.
Region III, with concurrence from the NRR fire protection licensing staff, does not consider that these statements in the discussion section of the Safety Evaluation Report can be utilized to modify the purpose of the Technical Specification Limiting Condition for Operation as stated in the Technical Specification Bases.
The functional integrity of fire doors and fire dampers as well as piping and cabling penetration fire barriers
"ensures that fires will be confined or adequately retarted from spreading to adjacent portions of the facility." Without verifying the integrity of fire doors and dampers, there can be no con-fidence in the fire containment qualities of the facility structure necessary to protect redundant safety related equipment from exposure fire damage.
Noncompliance (50-315/81-11-06(A); 50-316/81-14-06(A):
As a part of the NRC staff review of fire protection at the D.
C.
Cook Nuclear Plant Units 1 and 2, the staff requested, by letter dated September 30, 1976, that the licensee prepare a fire hazards analysis of the Cook Plant.
This letter stated in part, "...In order to begin a re-evaluation of the fire protection program at your facility, you must perform a fire hazards analysis with the assistance and technical directions of a qualified fire protection engineer.
In order for us to evaluate your fire hazards analysis we require that you submit the results in sufficient detail."
The licensee's response to this request, which the staff relied upon in reaching its conclusions regarding the ac-ceptability of the licensee's fire protection program, was contained in the licensee's submittal dated March 31, 1977,
"Fire Hazards Analysis Units 1 and 2."
The licensee described the existing method of fire containment in Fire Zones 9,
10, 11 "
f I t y*
11, 12, 22, 24, 25, 26, 38, and 39 in applicable parts of the
"Fire Hazards Analysis.
This description stated that these fire zones were protected by "Class B [Underwriters Labora-tories rated]
doors and dampers."
These statements are false in that the following doors in the indicated fire zones carry no fire resistance rating as indicated by facility design drawings, procurement and reciept inspection documents or visual inspection:
Fire Zone Door Number
10ll
25
12
38
39
323 339 325 326 324 341 373 374 385 387 386 388 The submittal of a false statement in a license application or in other information that the Commission may deem necessary is contrary to Section 186 of the Atomic Energy Act of 1954, as amended.
Noncompliance (50-315/81-ll-06(B); 50-316/81-14-06(B):
As a part of the NRC staff review of fire protection at the D.
C.
Cook Nuclear Plant Units 1 and 2, the staff trans-mitted several questions concerning the licensee's Fire Hazards Analysis dated July 17, 1977.
NRC question No.
stated in part,
"You did not consider the unprotected openings in analyzing a fire in the turbine driven auxiliary feed pump rooms.
Analyze the effect of this fire on the redundant cable outside the room and the other auxiliary feed pump rooms..."
The licensee's response to this question, which the staff relied upon in reaching its conclusions regarding the accept-ability of the licensee's fire protection program, was contained in the licensee's submittal dated November 22, 1977.
This response, in applicable parts, stated,
"The four feedwater pump rooms are equipped with Underwriters Labora-tories three hour rated fire doors so a fire in any one of the pump rooms will not spread..."
This statement is false in that the doors to the four auxiliary feedwater pump rooms, Doors No. 226, 227, 228 12-
f '
and 229, carry no fire resistance rating as indicated by facility design drawings, procurement and reciept inspec-tion documents or visual inspection.
The submittal of a false statement as part of a license application or in other information that the Commission may deem necessary is contrary to Section 186 of the Atomic Energy Act of 1954 as amended.
c.
Deviations Deviation (50-315/81-11-07; 50-315/81"14-07):
"Donald C.
Cook Nuclear Plant Response to Appendix A to Branch Technical Position APCSB 9.5-1 for Units 1 and 2," submitted to the NRC on January 31, 1977,Section II.D.l.J y states in part, "All doors...enclosing separated fire areas...carry UL Class A (three hour) fire rating."
"Donald C.
Cook Nuclear Plant Fire Hazards Analysis," submitted to the NRC on March 31, 1977, describes the fire protection measures which are taken in all areas of the plant.
Concerning the method of fire containment for the Unit 1 and Unit 2 Diesel Fire Pump Rooms, the Fire Hazards Analysis states,
"Walls, floor, ceiling; a%i reinforced concrete and in excess of three hour rating.
Class A (three hour) door."
Contrary to the above, at the time of this inspection, the Unit 1 and Unit 2 Diesel Fire Pump room fire doors did not maintain their UL Class A (three hour) fire rating due to inoperable latching mechanisms.
d.
