IR 05000331/1993012
| ML20057G069 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 10/05/1993 |
| From: | Schrum D, Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20057G062 | List: |
| References | |
| 50-331-93-12, NUDOCS 9310200140 | |
| Download: ML20057G069 (8) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION 111 Report No. 50-331/93012(DRS)
Docket No. 50-331 License No. DPR-49 Licensee:
Iowa Electric Light and Power Company lE Towers P. O. Box 351 Cedar Rapids, IA 52406 Facility Name: Duane Arnold Energy Center Inspection At.
Palo, Iowa Inspection Conducted: August 6-13 and September 20-23, 1993 Inspector:
D. @kd 10 /6!f3 D. Schrum Date d!5/8 Approved By:
u CA W.D.Shafer, Chief Date
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Maintenance and Ourages Section Inspection Summary inspection on Auaust 6-13 and September 20-23. 1993 (Report No. 50-331/93012(DRS))
i Areas Inspected: Routine fire protection inspection of surveillances, i
equipment, fire brigade training and drills, and fire protection audits.
The inspector uti-lized selected portions of NRC inspection procedures 64704 and 92702.
Results: Overall, fire protection program activities were effectively implemented in meeting the safety objectives of the program.
The staff was knowledgeable and had taken appropriate actions to correct most issues and problems.
Strengths included control of combustibles, fire watch training, resources devoted to fire protection activities, and audits performed.
Problems were identified with taking timely corrective action for inoperable fire barrier seals between the control room and the cable spreading room and for assigning a designated fire watch as a compensatory measure for inoperable fire barriers without notifying the personnel assigned to this task (Sections 3.2 and 3.3).
Non-cited violations (NCVs) were identified and reviewed during this inspecti:n period for barrier seal problems and missed fire watches (Section 2). One unresolved item is identified in Section 3.2 of this report.
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DETAILS 1.0 Persons Contacted lowa Electric Light and Power Company
- D. Wilson, P1 ant Superintendent
- D. Blair, Quality Assurance Assessment Supervisor
- J. Christenson, Mechanical Engineer
- D. Engelhardt, Secu' dy Superintendent
- J. Ertman, System Engineer C. Narhi, Mechanical Engineer
- K. Peveler, Manager, Corporate Quality Assurance
- K. Putnam, Technical Support
- D. Robinson, Regulatory Communication W. Rose, Safety Committee Engineer
- B. Schenkelberg, Fire Protection Coordinator D. Winchester, Internal Audit Group Superintendent V. S. Nuclear Reglatory Commission (NRC)
- J. Hopkins, Senior Resident inspector C. Miller, Resident Inspector
- C. Vanderniet, Reactor Engineer
- J. Hannon, Director, Project Directorate III-3, NRR
- R. Pulsifer, Licensing Project Manager, NRR
- Denotes those individuals attending the exit meeting on August 13, 1993.
- Denotes those individuals attending the exit meeting on September 23, 1993.
2.0 Licensee Event Reports (LERs)
2.1 (Closed) LER 90-009-00 - Inadeauate Fire Barrier Seal i
Plant personnel identified air leakage from the control room to the cable spreading room and conduit chase around the fire barrier seal through the
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" seismic gap" between the buildings.
The barrier seal did not meet the I
requirements of 10 CFR 50, Appendix R.
The barrier seal was missed during inspections and surveillances. This condition rendered the barrier inoperable, which was prohibited by Technical Specification 3.13.F.1.
The licensee took timely corrective actions by removing and replacing the seal and including it in the surveillance program.
This violation will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria specified in Section VII.B.(2) of the Enforcement Policy.
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2.2 (Closed) LER 92-003-00 - Fire Barrier Dearaded as a Result of an Unsealed Penetration Followino a Desian Modification Plant personnel found a penetration that was unsealed since two design modifications in 1977 and 1980.
A fire watch had not been used as a compensatory measure for the degraded barrier, a condition prohibited by Technical Specification 3.13.F.4.b.
The licensee took timely corrective actions by removing and replacing the seal and including it in the surveillance program. Changes made to a fire barrier penetration by design modification are now controlled as part of the Fire Hazards Analysis (FHA)
review.
This violation will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria specified in Section VII.B.(2) of the Enforcement Policy.
