IR 05000315/1985013
| ML17334A904 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 08/23/1985 |
| From: | Guldemond W, James Heller, Jorgensen B, Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17321A858 | List: |
| References | |
| 50-315-85-13, 50-316-85-13, NUDOCS 8509030156 | |
| Download: ML17334A904 (52) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-315/85013(DRS);
50-316/85013(DRS)
Docket No. 50-315; 50-316 License No.
American Electric Power Service Company (AEPSC)
& Michigan Power Company 1 Riverside Plaza Columbus, Ohio 43216 Facility Name:
D. C.
Cook Nuclear Plant, Units 1 and
Inspection At:
D.
C.
Cook Site, Bridgman, Michigan Inspection Conducted:
April 29 through May 3, June 21, and August 5-9, 1985 Inspector:
.
M. lie g/is/ar ate
. Qorgensen
. P'. Heller d~>
da Da e
Da e
Approved By:
.
G.
ulde ond, Chief Operational Programs Section Ins ection Summar 8/sa gs-Date Ins ection on A ril 29 throu h
Ma 3, June 21, and Au ust 5-9, 1985 Re ort Nos.
50-31 013 DRS 50-31
DRS Areas Ins ected:
Special, announced inspection by Region III inspectors of the tec nica status of outstanding fire protection issues, fire protection program implementation, and a review of allegations received by the NRC relative to fire penetration seals.
The inspection involved a total of 96 inspector-hours onsite and in-office review by three NRC inspectors including 17 inspector-hours on-site during off-shifts.
Results:
In the eight areas inspected, no violations were identified.
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C DETAILS 1.
Persons Contacted D. C. Cook Nuclear Plant
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Allard, Maintenance Superintendent Baker, Operations Superintendent A. Baker, guality Control Department, Administrative Coordinator Beilman, Design Change/Outage Planning Supervisor Blind, Assistant Plant Manager of Maintenance Bobay, General Supervisor of Outages Burke, Maintenance Engineer Fyrer, Radiation Protection Section Head Gerwe, Fire Protection Engineer, AEPSC Jacques, Fire Protection Coordinator Helms, Production Supervisor Kauffman, Chief Electrical Construction Kraus, Administrative Compliance Coordinator Murphy, Production Supervisor Pauls, Design Change Coordinator Scheffers, Outage/Planning Superintendent Smith, Jr., Plant Manager Stanwenzlick, Planning, Design Change Coordinator Stark, Performance Engineer Stietzel, guality Control Department Superintendent Svensson, Assistant Plant Manager of Operations Warm, Administrative Compliance Coordinator Widerwax, guality Control Supervisor Wizner, Maintenance Administrative Coordinator Compliance American Electric Power Service Cor oration
- A. Auvil, Nuclear Operating Department/Nuclear Safety and Licensing P. Barrett, Lead Compliance Engineer J. Feinstein, Manager, Nuclear Safety and Licensing Department
- J. Grier, Assistant Section Manager, Fire Protection/HVAC R. Keating, Section Head, Fire Protection/HVAC C. Toth, Configuration Control Engineer J. Zott, Fire Protection Engineer
- Denotes persons attending the exit meeting of May 3, 1985.
- Denotes persons attending the exit meeting of August 9, 1985 only.
- Denotes persons attending the exit meetings of May 3 and August 9, 1985.
The inspector also contacted other licensee personnel including members of the training and engineering departments.
The following NRC individual also attended the exit meeting of August 9, 1985.
W. Guldemond, Chief, Operational Programs Section, Region II n
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Action on Previous Ins ection Findin s a.
(Closed)
Noncompliance (315/81-1 1-01; 316/81-14-01):
The inspector found on June 3, 1981, that Technical Specification (TS) required fire detector supervisory circuits had not been demonstrated operable as required.
On June 9, 1981, the operability test of the supervisory circuits was completed.
The inspector reviewed the pertinent sections of the procedure numbered 12-THP.6030. IMP. 142 relative to satisfying the 6 month testing requirement contained in TS 4.3.3.7.2 for Unit 1 and 4.3.3.8.2 for Unit 2.
The inspector requested and was provided three surveillance test procedure results for 1982 and 1983.
These test procedures were satisfactorily completed at the required frequency.
b.
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d.
(Closed)
Noncompl iance (315/81-11-02; 316/81-14-02):
The fire suppression water system was not demonstrated operable at the required periodicity.
Testing was completed on May 5, 1979, and was due to be completed again on November 5, 1980.
The test was not performed until April 7, 1981.
The inspector reviewed the pertinent sections of the procedure previously numbered 12-0HP.4030.STP.
122 and currently numbered 12-THP.4030.STP.223 to verify that the procedure satisfies the eighteen month testing requirement of TS 4.7.9. 1. l.e.4.
The inspector requested and was provided the last three surveillance test procedure results since this item of noncompliance was identified.
The first surveillance test was performed by the Operations Department using Procedure No. 12-0HP.4030.STP.122 on September 9,
1982.
Test responsibility was then transferred and the following two surveillance tests were performed by the Performance Engineering Section per Procedure No. 12-THP.4030.STP.223 on, October 25, 1982, and again on September 7, 1984, consistent with the required periodicity.
(Closed)
Noncompliance (315/81-11-03; 316/81-14-03):
On January 3,
1980, the licensee identified that thirteen spray and/or sprinkler systems listed in TS Table 3.7-5 had not been demonstrated operable as required.
The operability tests were subsequently completed on February-6, 1980 and March 3, 1980.
The inspector reviewed the pertinent sections of procedure number 12-THP.4030.STP.223 which is performed on an annual basis to satisfy TS 4.7.9.2 requirements.
The inspector requested and was provided the two most recent sur-veillance test procedures which were completed satisfactorily on April 15, 1984 and April 16, 1985, respectively.
(Closed)
Noncompliance (315/81-11-04; 316/81-14-04):
Operations Procedure, 1-0HP.4030.STP.120, Data/Signoff Sheet 6.5, entitled,
"Auxiliary Building Water/CO Flow Path Verification," did not include acceptance criteria.
The inspector reviewed revised Procedure No. 1-0HP.4030.STP. 120 and verified that the signoff sheet portion of the procedure included acceptance criteria. Prior to the inspector's departure from the site the licensee's staff initiated a
Procedure Revision/Correction Sheet to incorporate the acceptance criteria into the body of the procedure.
These acceptance criteria were reviewed by the inspector and determined to be adequat ew W
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(Closed)
Noncompliance (315/81-11-05; 316/81-14-05):
Penetration fire barrier TS surveillance inspections were not being performed as required for fire doors and fire dampers.
The licensee has incorporated surveillance requirements for fire dampers and fire doors in Plant TS Section 3/4.7. 10.
The inspector was provided copies of surveillance test procedures the licensee has implemented in meeting TS 4.7.10.
These surveillance test procedures are numbered 12-MHP.4030.STP.028, Revision 1, for fire dampers and 12-MHP.4030.STP.027, Revision 0, for fire doors and hatches.
On April 29, 1985, during a plant tour, the inspector visually inspected the six fire doors identified in the previous item of noncompliance and other fire doors.
The inspector verified that the closure and latching mechanisms were in operating order with the exception of minor maintenance work needed on three of the fire doors numbered 227, 228, and 229 located in the Auxiliary Feedwater Pump area.
The licensee's fire protection coordinator promptly initiated Work Order No. 73556 to repair the three fire doors.