Discussion Unresolved Item (50-315/81-11-08; 50-316/81-14-08):
Technical Specification 3.7.9.4 for Units 1 and 2 states in part,
"The Halon system located in the Unit 1 and Unit 2 Control Room Cable Spreading Area shall be OPERABLE...Whenever equipment in the Halon protected areas is required to be OPERABLE...With the above required Halon system inoperable, verify that the fire detection system and the backup C02 fire suppression system are OPERABLE; otherwise, establish a continuous fire watch with backup fire suppression equipment for the unprotected area, within one hour."
The licensee described the personnel hazards of the Halon 1301 system operation in the "Donald C.
Cook Nuclear Plant Response to Appendix A to Branch Technical Position APCSB 9.5-1 for Units 1 and 2" dated January 31, 1977.
Sections II.E.4(b) and (c) of that document state in part,
"The toxicity of undecom-posed Halon 1301 has been considered...In the concentrations specified for Cook Plant, toxic effects of undecomposed Halon 1301 present no hazard..
~ Toxicity and Corrosivity of the decomposed Halon 1301 have been considered.
Due to the immedi-
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ate discharge of the agent on detection of fires before a large flame front develops, production of toxic and corrosive gasses is minimized and would be less than the products of combustion."
Onsite licensee management apparently misunderstood the personnel hazards associated with a Halon 1301 automatic suppression system and initiated a procedure to isolate the automatic actuation of the Halon 1301 system for personnel protection when anyone entered the. Unit 1 or Unit 2 Control Room Cable Spreading Areas.
This mode of operation unnecessarily degrades the fire protection of a critical safety related area of the plant.
On June 4, 1981, the inspector discussed these concerns with onsite licensee management.
On July 7, 1981 the licensee re-vised this mode of operation and "discouraged" the isolation of the Halon 1301 system when personnel are present and that the system "should" not be isolated except for testing and maintenance on the system.
This was contained in Temporary Sheet TP-8 to Plant Manager Instruction PMI-2270, "Fire Protection and Safety Equipment."
This item will remain unresolved pending review of further licensee actions to exercise positive control over the Halon 1301 system isolation switch to prohibit isolation of the systems except when necessary for maintenance and testing when the Technical Specification Action Statement requirements will be implemented.
This action will include retraining employees and contractors in the hazards of the Halon 1301 protected areas and the new operational mode of the system.
Unresolved Item (50-315/81-11-09; 50-316/81-14"09):
Technical Specification 3.7.9.2 for Units 1 and 2 states in part,
"The spray and/or sprinkler systems located in the areas shown in Table 3'-5 shall be OPERABLE...Whenever equipment in the spray/
sprinkler protected areas is required to be OPERABLE...With one or more of the above required spray and/or sprinkler systems inoperable, establish a continuous fire watch with backup fire suppression equipment for the unprotected area(s),
within one hour."
Technical Specification 4.7.9.2 for Units 1 and 2 states in part,
"4.7.9.2 Each of the above required spray and/or sprinkler systems shall be demonstrated to be OPERABLE:
a.
At least once per 12 months by cycling each testable valve in the flow path through at least one complete cycle of full travel.
b.
At least once per 18 months:
1.
By performing a system functional test which includes simulated automatic actuation of the system, and;
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a)
Verifying that the automatic valves in the flow path actuate to their correct positions on a test signal, and b)
Cycling each valve in the flow path that is not testable during plant operation through at least one complete-cycle of full travel."
On July 31, 1981, the inspector identified that the following spray and/or sprinkler systems listed in Technical Specifica-tion Table 3,7-5 had not been demonstrated OPERABLE since the systems were preoperationally tested:
Unit 1 Reactor Coolant Pumps Unit 2 Reactor Coolant Pumps Auxiliary Building Elevations 587 and 609 including:
Charging Pump Rooms Safety Injection Pump Rooms Corridors Laundry Area (Shared system by Units 1 and 2)
These technical specification requirements were initiated in license Amendment No.
44 for Unit 1 and license Amendment No.
for Unit 2 effective January 30, 1981.
At the time those amend-ments were issued, it had been approximately 18 months since the 12 and 18 month operability tests had been performed as part of system preoperational testing.
By July 31, 1981 when the in-spector discovered this situation, it had been approximately
months since the tests were performed.
Within one hour after the inspector informed the licensee of the situation on July 31, 1981 the licensee established an hourly fire watch patrol of the affected areas in the Auxiliary Building.
No action was taken concerning the Units 1 and 2 Reactor Coolant Pump Areas.
These actions were not adequate to satisfy the Limiting Condition for Operation for these systems.
Concerning the Auxiliary Building shared systems, a continous, dedicated fire watch was established on August 4, 1981, for the affected areas.