2.3 (Closed) LER 92-007-01 - Fire Barrier Dearaded as a Result of Unsealed Penetrations Plant personnel during maintenance and surveillances identified six unsealed penetrations.
Technical Specification 3.13.F.1 requires that all fire barrier penetration seals protecting safety-related areas shall be intact. A fire watch was not in place to compensate for a degraded barrier as required by Technical Specification 3.13.F.4.b.
Improvements were made to the fire
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protection program to ensure fire penetrations are adequately inspected.
The fire barriers were sealed. This violation will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria specified in Section VII.B.(2) of the Enforcement Policy.
2.4 (Closed)
LER 92-012-00 - Potential Dearadation of Control Room Habitability Due to lack of Seismic Oualification of Cable Spreadina Room Vent and Damper A temporary modification was installed to vent excess carbon dioxide from the cable spreading room to the atmosphere to ensure that it did not leak into the control room, rendering it uninhabitable during fire suppression carbon dioxide actuations. The modification was designed and constructed as non safety-related with no seismic requirements.
Testing indicated that the control room 0.10 wg positive pressure could not be maintained with the vent open and results in a condition during operation of the plant not covered by operating and emergency procedures.
The vent was replaced with a seismically qualified vent.
The control room habitability problem during emergency conditions will be tracked as an inspection followup item (331-93012-Ol(DRS)).
2.5 (Closed) LER 92-017-01 - Missed Hourly Firewatch Due to Personnel Error 2.6 (Closed) Unresolved Item 92022-01 - Missed Firewatches LER 92-017-01 and Unresolved item 92022-01 list numerous examples of missed firewatches for areas of the plant with impaired fire protection conditions This was a violation of plant Technical Specification 3.13.F.4.b.
The licensee implemented corrective actions to ensure that this situation does not Recent QA audits and surveillances and checks made by the fire recur.
protection coordinator indicates no recurrence of missed fire watches.
This
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violation will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria specified in Section VII.B.(2) of the Enforcement Policy.
2.7 (Closed) LER 92020-00 - Installation of Seismically Oualified Vend Assembly Results in Cable Spreadina Room Fire Suppression System Beina Out of Service Greater than Fourteen Days The cable spreading room carbon dioxide fire suppression system exceeded its allowable fourteen day period for inoperability.
This LER was the submitted Special Report to the NRC in accordance with Technical Specifications 3.13.0.3 and 6.11.
Appropriate compensatory measures had been taken.
The carbon dioxide fire suppression system was returned to service following the installation of the seismically qualified vent assembly.
3.0 Routine Fire Protection Program Review This inspection consisted of plant area observations and reviews of fire protection surveillances, maintenance on fire protection equipment, fire brigade training and drills, fire reports, deviation reports, work requests, safety evaluations, and audits of fire protection activities.
3.1 Plant Area Observations The inspector observed several areas of the reactor and turbine buildings.
The observation included combustibles, fire doors, hose stations, extinguishers, sprinkler valves, emergency lights, and housekeeping.
The material condition of the fire suppression and detection equipment was good. The only discrepancy noted with sprinklers or with fire main valves or headers was water pressure gages not reading the correct pressure.
Extinguishers had been inspected and had a current inspection date, except for those extinguishers in high radiation areas which were being inspected during outages.
Fire fighting gear was well organized and enclosed by a cage.
The licensee completed regular surveillances to assure that critical items were stocked and available in the event of a fire.
The plant was clean and housekeeping was good with a minimum of combustibles around work sites, even though the plant was in an outage. There were few transient combustibles; tags had been hung for those transient combustibles in the plant.
Transient combustibles were being tracked by a computer tracking system, with a daily update, and calculations were being maintained for fire loading in plant areas.
Later in the outage (September 20-23, 1993),
housekeeping had started to deteriorate; not uncommon at the end of an outage.
Combustibles were properly controlled. All wood checked in the plant was fire resistant.
In addition, fire resistant plastic was being used for most applications.
Lubricants were properly stored in fire resistant cabinets or in steel containers.
Equipment oil leaks were minimal. Anti-contamination clothing was being removed prior to becoming excessive.