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(1)
(Cl osed)
Noncompliance (315/81-11-06(A); 316/81-14-06(A) ):
As a part of the NRC 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.
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 protec-tion 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 acceptability 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, 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 Laboratories rated)
doors and dampers".
During the inspection documented in reports 50-315/85011 and 50-316/85014 numerous doors were identified that carried no fire resistance rating as indicated by facility design drawings, procurement and receipt inspection documents or visual inspection.
On May 17, 1985, the resident inspector visually verified that corrective action had been taken and that these areas were protected by properly rated fire doors.
(2)
(Cl osed)
Noncompliance (315/81-11-06(B);
316/81-14-06(B) ):
As a result of the NRC review of fire protection at D. C.
Cook the staff transmitted 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
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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 request, contained in their submittal dated November 22, 1977, stated that the four auxiliary feedwater pump rooms are equipped with Underwriters Laboratories three hour rated fire doors so a fire in any one of the pump rooms will not spread.
The doors to the four auxiliary feedwater pump rooms were subsequently found to carry no fire resistance rating as indicated by facility design drawings, procurement and receipt inspection documents or visual inspection.
A verbal report of this situation was made to the NRC on the evening of August 28, 1981.
An initial written report was submitted to the NRC on August 31, 1981, followed by a detailed report submitted September 18, 1981, correcting the incorrect information regarding the doors as provided in the March 31, 1977 report.
On May 2, 1985, the inspector verified that the fire doors had been replaced with rated fire doors.
g.
(Closed)
Deviation (315/81-11-07; 316/81-14-07):
The Unit 1 and
Diesel Fire Pump room fire doors did not maintain their UL Class A
(three hour) fire rating due to inoperable latching mechanisms.
On April 29, 1985, the inspector toured the Unit 1 and 2 Diesel Fire Pump room and verified that the fire doors latched and closed properly.
While performing the plant tour, the inspector observed the installa-tion of guartzoid bulb type fusible links on numerous fire doors located in safety-related areas of the plant to facilitate door closure in the event of a fire.
The inspector witnessed a satisfactory test of a guartzoid bulb fusible link on May 2, 1985.
h.
(Closed)
Unresolved Item (315/81-11-08; 316/81-14-08):
The inspector's concern related to the type of instruction provided to plant and contractor personnel on the Halon 1301 fire system including the determination of whether it is necessary for personnel to isolate the Halon system when entering Halon protected areas.
According to previous Halon system design criteria, a Halon system concentration of approximately five percent would not cause any side effects to individuals exposed to the Halon for up to fifteen minutes.
However, more recent Halon system concentration tests performed in the Unit 1 and 2 Control Room Cable Vaults showed Halon concentrations in excess of seven percent which, according to NFPA 12A, reduces personnel exposure time to approximately one minute.
Based on these more recent Halon concentration tests, the Plant Manager, at the exit meeting of August 9, 1985, indicated that plant policy for personnel entering areas being protected by a Halon system would require isolation of the system prior to entr t h
(Closed)
Unresolved Item (315/81-11-09; 316/81-14-09):
On July 31, 1981, the inspector identified that six spray and/or sprinkler systems listed in TS Table 3.7-5 had not been demonstrated operable since the systems were pre-operationally tested.
TS requirements were effective for Units 1 and 2 on January 30, 1981.
These sprinkler systems were subsequently demonstrated operable on August 6, 1981 and August 10, 1981 with the exception of the Unit 2 Reactor Coolant Pump sprinkler system which required repair.
The inspector requested and was provided two surveillance test procedures completed on April 15, 1984 and April 16, 1985 and verified both the procedures'dequacy and that operability had been satisfactorily demonstrated.
(Closed)
Open Item (315/81-11-10; 316/81-14-10):
A lack of housekeeping controls was previously identified in the 2AB Diesel Generator Room.
On May 2, 1985, while touring various safety-related areas of the plant, (including a tour of the 2AB Diesel Generator Room)
the inspector did not observe any noticeable problem in plant housekeeping activities as it related to fire protection.
(Cl osed)
Noncompliance (315/81-11-11; 316/81-14-11):
No written procedure was in place to have fire brigade members participate in quarterly fire drills as required in TS 6.8. l.e. Plant Manager Instruction No. PMI-2272, Revision 0, dated March 12, 1982, incor-porates fire brigade quarterly drill requirements as required by TS.
The inspector reviewed two of the shift fire brigade drill records for years 1982 and 1984 using the commitments contained in Section 12.3. 1 of the FSAR dated December, 1977.
The records showed that the licensee was meeting their commitments.
(Closed)
Unresolved Item (315/81-11-12; 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:
(1) the controls over the use and storage of combustible and flammable materials in safety related areas; (2) the contr'ols over the use of ignition sources in safety related areas.
On May 3, 1985, the inspector observed the fire protection portion of the General Employee Training (GET) Program and found that these inadequacies had been corrected.
(Closed)
Noncompliance (315/82-08-03; 316/82-08-03):
The licensee's submittal in response to 10 CFR 50.48 and Appendix R was late by twenty-five percent.
Regarding this item a telephone conference call was held on April 22, 1985 between the licensee's licensing staff and members of Region III in which the licensee concurred that their submittal was late by the amount of time indicated.
The inspector also discussed the implications of this item with the resident inspectors to determine if other licensee submittals have been sent to the NRC in a manner consistent with NRC regulations.
According to the resident inspectors, no recent problem in this area have been identified.
This item is considered close I1 ~
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(Closed)
Open Item (315/82-08-12; 316/82-08-12):
The licensee was found in violation of Section III.O of Appendix R to 10 CFR 50 concerning the capacity of the oil collection system tanks for the reactor coolant pumps and the seismic qualifications of those systems.
By letter dated December 23, 1983, NRR granted an exemption to the existing reactor coolant pump (RCP) motor lube oil collection system based on the oil collection tank having sufficient capacity to hold the total oil inventory of only one reactor coolant pump and based in part on the fact that any overflow would drain onto the lower containment floor where no ignition sources exist.
In addition, the exemption was granted based on the RCP motor lube oil system being capable of withstanding the safe shutdown earthquake.
The inspector also verified through a drawing review the adequacy of the size and capacity of the oil collection system tank.
Regarding the sight glass installed on the drain tank, the resident inspector, during a plant tour on May 17, 1985, verified that the sight glass installed on the Unit 1 oil collection system drain tank had been removed and plugged.
The seismic analysis of the oil collection system and its components, as reviewed and accepted by NRR, was performed by an outside consultant who proposed the modifications to seismically qualify the oil collection system tank.
The licensee has also implemented procedure No. 10-MHP.5030.001.003 to perform an inspection of the reactor coolant pump motor oil levels and oil spill protection integrity during each refueling outage.
(Closed)
Unresolved Item (315/82-08-15; 316/82-08-'15):
The fire door assemblies into the Unit 1 and 2 l/est Motor Driven Auxiliary Feedwater Pump rooms were not rated fire door assemblies and they had not been tested to demonstrate their fire resistance capabilities.
In addition, the doors were not designed and installed in accordance with NFPA 80, Standard for Fire Doors and Windows.
On April 29, 1985, the inspector verified that two newly installed three hour rated rolling fire doors approved by UL have been installed behind the horizontally sliding doors to provide the required fire resistance rating.
(Open) Unresolved Item (315/82-08-17; 316/82-08-17):
The inspectors raised two concerns as follows:
(1) the non-listed fire door frames used in the majority of the safety related fire door assemblies will degrade the fire resistance capability of the assembly below its design rating; and (2) modifications to fire doors, including handles and metal reinforcement plates welded to the doors, will degrade the fire resistance capability of the assembly below its design rating.