Installed local manual fire suppression equipment was available for use by the fire watch.
The Auxil-iary Building Elevations 587 and 609 sprinkler systems were demonstrated operable on August 6, 1981 and the fire watch was terminated, No system degradation was discovered during the OPERABILITY testing.
The licensee failed to submit the required report concerning this matter.
Concerning the Unit 1 and 2 Reactor Coolant Pump sprinkler systems, on August 7, 1981, Operations Department Memo OM 81-93 was issued describing the actions to be taken in the event of a fire in con-tainment.
The fire watch requirement was satisfied by utilizing the installed fire detection systems and backup fire suppression
"15"
~
~
was provided through utilization of the containment spray system.
When the OPERABILITY tests were conducted, the systems were de-clared inoperable due to malfunctioning solenoid actuation valves.
An orifice in the valve was plugged, preventing the sprinkler system flow control valve from modulating after an actuation as designed.
The Unit 1 Reactor Coolant Pump sprinkler systems were repaired, tested and declared OPERABLE on August 10, 1981.
The Unit 2 systems remained inoperable.
Because the elapsed time (approximately 7 months)
between the issuance on January 30, 1981, of Amendment No. 44 (Unit 1) and Amendment, No.
26 (Unit 2) and the completion of testing did not exceed the 12 and 18 month requirements of Technical Specifi-cation 4.7.9.2, the matter is not considered to be a violation.
However, prudent engineering practice would have been to test the systems as soon as possible following issuance of the amend-ments to attempt to comply with the intent of Technical Specifi-cation 4.7.9.2 which is to demonstrate operability of equipment and by conducting tests during specified intervals.
This item will remain unresolved pending review of the licensees implemented surveillance testing program for these systems.
3.
Manual Fire Fi htin E ui ment The inspector examined the licensee's manual fire fighting equipment including selected hose and standpipe stations, portable fire extin-guishers, self-contained breathing apparatus and other equipment available for fire fighting.
The equipment was reviewed using the commitments and requirements in the "Fire Protection Safety Evaluation Report," dated July 31, 1979, the "Fire Hazards Analysis," dated March 31, 1977, the "Response to Branch Technical Position APCSB 9.5-1," dated January 31, 1977, and the fire protection Technical Specifications.
a.
Areas of Ins ection (1)
Procedures Number Title Dates PMI 2270 Fire Protection and Safety Equipment PMI 4030 Technical Specification Surveillance 12QHP 2270.FIRE.001-7 Monthly Inspections and Semi Annual Maintenance of Port-1/30/81, able Fire Extinguishers 2/26/81
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I
Number Title
'ates 12QHP 2270.FIRE.002"1 Hydrostatic Testing of Fire Hoses
, 5/80 12QHP 2270.FIRE.002-2 12QHP 2270.FIRE.003-1 12QHP 2270.FIRE.004-1 12QHP 2270.FIRE.005-1 Visual Inspection of Fire Hoses Monthly Inspection of Fire Hydrant Equipment Cabinets Monthly Inspection of Foam Stations Monthly Fire Truck Accessory Inspection 3/79, 5/80 1/22, 2/17 3/7, 8 4/23/81 1/27, 2/23, 3/30, 8 4/27/81 1/2, 2/3, 3/23 S 4/22/81 12QHP 2270.FIRE.007-2 (2)
Plant Tours Monthly Visual Inspection of 1/8, 2/9, the Plant Hose Standpipe 3/9, 4/9, Connections 6 5/8/81 The inspector examined selected manual fire fighting equipment during tours of the following plant areas:
Turbine Building Auxiliary Building Circulating Water Pump and Screen House Plant Yard b.
F~indin n
No items of noncompliance were identified in this area.
4.
Fire Protection and Prevention Administrative Controls The inspector examined the licensee's fire protection and prevention administrative controls including the control of combustible and flammable materials, control of ignition sources, housekeeping controls, fire emergency response procedures, and fire protection audits and inspections.
The administrative controls were reviewed using the corn-mitments and requirements in the "Fire Protection Safety Evaluation Report," dated July 31, 1979, the "Response to Branch Technical Position APCSB 9.5-1," dated January 31, 1977, and the fire protection Technical Specifications.
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a.
Areas of Ins ection (1)
Procedures Number PMI 2090 PMI 2271 PMI 2275
- PMP 2080.EPP.016 PMP 2082.EPP.006 PMP 2080.EPP.009 EPP APPENDIX A Title Housekeeping/Plant Cleanliness Control of Combustible Materials Fire Prevention - Control of Ignition Sources Formation of Emergency Teams Fire Emergencies Emergency Procedure Drills, Alarm Tests, and Training Emergency Plan Training Fire Emergency Guidelines Telephone Numbers for Offsite Groups-These procedures are no longer in effect.