Detracting from the overall reduction of combustibles was temporary staging material which was often constructed of wood platforms and kickboards.
The inspector noted that
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a 500 gallon propane tank was located within 25 feet of the turbine building when the normal distance for tanks of combustibles is 50 feet. The licensee had addressed the NRC's seismic concerns with this tank but had not addressed any fire protection considerations.
The licensee stated that the fire protection personnel would review this issue.
Cutting and welding were well controlled and inspected routinely by licensee fire protection personnel. Hotwork fire watches were on the job site and attentive to their duties. Fire watches were assigned to areas below the hotwork in case sparks or slag caused a fire in those areas.
Combustibles were removed or covered within 35 feet of the work areas. Hotwork equipment was inspected for leaks prior to use.
The number of tanks of acetylene was being kept to a minimum at work sites.
Fire doors were in good condition and were properly monitored for impaired conditions.
All doors checked properly closed and self-latched.
Fire doors throughout the plant were labeled with large lettering and bright colors to highlight the requirement for a fire watch if they are blocked open.
Impaired doors had documentation attached to the door stating the impaired condition, so any person in plant could tell if the door was inadvertently blocked open or was impaired.
Emergency lighting observed were operable and were correctly aimed for safe shutdown paths in the plant. The inspector reviewed a sample of completed surveillance procedures for 1992.
The surveillances had been performed accurately and on time.
3.2 Fire Barrie_rs Unsealed or inoperable fire barrier penetration seals have been and continue to be a long term problem at DAEC. A 1990 DAEC audit report finding indicated that a lack of an accurate data base showing the location and description of all penetration seals prohibited the assurance that 100 percent of the fire barrier seals were inspected in a five year period. A 1992 DAEC audit left the finding open because the corrective actions addressing this same problem had not been-completed.
As indicated in the LERs, listed in Section 2, a major problem was noted in this area in early 1992.
The surveillance frequency, normally one-third of the barrier seals inspected each operating cycle, was increased so that most of the barriers had been inspected at the time of the inspection. Ladders or scaffolding were being used to ensure thorough inspections.
The data base for fire barrier penetration seals had been improved and was being updated for those barrier seals not previously documented.
The improvements made to the inspection process and data base gives a high confidence that most inadequate fire barriers had been found and repaired.
The plant had been very proactive in resolving these problems with the exception of the barrier seals between the control room and the cable spreading room as discussed below.
The licensee had taken appropriate compensatory measures by assigning a one hour fire watch until barrier seals were repaired.
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On September 29, 1992, the licensee documented that between 80-120 barrier seals between the control room and the cable spreading room were inoperable due to over-filling the penetration seals.
The inoperable fire barriers between the control room and the cable spreading room are safety significant in that the impaired barrier seals were known to the licensee for almost a year and a fire in the cable spreading room could contribute to both trains of safe shutdown equipment being made inoperable.
However, minimizing the risk to the plant were fire detection and fire suppression available in the cable spreading room.
The safety significance of a control room fire was less because it was constantly occupied by plant personnel and a fire would be responded to in a short time period.
Fire detection was also available in the control room.
The licensee did not appear to take timely corrective action for the above condition.
The licensee had not assessed whether to build up the seals so they would meet the three hour barrier seal requirement or to remove the control cables for the alternate shutdown equipment from the cable spreading In addition, the licensee had numerous opportunities to determine that room.
problems existed with these barriers prior to 1992 due to carbon dioxide leakage from the cable spreading room into the control room; such as, the inadvertent initiation of the CARD 0X system during September 1990 when unnecessary personnel had to be evacuated from the control room. By the end of the inspection, the licensee had issued a letter to a contractor to evaluate the scope of the work and prepare a cost estimate for rerouting the c abl e s.
The failure to promptly correct conditions adverse to quality will be tracked as an unresolved item (331/93012-02(DRS)).
3.3 Fire Watches Numerous fire watches were missed when they were used as compensatory measures for impairments.
NRC Inspection Reports No. 50-331/92017 and No. 50-331/92022 document the problems with missed fire watches.
Corrective actions were taken to improve the fire watch training program.
In addition, the fire watches are required to carry the log sheets with them and document the inspection of each impairment.