The licensee provided to the inspector a
UL test report dated January 25, 1985 which indicated that no flaming of any sign material occurred throughout 180 minutes of fire exposure, and that a simulated door demonstrated conformance with three UL test requirements thereby allowing this type of sign to be used on fire doors.
During tours of the plant on May 2 and 3, the inspector observed fire door frame assemblies that remained unlabeled and hardware
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which appeared to be non-listed.
On June 21, 1985, the licensee provided the inspector additional copies of Underwriters Laboratories letters dated July 18, 1983, October 29, 1984, and May 23, 1985 which described the results of the UL field inspections regarding the installation of doors, frames, and hardware installed at the D. C.
Cook plant.
In certain cases these letters provided the licensee with alternatives in satisfying UL criteria for fire door assemblies and their components.
This item will remain open until the UL criteria have been met as described in their latest correspondence dated May 23, 1985.
(Closed)
Open Item (315/82-08-18; 316/82-08-18):
Foam suppressant concentrate was up to ten years old and had never been sampled and analyzed as recommended in NFPA ll, "Foam Extinguishing Systems".
The licensee committed to take samples from each manufacturing lot of material and return the samples to the manufacturer'for analysis.
This was accomplished on May 27, 1982 and June 1, 1984.
The results of these two tests showed the foam samples to be acceptable.
The licensee has implemented a procedure entitled, "Fire Protection Foam Testing" dated June 19, 1984.
According to the Fire Protection Coordinator this surveillance testing procedure is now planned to be performed annually.
(Open)
Open Item (315/83-02-02; 316/83-02-02):
In Licensee Event Report (LER)
RO 81-051/03L-0 covering fire barrier seals and electrical conduit sealing, the licensee committed to an AEPSC engineering evaluation of conduit and sealing requirements as part of their corrective actions.
As of February 10, 1983, fire zones had been redefined, the fire seal identification and surveillance program for fire seals had been revised, and a revision to DCC-FP101-(CN, "Silicone Foam Fire Stops and Seals",
was issued.
This revision included requirements to seal new conduits or changes to existing conduits that penetrate a fire rated barrier (wall, floor, etc.).
However, by AEPSC internal memo Grier to Smith dated May 3, 1984, this revision was not retroactive to previously existing conduits penetrating fire barriers.
A review of this item by the inspector during this inspection included the following:
(1)
The licensee's response to Appendix A to the NRC Branch Technical Position (BTP) 9.5-1 indicates that all openings for cable, pipe, and ductwork in fire barrier walls, floors, and ceilings have been sealed with foamed in place silicone which was tested in March, 1975 for up to five hours fire exposure in an ASTM E-119 wall fire test.
(2)
Throughout the Fire Hazards Analysis (FHA), statements regarding cable and pipe openings having been sealed with a sufficient thickness of silicone foam for a three hour fire resistance rating are made for a number of different fire zones.
(3)
The NRC Safety Evaluation Report (SER) indicates that the NRC review was based on the licensee's proposed program for fire protection as described in the licensee's response to Appendix A to the BTP 9.5-1 dated January 31, 1977 and the D. C.
Cook
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The section entitled, "Penetration Fire Stops" states in part, "Silicone foam poured in and around...conduits where they penetrate fire barriers make up the penetration fire stops."
The SER further stated that the licensee had cited applicable generic test data for the penetration fire stops which show that the silicone foam material in this application provides a three-hour fire resistance to an ASTM E-119 type fire exposure.
Although the licensee was unable to locate the generic test data at the time of the inspection, the inspector made mention of fire seal test data reviews at other plants using the same sealant material which showed that sealant material was installed inside of conduits during the fire exposure test period.
The inspector requested that the generic test data used for acceptance of the type of penetration seals installed at D. C.
Cook be provided for review.
This item is being tracked as an open item and is discussed in more detail in Paragraph 7.a. of the report.
Based on the review of the documents noted above, it was the inspector's belief that the licensee should seal the inside of conduits in accordance with their commitments.
This topic was discussed in detail between the licensee's staff and the inspector during the inspection including a telephone conference call with the AEPSC staff members on May 2, 1985.
At the conclusion of the April 29-May 3, 1985 portion of the inspection, the inspector indicated that Region III would request NRR provide clarification of the intent of the wording used in the Safety Evaluation Report (SER) dated May 31, 1979.
Subsequent to the inspection, Region III contacted the NRR Chemical Engineering Branch to discuss this item.
On May 16, 1985, NRR informed the Regional inspector that, based on their review, the intent of the July 31, 1979 SER covering penetration fire stops was for the licensee to seal the inside of conduits.
However, if the licensee could provide justification for not sealing the inside of conduits this justification would be reviewed and dispositioned accordingly.
The licensee was notified by Region III of NRR's decision on May 17, 1985.
(Closed)
Open Item (315/83-XX-Ol; 316/83-XX-01):
This item documented fire protection concerns identified in a fire protection survey of D. C.
Cook by a consultant as documented in a report dated October 26, 1982.
The inspector identified two open items regarding the same concerns.
The consultant's fire protection concerns will be tracked as Inspection Report Item No. 315/83-11-04; 316/83-12-05 to avoid du pl icati on.
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(Closed)
Open Item (315/83-11-04; 316/83-12-05):
The following fire protection deficiencies were identified from the licensee's consultant's report.
Those items remaining open will be individually tracked as indicate U W ~ h h
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(7)
Revise administrative procedures PMI-5040 and PMI-5045 to include more detailed guidance in the review of plant modifications and design changes with respect to potential impact on fire protection.
The licensee incorporated PMI-5045 into PMI-5040.
The inspector reviewed the changes incorporated into'PMI-5040, Revision 6, and found them to be acceptable.
This portion of the item is considered closed.
The control and storage of flammable and combustible liquids procedure should include a mechanism for checking all safety containers used in transporting and storage of flammable and combustible liquids to ensure the flame arrestors are properly inserted.
The licensee provided the inspector with Procedure No. PMI-2271, Revision 2, which requires flame arrestors to be installed in flammable and combustible approved safety contain-ers and which requires checks on periodic plant tours by the fire protection coordinator.
During a plant tour on May 2, 1985, the inspector inspected approximately seven safety containers.
All had flame arrestors installed.
This portion of the item is considered closed.
The control of flammable gases procedure should include the use and storage of fixed gases in addition to compressed cylinders.
During the inspector's review of Procedure No. PMI-2271, a
section covering the control of flammable and compressed gases was incorporated and found acceptable.
This portion of the item is considered closed.
Revise the door closure arrangement for door 445 located in the corridor separating the Unit No.
1 and 2 Control Rooms.
The inspector observed this action to be completed by the installa-tion of a magnetic hold-open device which releases automatically when actuated by smoke detectors in either control room.
This portion of the item is considered closed.
Revise the existing welding permit system described in Procedure No. PMI-2275 to restrict the use of permits to a maximum duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the plant is operating or for the duration of a particular job during plant shutdown.
The subject procedure has been revised.
This portion of the item is considered closed.
Provide three hour rated fireproofing for the structural steel beams resting on the perimeter walls of the Diesel Fire Pump rooms since these beams appear to support the 4 inch poured concrete roof above each room.
This area has a sprinkler system installed and a fuel oil tank installed in a sand covered pit.