PMP 2082.EPP.006 and PMP 2080.EPP.009 replaced these procedures effective March 31, 1981.
(2)
R~e orts Title American Electric Power System Fire Reports D.
CD Cook Nuclear Plant Plant Safety Committee Meeting Minutes Quality Assurance Audit Report No.QA-80-17 Quality Assurance Audit Report No. QA-78-15 NSDRC Audit Report No. 56 NSDRC Audit Report No.
Quality Assurance Surveillance Reports Control of Combustible Materials jI2-80-622 Hot Work Permit Review 812-80-231 Hot Work Permit Review g12-80-360 Hot Work Permit Review j/12-80-543 Hot Work Permit - Turbine Bldg.
812-80-427 Hot Work Permit - Auxiliary Bldg.j/12-80-483 Auxiliary Building Tour jj12-80-545 Auxiliary Building Tour jj12-80-544 Fire Extinguisher Inspection jjl2-80-229 Foam Section Inspection gl2-80-501 (3)
Plant Tours Date 1980(5 reports)
1980(monthly)
4/22/81 8/25/78 12/3"6/79 12/1"5/80 1980(10 Reports)
The inspector examined the implementation of fire protection and prevention administrative controls during tours of the following plant areas:
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Tubine Building Auxiliary Building Containment Electrical Penetration Area Circulating Water Pump and Screen House cindias Noncompliance (50-315/81-11-06(C);
50-316/81-14-06(C):
As a part of the NRC staff review of fire protection at the D.
C.
Cook Nuclear Plant Units 1 and 2, the staff requested by letters dated July 16, 1976 and July 30, 1976 that the licensee prepare a point by point comparison of the fire protection program at Cook Plant to the positions in Appendix A to Branch Technical Position APCSB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976." Position B.2. stated in part, "Effective administrative measures should be implemented to prohibit bulk storage of combustible materials inside or adjacent to safety related buildings or systems during opera-tion or maintenance periods."
The licensee's response to this position, which the staff relied upon in reaching its conclusions regarding the acceptability of the licensee's fire protection program, was contained in the licensee's submittal dated January 31, 1977,
"Response to Appendix A to Branch Technical Position APCSB 9.5-1 for Units
and 2."
Section B.2. of this response, in applicable parts, stated,
"Administrative measures have been established to control the storage of combustible materials and to prohibit their storage in the vicinity of safety related systems."
This statement is false in that when the statement was made, administrative procedures had not been established to prohibit the storage of combustible materials in the vicinity of safety related systems.
Upon further questioning by the NRC inspector, the licensee could not identify any other administrative measure (training, instructions, etc.) that was utilized to prohibit the storage of combustible materials in the vicinity of safety related systems.
The submittal of a false statement as part of the license applica-tion or in other information that the Commission may deem necessary is contrary to Section 186 of the Atomic Energy Act of 1954 as amended.
Amendment No.
31 for Unit 1 and Amendment No.
12 for Unit 2 effective July 31, 1979 states in parts,
"Administrative controls for fire protection as described in the licensee's submittals dated January 31, 1977...shall be implemented and maintained."
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Contrary to the above, on June 4, 1981,, administrative measures had not been established to prohibit the storage of flammable and combustible liquids in the vicinity of safety related systems.
Plant Manager Instruction.PMX-2271, "Conti'ol of Combustible Materials,"
was established'n July-28, 1977.
This procedure was inadequate, as of June 4, 1981, in that it did not prohibit the storage of combustible and flammable liquids in the vicinity of safety related systems and the inspector observed improper storage of these materials in the following safety related areas.
Auxiliary Feedwater Pump Area - flammable solvents Unit 2 East Essential Service Water Pump Area - grease and oily rags Unit 2 West Motor Driven Auxiliary Feed Water Pump Area-lumber and rags Unit 2 Turbine Driven Auxiliary Feed Water Pump Panel 2TFP - bundle of rags Unit 2 Component Cooling Water Heat Exchanger Area-Spray Paint Unit 2 Diesel Fire Pump Room - Wooden Iadders Open Item (50-315/81-11-10; 50-316/81-14-10):
ANSI N45.2.3-1973, Section 2.1, states in part,
"Necessary procedures...shall be identified...Cleanness requirements for housekeeping activities shall be established on the basis of...zone designations."
These zone designations describe the necessary cleanliness controls over personnel and materials which are necessary to preserve the requisite quality of the equipment.in the various areas of the plants.