On a sample basis, the QA staff and the fire protection.vordinator were comparing fire watch requirements and logs to the security computer records for areas with card readers to ensure that fire watches were being conducted as required. QA surveillances were also being conducted on the fire watches as they made their inspections.
No problems were found during these QA reviews and surveillances. Af ter considerable NRC oressure for program improvement, corrective actions became comprehensive and contributed to no fire watches being missed since the program was improved, except for the problem discussed below where an appropriate fire watch was not assigned for the inoperable barriers between the control room and the cable spreading room The licensee was using cameras and video displays for some impaired conditions to reduce radiation exposures of the fire watches.
Inadequate compensatory measures were taken for inoperable fire barriers between the control room and the cable spreading room.
The licensee
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On September 29, 1992, the licensee documented that between 80-120 barrier seals between the control room and the cable spreading room were inoperable due to over-filling the penetration seals.
The inoperable fire barriers between the control room and the cable spreading room are safety significant in that the impaired barrier seals were known to the licensee for almost a year and a fire in the cable spreading room could contribute to both trains of safe shutdown equipment being made inoperable. However, minimizing the risk to the plant were fire detection and fire suppression available in the cable spreading room.
The safety significance of a control room fire was less because it was constantly occupied by plant personnel and a fire would be responded to in a short time period. Fire detection was also available in the control room.
The licensee did not appear to take timely corrective action for the above condition.
The licensee had not assessed whether to build up the seals so they would meet the three hour barrier seal requirement or to remove the control cables for the alternate shutdown equipment from the cable spreading In addition, the licensee had numerous opportunities to determine that room.
problems existed with these barriers prior to 1992 due to carbon dioxide leakage from the cable spreading room into the control room; such as, the inadvertent initiation of the CARD 0X system during September 1990 when unnecessary personnel had to be evacuated from the control room.
By the end of the inspection, the licensee had issued a letter to a contractor to evaluate the scope of the work and prepare a cost estimate for rerouting the cables.
The failure to promptly correct conditions adverse to quality will be tracked as an unresolved item (331/93012-02(DRS)).
3.3 Fire Watches fiumerous fire watches were missed when they were used as compensatory measures for impairments. fiRC Inspection Reports fio. 50-331/92017 and tio. 50-331/92022 document the problems with missed fire watches.
Corrective actions were taken to improve the fire watch training program.
In addition, the fire watches are required to carry the log sheets with them and document the inspection of each impairment.
On a sample basis, the QA staff and the fire protection coordinator were comparing fire watch requirements and logs to the security computer records for areas with card readers to ensure that fire watches were being conducted as required. QA surveillances were also being conducted on the fire watches as they made their inspections. fio problems were found during these QA reviews and surveillances. After considerable f4RC pressure for program improvement, corrective actions became comprehensive and contributed to no fire watches being missed since the program was improved, except for the problem discussed below where an appropriate fire watch was not assigned for the inoperable barriers between the control room and the cable spreading room.
The licensee was using cameras and video displays for some impaired conditions to reduce radiation exposures of the fire watches.
Inadequate compensatory measures were taken for inoperable fire barriers between the control room and the cable spreading room.
The licensee
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documented that the compensatory measures for the inoperable barrier seals would be taking credit for the control room being constantly manned. This was assumed by the licensee to fulfill the fire watch requirement. The inspector disc >ssed this with the region and was informed that the fire watch had to be an identified person (s) unless the licensee had written authorization to take credit for personnel in a continuously occupied space.
The operators must be qualified, such as fire brigade trained or fire watch trained. A designated person (s) already assigned to a continuously occupied area is allowed to perform the fire watch duties if those duties do not interfere with other assigned duties.
The fire watch should include an hourly inspection of the impaired condition and be logged as having been inspected.
Most of the above conditions for a designated fire watch were not met.
There was no authorization to use control room personnel. No individual (s) were assigned as the fire watch. An hourly tour of the impaired barriers was not made and had not been documented. However, the majority of the control room staff were fire brigade trained and could quickly respond to a fire.
The above regional position on what constitutes a fire watch had not been previously communicated to the licensee. As a result, this concern is not being cited as a violation.
In addition, the safety significance of whether an hourly fire watch performs the fire watch duty or the control room staff is available to detect the fire is minimal.