Subsequent to the inspection di.scussions between Region III and NRR indicated that adequate fire protection features are in place; however, a more detailed review is necessary.
This portion of the item will remain open pending further review by the inspector (315/85013-Ol(DRS);
316/85013-01(DRS)).
Strictly enforce controls on smoking in safety-related areas of the plant.
This applies specifically to the cable vaults,
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control rooms, and diesel generator rooms.
The inspector toured these and other plant areas on May 2, 1985, and found no indications of personnel smoking in identified no smoking areas.
This portion of the item is considered closed.
Improve control of specific combustibles and ignition sources in safety related areas.
The inspector, while touring the plant on May 2, 1985, observed that the three specific concerns and the general plant control of combustibles appeared to have improved.
This portion of the item is considered closed.
Develop a procedure to regularly test the automatic operation of two motor operated valves or expand existing procedures to include the recommended testing to ensure operability.
The inspector reviewed Procedure No. 12-0PH.4030,STP. 120, Revision 8, which does include an operability test of motor operated valves 12-ZMO-10 and 12-ZMO-20.
Also reviewed was a copy of a recent satisfactory operability test performed on May 15, 1985.
This portion of the item is considered closed.
Revise Step 5.7.2 in Procedure 12-0HP.SP.011 to require verification that dry pilot system pressure is 40 psig
+ 5 psig.
Procedure No.
12-0HP.SP.011 has been replaced with Procedure No. 12-0HP.4030. 120.
The inspector reviewed three Data/Signoff sheets (No. 6.12) showing that the dry pilot system air pressure is being checked.
The licensee's engineering staff performed an evaluation of the pilot system air pressure determining that less pressure (30+5 psig) than what was recommended by the consultant is adequate to assure proper actuation of the sprinkler system deluge valve.
Based on discussions with the licensee's staff and a procedural review, this portion of the item is considered closed.
Conduct a detailed study concerning the design and acceptance testing of the Halon 1301 systems protecting the control room cable vaults.
The inspector reviewed the Unit 1 and 2 Halon system concentration test results and found them to be acceptable.
Further, the inspector verified that combination nozzles specifically designed for CO, and Halon 1301 system use were installed in the Unit 1 Control Room Cable Vault.
The Halon 1301 systems protecting the Unit 1 and 2 Control Room Cable Vaults as installed appeared to be able to extinguish a
fire if actuated.
Following the exit meeting of August 9, 1985, the licensee declared the Unit 1 and 2 Cable Vaults Halon systems operable.
This portion of the item is considered closed.
Complete the installation of additional smoke detectors below the ceiling of the Unit 1 Control Room to ensure detection of fires originating within closed electrical cabinets.
The licensee provided the inspector with a consultant's test report regarding the D. C.
Cook Unit 1 Control Room fire detection system dated October 13, 1983.
The inspector reviewed this test report and found the test arrangement and results derived
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from the test acceptable.
This test showed the fire detection system as installed met the criteria defined in Section 34 of UL268 and adequately sensed a smoldering fire in a closed cabinet.
This portion of the item is considered closed.
Develop and enforce a procedure to ensure that all fire protec-tion equipment procured and installed in the future is listed and approved for fire service use by a nationally recognized testing laboratory.
An internal licensee memo from R. S. Hunter to various Division and Section Heads and others dated March 1, 1983, indicated that future fire protection equipment was to be listed and approved for fire service use by a nationally recognized laboratory and identified General Procedures numbered 2.1 and 25 as incorporating these requirements.
This portion of the item is considered closed.
(14)
(i5)
(i6)
Relocate specific sprinklers installed in the auxiliary building due to obstructions.
During a plant tour on May 2, 1985, the inspector, using the applicable drawings, observed that the sprinklers had been relocated, and the existing sprinkler system appeared to be expanded.
This portion of the item is considered closed.
Replace sprinklers in the Charging Pumps room and Safety Injection Pump rooms with sprinklers of the proper temperature rating and type.
On May 2, 1985, the inspector toured these areas and found the proper sprinkler heads installed.
The inspector observed that the sprinkler system sensing lines had sprinklers installed in positions opposite to their intended design; however, according to the licensee the purpose of these sprinklers was to sense a fire and actuate the systems,'ot to apply water on the fire.
The inspector found this design to be acceptable although irregular.
This portion of the item is considered closed.
Install additional hose stations in the following areas to comply with SER commitments:
(a)
Unit 1, squad 3 South (b)
Unit 2, squad 3 North (c)
Outside Unit 2 Switchgear Cable Spreading Room On June 21, 1985, the liensee provided the inspector documenta-tion which showed that these three additional stations had been installed, however; inadequyte fire hose coverage of these three areas still existed.
The licensee has committed to installing additional hose stations in these areas so as to provide adquate hose coverage by December 31, 1985.
During the interim, the licensee has placed additional lengths of hose at the existing hose stations.
The inspector requested the licensee to perform friction loss calculations for the committed to hose stations to verify hose station pressure and gallonage adequacy.,
This portion.of the item will remain open pending installation of an
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adequate number of.hose stations in accordance with NFPA 14-1978 as committed to by the licensee (315/85013-.02(DRS):
316/8513-02(DRS)).
Replace the plastic tubing used as a flexible connector in the Reactor Coolant Pump (RCP) oil collection and drainage systems.
According to the licensee, this plastic tubing (tygon) is examined at every outage to determine if any deterioration has occurred.
The inspector was unable to tour the area where the tubing was installed due to high radiation.and/or contamination in the area.
By letter dated December 23,. 1983, NRR had informed the licensee that the exemption request regarding the oil collection system for the reactor coolant pumps had been granted.
However, subsequent to the August 9, 1985,.inspection visit, the inspector discussed this subject with the NRR fire protection reviewer indicating that NRR had not specifically considered the tygon tubing in granting an exemption to Section III.O to Appendix R.
Thus, this item will remain open pending licensee submittal of documentation clarifying the use of tygon plastic tubing as a flexible connector in the RCP oil collection system and its acceptabil ity to NRR (315/85013-03(DRS);
316/85013-03(DRS)).
Open motor-operated butterfly valves supplying standpipes and water suppression systems in the auxiliary. building or affix permanent labels adjacent to each hose station in the auxiliary building.
The licensee chose to affix permanent labels adjacent to each hose station plant wide indicating. that pressurization of the standpipe can occur by pushing the local button station.
This method was chosen becausq, of licensee. concerns relative to damaging safety-related systems.
The inspector verified on a
sample basis during a plant tour that permanent labels were affixed adjacent to the hose stations.
This portion of the item is considered closed.
The two electric motor-driven high demand fire pumps should be provided with controllers that are specifically tested and approved for fire service use and that comply with all applicable provisions of NFPA.
A review was performed to determine the controllers adequacy for fire service use including the controllers performance history, and a comparsion to Chapter 7 of NFPA 20.
Deviations from NFPA 20 were noted and as such need to be reviewed and accepted by NRR.
This portion of the item will remain open pending licensee submittal to NRR and acceptable dispositioning of this item (315/85013-04(DRS);
316/85013-04(DRS)).
Replace the spectacle valve located on each reactor coolant pump water spray system with an indicating valve and tamper switch with electrical annunciation of each tamper switch in the control room.
The licensee has implemented Step 6.2 of Procedure No. 12-THP.4030.STP.239 which instructs personnel to restore the reactor coolant pump headers spectacle flange to
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As the spectacle valves are located in the containment annulus which is a controlled access area and the use of small tools is necessary to close the spectacle valves, adequate controls are in place.