ANSI N45.2.3-1973, Section 2.2 states in part,
"The procedures and instructions for housekeeping activities shall be prepared."
ANSI N45.2.3-1973, Section 3.2, states in part,
"The control of all tools, equipment, materials and supplies...shall be maintaine'd to prevent the inadvertent inclusion of deleterious materials or objects in critical systems."
ANSI N45.2.3-1973, Section 3.2.1, states in part,
"Excess material shall not be allowed to accumulate..."
The housekeeping procedures developed by the licensee do not implement all the above requirements of ANSI N45.2.3-1973 except for housekeeping procedures covering refueling activities.
An example of the lack of housekeeping controls was identified in the 2AB Diesel Generator Room where a large table was covered with loose spare parts and a large roll of absorbent material was lying on the floor.
No one was working on the system at the time of this observation.
This matter will be reviewed further during a sub-sequent inspection.
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5.
Fire Protection and Prevention Trainin The inspector examined the licensee's fire protection and prevention training program for general employees, contractors and fire brigade members.
The fire protection and prevention training program was reviewed using the commitments and requirements in the "Fire Protection Safety Evaluation Report" dated July 31, 1979, the "Response to Branch Technical Position APCSB 9.5-1," dated January 31F 1977F the fire protection Technical Specifications, and the "Final Safety Analysis Report," Amendment No. 80, effective December1977, a
~
Areas of Ins ection (1)
Procedures Number Title PMI 2070
"FPMP 2080.EPP.016 Training Emergency Procedure Drills, Alarm Tests, and Training PMP 2082.EPP.006 Emergency Plan Training
>This procedure is no longer in effect.
PMP 2082.EPP.006 replaced this procedure effective March 31, 1981.
(2)
Observations The inspector observed the general employee training session on June 1,
1981.
,b.
~Findin n
Noncompliance (50-315/81-11-11; 50-316/81-14-11):
Technical Specification 6.8.1.e for Units 1 and 2 states in part, "Written procedures shall be established, implemented and maintained covering the...emergency plan implementation."
The Donald C.
Cook Emergency Plan contained in Section 12.3.1 of the Final Safety Analysis Report was amended in December 1977 (Amendment No. 80) to include a requirement that fire brigade members participate in quarterly fire drills.
Part IX.F.4. of Section 12.3.1 of the Final Safety Analysis Report states in part,
"Fire Brigade [training includes]...participation in quarterly fire drills."
Contrary to the above, no written procedure was established covering this emergency plan requirement and the requirement was not implemented on four occasions; the Operating Shift A Fire Brigade did not participate in a fire drill in the second quarter of 1979, the Operating Shift C Fire Brigade did not participate in
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a fire drill in the third quarter of 1979, the Operating Shift B Fire Brigade did not participate in a fire drill in the third quarter of 1980 and the Operating Shift D Fire Brigade did not participate in a fire drill in the fourth quarter of 1980.
c.
Discussion Unresolved Item (50-315/81-11-12; 50-316/81-14-12):
The inspector observed a general employee training session on June 1, 1981, and noted that the following subject areas were not discussed in the training session.
(1)
The controls over use and storage of combustible and flammable materials in safety related areas; (2)
The controls over use of ignition sources in safety related areas.
The inspector brought these inadequacies to the attention of the Plant Training Supervisor who committed to include these subject areas in the revision of the general employee training program which will be completed before September 15, 1981.
6.
Licensee Action on Previous Ins ection Findin s (Closed)
Noncompliance (50-315/80-01-08; 50-316/80-01-08):
Failure of plant general safety committee to perform quarterly housekeeping inspec-tions.
The inspector found that housekeeping inspections are being performed monthly by the Quality Assurance Department as is procedurally required.
The Plant General Safety Committee is meeting monthly and apparently fulfillingall 'of its*functions'.
This information was obtained through review of monthly housekeeping inspection reports and committee meeting minutes.
7.
Licensee Event Re ort Review H
The inspector reviewed Iicensee Event Report No. 81-009/03L-0 for Unit 1 and No. 81-008/03L-0 for Unit 2 concerning the water fire'uppression system on the HVAC charcoal filters for completeness and correctness of reported information and adequacy of the corrective actions and actions to prevent recurrance.
The information provided in the reports is complete and correct and the corrective actions in conjunction with the required Technical Specifica-tion surveillance tests appear adequate to prevent recurrence and assure system integrity in the future.
These licensee event, reports are con-sidered closed.
8.
Exit Interview The inspector met with the licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection on June 4 and August 13, 1981.
The purpose and scope of the inspection was summarized and the findings were discussed.
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