The licensee assigned the fire watch duties to an hourly fire watch during the inspection.
3.4 10 CFR 50.59 Review Reauirements for Fire Protection Two 50.59 reviews had been performed for changes in the fire protection program.
Evaluations were thorough and had addressed safety concerns.
A 50.59 was performed for a temporary modification to install smoke detectors near a themo-lag fire barrier which is currently monitored via a video camera.
The area in the torus contains very little combustible materials.
The smoke detectors were added to the area to supplement the use of the video camera to ensure a fire is detected early in this area.
A second 50.59 was written to extend the surveillance on testing smoke detectors from 6 months to 1 year. This change was consistent with the requirements of the National Fire Codes NFPA 72E, 1990 Edition. The smoke detectors are highly reliable with a very low failure rate, so the extension of the surveillance should have little effect on the increase in risk from fires.
3.5 Diesel Fire Pumos The diesel fire pump and electric fire pump had a low unavailability, but some discrepancies were noted.
The housekeeping around the diesel fire pump was poor with numerous soaked rags under the diesel indicating a poor material condition. The electric fire pump had substantial quantities of water leaking past the seals.
The hoses and wiring on the diesel were in good condition.
One concern was that the fire pumps were being used to pump the water pit for cleaning which could contribute to quantities of grit and dirt getting into the main fire loop and subsequently into the entire fire protection system.
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During the time the pit was being cleaned the fire main system was declared inoperable because no method existed to supply the required quantity of water to the system. Appropriate fire watches were posted as a compensatory measure.
3.6 Fire Briaade The inspector reviewed fire brigade qualifications records, which included drill and other training records. Onsite fire drill requirements had been met by all brigade members who were listed as qualified.
Live fire training for all brigade members was being conducted on an annual bases at Kirkwood Community College. Proper critiques of the drills had been completed.
Pre-fire (fighting) plans were a good representation of the conditions in the plant.
However, one inspector concern was that the actions in the fire plan for a cable spreading room fire was to switch to the alternate shutdown system. As indicated in Section 3.2, a number of control cables for alternate shutdown systems are routed through the cable spreading room thus increasing the risk that this equipment would be inoperable. The licensee stated that operator training for this condition had been implemented but the discrepancy in the fire plan had not been noted. The licensee stated that the statement would be removed from the pre-fire plan.
3.7 Fires The inspector reviewed the following three fires. One fire occurred in the switchyard. The deficiencies are documented in Inspection Report No.
50-331/92006. Corrective actions had been taken to prevent a recurrence of these problems.
A second fire was a river water pump motor breaker fire. The fire and corrective actions are documented in Inspection Report No. 50-331/92017. An offgas hydrogen burn with corrective actions is documented in Inspection Report No. 50-331/92020. None of the fires were indicative of a fire protection program problem.
3.8 Audits and Self-Assessments of Fire Protection Audit investvgations were detailed and thorough with adequate staff hours devoted to each audit. An independent person from outside the company had
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been assigned as a team member for the biennial and triennial audits.
The audits included good findings and recommendations to improve the fire protection program. The licensee had used the findings and recommendations to improve the fire protection program. All important fire protection areas had been assessed in the audits.
The following audits were reviewed:
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Fire Protection Audit, I-90-11, 8/22/90 b.
Triennial Fire Protection Audit, I-92-14, 7/17/92 c.
Biennial / Annual Fire Protection Audit, I-93-05, 6/01/93 3.9 Bio-Foulina The licensee was monitoring for zebra mussels.
No zebra mussels had been detected at the time of the inspection.
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4.0 Inspection Followup Items inspection followup items are matters which have been discussed with the i
licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. An inspection followup item disclosed during the inspection is discussed in Section 2.4 of this report.
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5.0 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations or deviations. An unresolved item disclosed during this inspection is discussed in Section 3.2 of this report.
6.0 Exit Meetina The inspector met with licensee representatives (denoted in Section 1) on August 13, 1993, and summarized the scope and findings of the inspection.
A second exit was held on September 23, 1993, to address the control room and cable spreading room barrier seal problems.
The informational content of the inspection report was discussed with regard to documents reviewed during the inspection. The licensee did not identify any of the documents as proprietary.
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