This portion of the item is considered closed.
(21) The current practice of allowing the "low demand" pump to supply the office building HVAC system during outages of Unit
should be discontinued as soon as practical.
The licensee has discontinued the use of the "low demand" pump to supply the office building HVAC system.
An independent water supply has been installed to meet the water demands of the office building air conditioning system.
This portion of the item is considered closed.
(22)
(23)
(24)
Install additional hangers for sprinkler system piping in five locations in the auxiliary building and at one location in the Unit 1 containment contractor's entry point to conform to applicable provisions of NFPA 13.
On May 2, 1985, during a
plant, tour, the inspector verified through drawing review and discussions with licensee staff knowledgeable in this concern that adequate numbers of hangers were installed in the five locations in the auxiliary building.
During a tour of the Unit
containment contractor's entry point the inspector verified the installation of a piping support for the sprinkler system located in this area.
On June 21, 1985 the inspector was provided sat-isfactory supporting information on the design and installation of this sprinkler system piping support.
This portion of the item is considered closed.
Develop a comprehensive operational guide or revise existing Fire Protection System Description DCC-FP101 to include a
complete description of the low demand and high demand fire pump logic system.
Existing documents do not describe the automatic starting of the pumps upon receipt of signals from individual sprinkler and water spray systems which may activate.
Actuation of fire pumps from individual system pressure switches should be described in detail including a
listing of specific pressure switch locations, identification numbers, pressure settings, etc.
The licensee has revised the Fire Protection System Description DCC-FP101 to include fire protection instrument data (i.e., device, device function, and device settings).
This portion of the item is considered closed.
Install a pressure regulation valve or other approved device on each fire hose station to reduce the pressure to 100 psig as recommended in NFPA 14, Section 4-2.2.
An alternative suggested by the inspector having been accepted at other Region III sites involved fire brigade hose handling training with maximum pressures expected at the plant, instructions in the General Employee Training Program indicating that the fire hose is to be used by trained personnel only, and the installation of signs on interior hose stations cautioning on hose station
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use by trained individuals only.
This portion of the item will remain open pending further review by the licensee of the noted alternative to meeting NFPA 14, Section 4-2.2 and inspector fol 1 owup (315/85013-05(DRS);
316/85013-05(DRS)
).
Install smoke detectors inside the tool crib and in beam pockets in the Unit 1 side of the auxiliary building.
In addition, relocate several existing smoke detectors located on the bottom of beams in the 4KY switchgear areas.
The inspector observed that a fire detector base had been installed inside the tool crib but was missing the sensing portion of the detector unit.
Also a detector located outside of the tool crib was disconnected and according to the fire protection coordinator scheduled to be relocated to another beam pocket location.
The inspector observed that a sufficient number of detectors were installed and operable in the area as required by Technical Specifications.
This portion of the item will remain open and tracked as part of (315/85013-06(DRS);
316/85013-06(DRS)).
The other smoke detectors in the 4KV switchgear areas for Unit
were inspected and found to be relocated and appeared operable.
This portion of the item is considered closed.
Relocate the infrared detectors in Cable Penetration squad
(both units).
As-installed in the horizontal position these detectors are directed at nearby concrete beams.
The inspector observed that these infrared detectors had not been relocated.
These detectors are positioned so some protection is provided, but not the optimum range of protection.
Further, ionizatin detectors are installed in these areas.
This portion of the item will remain open (315/85013-06(DRS);
316/85013-06(DRS)).
Develop pre-fire plans for all safety-related areas of the plant and use the plans in fire brigade training and drill sessions.
The inspector reviewed ten pre-fire plans for various plant fire areas.
These plans included reference information regarding the area covered, primary and secondary access to the area, emergency egress routes, access/egress problems, fire/
safety hazards of the area, guidelines for attacking a fire, fire protection equipment available, construction, and adjacent area information.
Also included as part of the pre-fire plans was a drawing of the area including expected radiation doses.
The licensee's staff was in the process of refining the pre-fire plans to enhance their usefulness at the time of the inspection.
This portion of the item is considered closed.
Establish a new position of Fire Brigade Training Coordinator whose responsibilities should include coordination, scheduling and training of new fire brigade members, quarterly retraining sessions, fire drills, and procurement and use of training materials.
The licensee has hired an individual to fill the Fire Brigade Training Coordinator's position having the title of "Fire Brigade Training Instructor."
The inspector reviewed the individuals'esume, observed a portion of the fire brigade training program and determined that this recommendation had been satisfied.
This portion of'he item is considered. closed.
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Institute a formal training program specifically designed for fire brigade leaders in addition to the brigade member training program.
The inspector reviewed a copy of the course outline for the Fire Brigade Leadership program which appeared adequate, however, no sessions for the leadership program were held during the inspection visit.
The lesson plans reviewed for this training program also appeared to be adequate.
This portion of the item is considered closed.
(30)
(31)
Remove the Shift Supervisor from the fire brigade and relieve him of any training responsibilities associated with the brigade.
In hiring the Fire Brigade Training Instructor, the licensee has transferred the training responsibilities of the fire brigade to a full time fire brigade training instructor.
This portion of the item is considered closed.
Establish and implement a training program for new fire brigade members.
The inspector reviewed Procedure Numbered 12-PMP-2070-TRN-115, Revision 0, regarding the Fire Brigade Training Program which is designed to provide brigade members the necessary knowledge and skills in firefighting including site specific classroom and hands-on training.
The inspector reviewed three lesson plans of this program and found them to be adequate.
The inspector also witnessed portions of the fire brigade training sessions including the annual and quarterly drill requirements and found the training provided adequate.
This portion of the item is considered closed.
(32) Conduct quarterly fire brigade retraining sessions for a minimum of two hours each using a detailed training guide to assure thorough coverage of all required subjects.
The licensee does now schedule their quarterly fire brigade retraining sessions for a minimum of two hours each; however, if the instructor covers the subject matter as scheduled, sessions may be completed in less than two hours.
The inspector participated in a quarterly retraining session covering the topic of "Fire Hazards" and determined the amount of material covered and length of instruction to be adequate for the subject.
While participating in the quarterly retraining sessions the inspector observed the Bio-Pak 60 type self-contained breathing apparatus (SCBA) whereas during a plant tour of the auxiliary building the inspector observed MSA manufactured type SCBA.
The inspector commented that the use of two.types of SCBA units having different design and physical characteristics increase the chance of brigade member injury, in effect decreasing the amount of fire protection afforded the plant.
The inspector recommended uniformity in the type of breathing apparatus used throughout the plant; however, the licensee appeared to be meeting their corrmitment and.therefore this portion of the item is considered closed.
(33)
Remove smoke ejectors from the fire truck and relocate them to a permanent position inside the plant secured area to facilitate
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their use by the fire brigade, or purchase two additional units.
The licensee purchased two additional smoke ejectors and has installed these units at an accessible location inside the protected area.
Due to discussions with the plant fire protec-tion coordinator the inspector contacted the NRR Fire Protection Reviewer regarding the need to maintain the two smoke ejectors located outside the protected area on the fire truck. It was determined, based on the purchase and accessibility of the two new smoke ejectors, that no further need to maintain the two smoke ejectors on the fire truck existed; however, the licensee needed to formalize this understanding with NRR to deviate from an NRR commitment.
This portion of the item is considered-closed.
(34) Provide a conveniently located fire equipment cart to contain items such as extra fire hose, air masks, etc.
The inspector discussed this recommendation with the fire protection coordinator and the fire brigade training instructor who indicated that a fire equipment cart was not necessary based on past experience.
Feedback received from the brigade members has indicated the possible need to permanently station additional fire equipment in certain plant areas to better enable the brigade to perform their duties.
Plant tours taken by the inspector showed that ample fire equipment is now available and
. stationed strategically throughout the plant.
The inspector did recommend that portable fire equipment (i.e., wheeled unit type fire extinguishers, portable fire extinguishers positioned on carts, etc.) permanently stationed in the plant should have its location marked so as to prevent inadvertent movement of the equipment.
This portion of the item is considered closed.
(Cl osed)
Unresolved Item (315/83-14-02; 316/83-15-01):
The installation of two non-listed fire dampers in a three hour fire wall were identified.
These two fire dampers are located in the ductwork as part of the exhaust system post accident sampling system.
The dampers are 4.375 inches wide by 4.5 inches high and
.375 inches thick having an area equal to 19.7 inches square.
The dampers are fabricated from A36 structural steel.
The licensee provided the inspector a copy from the Factory Mutual Systems Loss Prevention Data Book 1, data sheet 1-45 under "Construction".
In this section under "Automatic Fire Doors and Dampers,"
item 2 states in part,
"llherever ducts pass through interior fire cutoffs of 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> or more fire resistance ratings,....
At openings in such cutoffs not exceed-ing 18 inches in diameter or on longest side, steel plates may be used."
According to the licensee's.review of the Safe Shutdown Capability study, if a fire damages equipment on either side of the barrier in question, one train of systems is still available to safely shutdown the plant.
Subsequently the inspector discussed this issue with NRR and found this specific deviation from NRC guidelines to be acceptable.
Maintaining of the fire dampers is expected to be performed on a periodic basis.
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Unresolved Item (315/84-02-01; 316/84-02-01):
During previous tours of the Auxiliary Building, including the Unit 1 and 2 Coolant Charging Pump (CCP) rooms, the inspector noted examples of the following:
(1) safety related cable trays with metal covers removed, (2) opposite train cable trays and/or conduit running in close proximity with no intervening fire barrier, and (3) previously installed fire barriers between cable runs degraded or removed.
During a plant tour on May 2, 1985," the inspector observed two cable trays numbered lVC164 and 1BC200 having fire resistive board covering each of these trays on three sides.
However, no cover was in place nor could the licensee's staff provide the inspector information to determine if these two trays were required to be covered.
The licensee's follow-up on this item was continuing at the time of the inspector's departure from the site.
This portion'f the item will remain open.
(Closed)
Noncompliance (315/84-19-06):
On August 22, 1984 at 0000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, the control room cable vault supply fan fire damper (1-HV-ACES-2) was found held open by a piece of conduit during performance of CO system testing.
Failure to ensure the operability of th( fire damper at all times was a violation of Technical Specification requirements.
Corrective actions by the licensee included the following:
(1)
Develop an administrative measure to ensure that resetting of fire dampers will be done only by a qualified maintenance individual whose function will be to restore and assure operability of the closure device.
The licensee provided the inspector a copy of Technical Department guality Control Action Request No. AR-123 dated October 19, 1984 indicating a
revision is in progress to all Performance Section procedures including the requirement to have the maintenance department involved when other departments perform tests that affect fire damper operability.
This portion of the item is considered closed.
(2)
Place a caution tag on the CO, actuation switch which refers the operator to the revised procedure directing two CO~
actuations.
The inspector verified the caution tag was in place and the applicable procedure had been revised.
This portion of the item is considered closed.
(3)
Restore the Halon Suppression system to an operable condition.
According to the licensee's Engineering and Design Change Coordinator staff the Halon system is installed to function if a fire were to occur; however, testing to determine the system's operability was not complete at the time of the inspection.
Related to this item is LER 315/84-020 which was closed out in Inspection Reports 50-315/84-19 and 50-316/84-21.
Following the exit meeting of August 9, 1985, the licensee declared the Unit 1 and 2 Control Room Cable Vaults Halon Systems operable.
This portion of the item is considered closed.
No violations or deviations were identified in the-review of this program area.
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Followu on Licensee Event Re ort No.
LER 85-006 This LER reported an Auxiliary Building Access Control Area Ventilation Duct Fire Damper that was found closed during the performance of mainten-ance activities in the area.
The licensee's investigation of this item determined that this ventilation duct fire damper had been misidentified as non-safety related during the safety related fire damper identification program of 1'982.
As a result of this finding the licensee's engineering staff performed a review of fire dampers designated as non-safety related and identified four additional fire dampers which had been misidentified.
These five fire dampers have been added to the fire damper surveillance test schedule.
The inspector determined that the improper classification of these five dampers was due to personnel error.
According to the licensee's staff, determination of the fire dampers safety significance has been based primarily on those designated fire barriers identified in their response to Appendix A to BTP 9.5-1 dated January 3,
1977.
The inspector noted that a re-review may need to take place after the Appendix R safe shutdown capability study modifications have been completed.
The inspector determined that the licensee fulfilled the reporting requirements and took appropriate corrective action regarding the reopening of the fire dampers.
Thus, LER No. 85-006-01 is closed.
Further review by the licensee concluded that a malfunctioning preheater steam coil located in that ventilation duct caused the fire damper fusible link to melt and allowed the damper to close.
Through discussions with the licensee's staff, the inspector learned that no preventive maintenance program was in place to care for the preheater steam coils located in the Heating, Ventilating, and.Air Conditioning (HVAC) system(s).
The licensee could not provide documentation to show that an engineering evaluation had been performed to determine if any adverse safety consequences could result from a closed ventilation duct fire damper.
This could result in high temperature in the room being supplied ventilation causing vital equipment to become inoperable.
This item is considered open (315/85013-07(DRS);
316/85013-07(DRS)).
No violations or deviations were identified in the review of this program area.
A endix R Safe Shutdown Ca abilit Drawin Discre anc The inspector performed a plant tour of the turbine building on April 29, 1985, comparing the as-built plant condition to the drawing in the Appendix R safe shutdown capability study.
Figure 2.6 of the study showed the east wall of the Turbine Building sub-basement as being a fire area boundary.
Having been designated a fire area boundary implies that this boundary was rated for a three hour fire exposure; however, during the tour of this area, the inspector observed several unsealed penetration openings and what appeared to be two non-fire rated watertight doors.
This possible discrepancy in the licensee's Appendix R study was brought to plant management's attention by the inspector.
The inspector emphasized
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the necessity for the licensee to perform a comparison of the information provided in the Appendix R safe shutdown capability study to the actual plant construction.
The licensee acknowledged this concern and indicated that both their engineering staff and their consultants were pursuing resolution of this concern.
This item is considered open (315/85013-08(DRS);
316/85013-08(DRS)).
No violations or deviations were identified in the review of this program area.
5.
Fire Dam er Maintenance Ins ection Procedure Review
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The inspector reviewed procedure number 12-MHP.4030.STP.928 for maintenance inspection of fire dampers protecting safety related areas.
This maintenance inspection procedure was implemented to verify the operability of fire dampers protecting safety related areas on a routine basis and following repairs.
The inspector's review of this procedure generated the following comments:
(1)
Step 7.5 should indicate to the individual performing the test that no cleaning or accidental movement of the damper from its as-found condition should be done prior to the functional test.
(2)
Step 7.6. 1 needs to address the appropriate attachment of the procedure.
(3)
Attachment No.
2 of the procedure has numerous dampers identified using the word "unlabeled".
The inspector requested these dampers be assigned a number.
(4)
Further clarification to the procedure is necessary to deter-mine the as-found damper condition versus the as-left damper condition.
Resolution of the four inspector comments is considered an open item (315/85013-09(DRS);
316/84013-09(DRS) ).
b.
The inspector discussed with the licensee's staff their actions relative to a
CFR Part 21 Report submitted by Ruskin Manufacturing Company regarding a problem with fire dampers failing to close under normal duct pressure.
According to the licensee's staff, an engineering evaluation of the
CFR Part 21 Report is on-going and no conclusions have been reached.
The inspector learned that fire dampers other than those manufactured by Ruskin were installed in safety-related areas of the plant.
The inspector suggested that the licensee broaden their engineering evaluation of the Part 21 report to include these other dampers.
The licensee acknowledged the inspector's request.
No violations or deviations were identified in the review of this program area.
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Shift Su ervisor Interrelatin Duties as The Fire Bri ade Leader In examining one of the previously opened items the inspector reviewed Procedure No. PMI-2270.
During the review of this procedure, the inspector noticed that step 16.3 indicates that the Shift Supervisor on duty shall be the responsible Fire Chief (Fire Brigade Leader)
and will coordinate the firefighting efforts of the fire brigade.
The inspector pointed out that the NRC has taken a position as outlined in Section III.H of Appendix R
which requires that the Shift Supervisor shall not be a member of the fire brigade in so far as taking credit for the Shift Supervisor comprising any of the five required brigade members.
The inspector acknowledged the Shift Supervisor as having the ultimate responsibility of safely shutting down the plant; but expressed a concern over having the Shift Supervisor designated as brigade leader while other qualified individuals are also on shift.
Staffing requirements do not prohibit designating another qualified individual as brigade leader.
This would free the Shift Supervisor to allow him to maintain control over all plant activities including incident response.
The inspector requested plant management to review their policy in this area.
This request was acknowledged by the Plant Manager.
This item is considered open (315/85013-10(DRS);
316/85013-10(DRS)
) pending licensee review of this policy and inspector followup of this concern.
No violations or deviations were identified in the review of this program area.
Review of Alle ations Concernin BISCO Penetration Seals The NRC received three generic (not specifically mentioning the D. C.
Cook Plant) allegations regarding Bisco penetration seals indicating that:
(1) test data to support the penetration seal fire resistance capability did not exist including test data to show that the six inch silicone foam fire barrier penetration seals are rated for three hours, (2) penetration seals were installed with a 2" overlap on the seal boot instead of the required 3", and (3) Bisco procedures SP504, SP505, SP505-1, SP505-2, and SP505-3 were deficient.
To determine if these allegations could be substantiated the inspector performed a review of the applicable documents including Plant Procedure No. 12-QHP.4030.STP.001, Revision 3, entitled, "Surveillance Inspection of Silicone Fire Seals",
dated April 4, 1985; Plant Procedure No.
12-QHP.2270.QC.004, Revision 0, entitled,
"QC Inspection for Ratio, Density and Quality of Machine Installed Silicone Foam", dated November 14, 1984; Plant Procedure No. 12-QHP.2270.C.002, Revision 1, entitled,
"Control of Fire Barrier Seal Identification Numbers",
dated April 17, 1984, and.Specification No.
DCC-FP101-QCN, Revision 9, dated December 13, 1985.
In addition, the inspector performed a plant tour paying particular attention to penetration seals, and held discussions with the licensee's staff including penetration seal installers and NRC resident inspectors regarding penetration seals.
As a result of these reviews and discussions the'ollowing findings and conclusions were made:
a.
Alle ation No. RIII-83-A-0029-01:
Test data to support the penetration sea
>re resistance capability did not exist including test data to show that the six inch silicone foam fire barrier
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penetration seals are rated for three hours.
In the SER dated July 31, 1979, NRR indicated that the licensee had cited applicable generic test data for penetration fire stops which showed that the silicone foam material in this application provides a three-hour fire resistance to an ASTM E-119 type fire exposure.
The licensee was unable to provide the applicable generic test data at the time of the inspection.
This item is considered open (315/85013-11(DRS);
316/85013-ll(DRS))
pending inspector review of the applicable generic test data.
In the inspector's review of Specification No. DCC-FP101-(CN, Step 5.5, the required penetration seal depth indicated was twelve inches.
According to the licensee's guality Control Supervisor the twelve inch depth requirement for penetration seals is the only criteria currently being used at the plant.
During plant tours on April 29, May 2 and 3, 1985, the inspector observed penetration seals in the Auxiliary and Turbine Buildings but was unable to verify seal thickness without a destructive test.
The inspection did note the thickness of the wall and observed that sealant material was in place on both sides of the barrier.
Although the inspector did not observe any barriers less than twelve inches thick, the licensee's seal installation procedures had provisions for installing twelve inches of sealant material in barriers less than twelve inches.
The inspector concluded that since no sealant material is installed less than'twelve inches, the portion of the allegation regarding the fire resistive capabilities of a six inch silicone foam seal is not applicable to the D. C.
Cook plant.
This portion of the allegation is considered closed.
b.
Alle ation No RIII-83-A-0029-02 and 03:
Penetration seals were installed with a
overlap on the seal boot instead of the required 3" and Bisco Company procedures SP504, SP505, SP505-1, SP505-2, and SP505-3 were deficient.
The inspector determined that these two allegations were interrelated and as such are discussed together.
The inspector determined through discussions with the licensee's staff including quality control, engineering, fire protection, and maintenance personnel, and the NRC resident inspectors that the seal boot as referenced in the allegation is not being used at the D.
C.
Cook Plant.
In addition, during plant tours of safety related areas and areas important to safety, the inspector did not observe this type of seal installed in the plant.
Based on the above, the inspector concluded that, these allegations are not applicable to the D.
C.
Cook Plant and are therefore considered closed.
8.
Penetration Fire Seal Procedure Review During the inspector's in-office review of an open item and inspector followup on allegations, both relating to penetration seals, the inspector identified an additional concern regarding one of the penetration fire seal procedures.
Step 7.0 of Plant Procedure No. 12-(HP.4030.STP.OOl,-
Revision 3, dated April 4, 1985, provides acceptance criteria for determining whether a fire seal is functional or not.
The inspector's
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concern is specifically regarding step 7.2. 1 which allows up to two inches of fire seal depth to be missing and still consider the fire seal functional.
As noted in Paragraph 7 of the inspection report it was the inspector's understanding that a minimum of twelve inches of sealant material was installed in penetration openings based on test data.
The guality Control Supervisor indicated that Appendix E of Specification No. DCC-FP101-gCN regarding temporary barriers provided sufficient justification for a penetration fire seal to be missing up to two inches of silicone sealant.
However, Appendix E does not address penetrations having sealant degradation of up to two inches of sealant material.
This item is considered unresolved (315/85013-12(DRS);
316/85013-12(DRS) )
pending the inspector's review of applicable generic test data.
No violations or deviations were identified in the review of this program area.
On November 9, 1982, an inspection team from the NRC Division of Human Factors Safety (DHFS) conducted a walk-through of the licensee's
"Diesel Generator Local Control" procedure and performed a review of, ghe procedures and training for alternate emergency shutdown and cooldown.
The conclusion made as a result of their inspection was that the procedures and the related training were acceptable for interim operation of the D. C.
Cook plant until further fire protection measures are established in accordance with the D.
C.
Cook fire protection program.
Recommendations were made as a result of their inspection and documented in an internal NRC memorandum (dated December 16, 1982) from Joel Kramer, Deputy Director DHFS to Gus Lainas, Assistant Director for Operating Reactors, Division of Licensing.
During the inspector's August 5-9, 1985 inspection visit, follow-up of these recommendations was performed.
The recommendations were as follows:
a
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General guidelines should be developed for when to shut down each of the units in the event of a fire in either unit.
The inspector reviewed "Alternate Emergency Shutdown and Cooldown Procedure Due to Loss of Normal and Preferred Alternate Methods" numbered 1-OHP 4023.001.001, Revisions 5 and 6, for Unit 1, dated June 1,
1982, and June 8, 1984, respectively, and 2-OHP 4023.001.001, Revision 3, for Unit 2, dated May 15, 1984.
The inspector determined that adequate guidelines are provided in the objective and discussions portions of the procedures.
This item is considered closed.
Covered in the same discussion in the body of the report dealing with shutdown guidance was the following statement, "It was pointed out by the licensee that more manpower is required for shutdown than for normal operation and shutting down might distract from fire fighting activities."
In discussions with the Operations Superin-tendent and a walk through of the emergency procedures it was determined that the manpower available to perform these procedures included one Shift Supervisor, one Assistant Shift Supervisor, two Unit Supervisors (US), two Reactor Operators (RO) for each unit (four total),
and seven Auxiliary Equipment Operators (AEO) and/or Unit Operators (UO). Of these fifteen personnel, five are assigned to the fire brigade (one Assistant Shift Supervisor as brigade leader,
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four AEO/UO's), three personnel are required to remain in the non-affected unit (one US, one RO, and one AEO) leaving seven personnel to perform the emergency procedures.
During the inspector's review of the Alternate Emergency Shutdown and Cooldown Procedure it appeared that six personnel would be required to perform the necessary actions.
Final review and acceptance of the procedures will be performed at the time of the follow-up Appendix R team inspection.
In addition to the list of personnel noted above, two Control and Instrument (C81) technicians are available on each shift to perform modifications to circuit breakers and local diesel generator control circuitry as required in the emergency procedures.
The inspector verified through the use of the Production Supervisor's list of CKI technicians and the Plant Security Automated Controlled Access Device (ACAD) system that seven technicians were on-site during the midnight shift of July 31, 1985.
Ensure that separate emergency operating procedures exist for each unit.
The licensee provided a copy of the Alternate Emergency Shutdown and Cooldown Procedure for each unit as mentioned in Paragraph 9.a.
Each was a separate procedure having different revision numbers.
Much of the information was similar in both procedures.
This item is considered closed.
Verify that wiring diagrams or schematics are not necessary to carry out emergency operating procedures.
During the walk through of the emergency operations procedures no wiring diagrams, or detailed schematics, were necessary to perform these procedures.
The inspector determined the schematics contained in the procedures were useful, especially under emergency conditions.
This item is considered closed.
The following changes are proposed for the alternate Emergency Shutdown and Cooldown Procedure:
(1)
Nherever the procedure refers to an attachment, also designate the page number of the attachment.
(2)
Add symptom 3.2, Loss of Control Capability from the Control Room and Hot Shutdown Panel.
(3)
In the modification instructions, place a caution statement immediately preceding the step that requires direction from the control room.
(4)
The same terminology should be used in steps 5.6.4.26, 5.6.4.29 and 5.9.2.4 when referring to turbine-driven auxiliary feedwater pumps or Terry Turbine.
(5)
In step 5.8. 1, delete the words "due to the fire."
At the time of the inspection visit the licensee had yet to make.
these changes although after the walk through of this procedure, these changes were submitted to be included in the next revision of
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the Alternate Emergency Shutdown Procedures.
This item is considered an open item (315/85013-13(DRS);
316/85013-13(DRS)
) pending the necessary procedural revisions.
e.
The licensee should continue to test modifications made in accordance with the modification instructions to verify proper operation of all equipment listed in the modification instructions and all emergency diesel generators.
The inspector requested the licensee's staff to provide documented verification that the modification instruction for three valve modifications designated as Attachment No.
7 of the Alternate Emergency Shutdown and Cooldown Procedure for Unit 1 had been tested satisfactorily.
Data sheet No.
5 of Test Procedure RFC-DC-12-840 dated February 2, 1977 showed that the valves had been tested operable.
This item is considered closed.
The licensee was informed that additional review of systems and component testing may be performed during the Appendix R reinspection.
f.
The licensee should verify that adequate communication can be established between each of the component locations and the control room, the hot shutdown panel, the shift supervisor's office and other locations that might be used as the emergency reactor control center.
During the walk through of the Alternate Emergency Shutdown and Cooldown Procedure, portable handheld radio tests were conducted by the Administrative Compliance Coordinator and witnessed by the inspector at two areas:
(1) Unit 1 Regulating Air Valve Equipment Local Control Station and (2) at the 11BD and 11B11 600 V feed breakers panel.
The clarity and volume of the radio voice communications was satisfactory.
This item is considered closed.
Other aspects of the licensee's emergency procedures examined by the inspector not directly identified as recommendations but mentioned in the NRC internal memo included a review of selected Operations Department personnel training records on the Alternate Emergency Shutdown and Cooldown Procedures, a partial walk through of the "Reactor Shutdown from Hot Standby Panel Due to Control Room Inaccessibility" Procedures Numbered 1-OHP 4023.001.011, Revision 4 and 2-OHP 4023.001.011, Revision 2 for Unit 1 and 2 respectively, dated December 11, 1984 for both procedures and a partial walk through of the
"AB Diesel Generator Local Control" Procedure Numbered 2-OHP 4023.032.002, Revision 0, dated August 27, 1982.
During the review of the selected Operations Department personnel training records, no discrepancies were found.
All operations department personnel are required to review these procedures on an annual basis.
Regarding
"Reactor Shutdown from Hot Standby Panel Due to Control Room Inaccessibility" procedure for Unit 1, the 'inspector verified instrumen-tation indications were identified as noted in steps 2.6. 1 through 2.6.7 of the procedure.
Also a copy of this procedure and a key inside a break glass station was available to open the Hot Standby panel doors at the panel location.
Regarding the
"AB Diesel Generator Local Control" procedure, selected wires needing to be lifted to disable the diesel generator
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control cables that lead to the control room'ere verified to be marked as identified in steps 4.2. 1 of the procedure and other wires needing to be jumpered were verified to be marked as identified in 4.2. 1.5 through 4.2.1.7 including a set of jumpers having been taped to the inside of the diesel control cabinet doors.
Also, copies of the applicable portions of the emergency procedures were located in the areas requiring the manual actions (i.e., valve manipulation, stripping wires, etc.).
No violations or deviations were identified in the review of this program area.
10.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
An unresolved item disclosed during the inspection is discussed in Paragraph 8.
11.
~0 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 both.
Open items disclosed during the inspection are discussed in Paragraphs 2.t., 3, 4, 5.a, 6, 7.a.
and 9.d.
12.
Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on May 3, and August 9, 1985, and summarized the scope and findings of the inspection.
The licensee acknow-ledged the statements made by the inspector.
The inspector also discussed the likely informational content of the inspection report with regard to documents reviewed by the inspector during the inspection.
The licensee did not identify any such documents as proprietary.
In addition, a
telephone conference call was held between the licensee and Region III on May 17, and August 1, 1985.
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