IR 05000454/1989002

Insp Repts 50-454/89-02 & 50-455/89-02 on 890123-0206.No Violations Noted.Major Areas Inspected:Implementation of Fire Protection Program.Weaknesses Noted in Control of Transient Combustible Matls & Control of Flammable Liquids

ML20235X159
Person / Time
Site:	Byron
Issue date:	03/02/1989
From:	Gardner R, Holmes J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235X156	List: IR 05000454/1989002 ML20235X151
References
50-454-89-02, 50-454-89-2, 50-455-89-02, 50-455-89-2, NUDOCS 8903130338
Download: ML20235X159 (11)

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U. S. NUCLEAR REGULATORY COMMISSION l

, REGION III l I

Reports No. 50-454/89002(DRS);50-455/89002(DRS)

Docket Nos. 50-454; 50-455 Licenses No. NPF-37; NPF-66 Licensee: Commonwealth Edison Company j Post Office Box 767 I Chicago, IL 60690 Facility Name: Byron Nuclear Power Station, Units 1 and 2 Inspection At: Byron Station, Byron, Illinois Inspection Conducted: January 23 through February 6, 1989 b

Inspector: JeMHolmes k2M9 Date hM -

Approved By: Ronald N. Gardner, Chief 3 87 Plant Systems Section Date Inspection Sunmary Inspection on January 23 through February 6, 1989 (Reports No. 50-454/89002(DRS);

No. 50-455/89002(DRS))

Areas Inspected: Routine, unannounced safety inspection conducted to review the implementation of the Fire Protection Program. This inspection was conducted in accordance with Inspection Procedures 64704 and 9270 Results: Of the areas inspected no violations were identified; however, weaknesses were noted in the areas of control of transient combustible materials and control of flammable and combustible liquids (Paragraph 3.a.). Strengths were noted in the revised Fire Watch Program (Paragraph 3.c.). Two open items were identified. The first open item concerned the need for the evaluation of temporary storaae of lubricating oil in safety-related areas (Paragraph 3.a.(2)). The second open item concerned the need to include all sprinkler control valves in scheduled surveillance (Paragraph 3.b.(2)). !

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DETAILS Persons Contacted Coninonwealth Edison Company (Ceco)

• +R. Pleniewicz, Station Manager M. Cichon, Technical Staff Engineer

• + Freidel, Technical Staff Engineer R. Flahive, Technical Staff Supervisor

+T. Higgins, Operating Engineer 0. Hoaglan, Technical Staff Engineer

+T. Joyce, Production Superintendent

• +D. Meier, Fire Marshal

• W. Pirnat, Regulatory Assurance M. Snow, Regulatory Assurance Supervisor L. Sues, Assistant Superintendent of Technical Services

• +K. Sullivan, Technical Staff Engineer T. Tulon, Assistant Superintendent of Operations

• R. Ward, Services Superintendent D. Winchester, Quality Assurance Superintendent

+ Zittle, Regulatory Assurance

• G. Stouffer, Assistant Regulatory Assurance Supervisor U. S. Nuclear Regulatory Connission (U. S. NRC)

P. Brochman, Senior Resident Inspector

+ Gilles, Resident Inspector

+ Denotes those participating in the exit meeting on January 31, 1989

(telecon).

• Denotes those participating in the exit meeting on February 6, 1989

(telecon). Action on Previous Inspection Findings (92701) (Closed) Unresolved Item (455/83-42-04): In a January 13, 1987 letter, S. Hunsader, CECO, to J. G. Keppler, NRC, the licensee stated that, "At the time of achieving 5% power, save for those seals that are subject to maintenance modification, there will be nine (9) seals that will not be completed. Incomplete in this connotation includes seals necessary for Unit 1 fire protection currently installed in Unit 1 and Unit 2 areas. These seals have been upgraded and need to be replaced to satisfy other Unit 2 design requirements such as Radiation Protecticn."

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During this inspection the inspector visually observed four of the nine seals identified in the January 13, 1987 letter to the NRC (Seal Nos. 3120, 3121, 3122 and 3127). The remaining five seals could not be visually observed because Unit 1 was at power. The licensee provided the inspector with action item record No. 6-87-2016, which indicated that all nine seals identified in the January 13 letter to the NRC were repaired and/or installe Based on the inspector's observations and the licensee's action item record, this item is considered close (Closed) Open Item (454/88009-02; 455/88009-02): As a result of identified Carbon Dioxide (00 7) system problems, the inspector was j concerned about the design reviews which were performed on other

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fire protection systems, and whether procedures for operation of fire protection systems were adequat During this inspection, the licensee provided the inspector with a January 25, 1989 Memo to File (File: 2.1.200(88-07)) which indicated that a partial design review of the various fire protection systems at Byron Station was performed. The memo further indicated that the intention of this partial review was not to assure zero discrepancies in the fire protection systems, but rather to validate the original design reviews performed on the systems as part of the station ;

startup program. The licensee indicated that the surveillance and '

the operating procedure performance which have occurred prior to and since licensing have demonstrated both compliance with design and the ability of the systems to perform their intended function. Based on the licensee's actions, this item is considered close . Routine Fire Protection Program The Byron Fire Protection Program has incorporated the defense-in-depth philosophy against hostile fires. The Byron Fire Protection Program philosophy of defense-in-depth consists of: Fire Prevention Detection and Suppression Mitigation of Fire Damage As indicated in Facility Operating License Number NPF-37 (Unit 1) and Facility Operating License Number NPF-66 (Unit 2) the licensee is required to maintain in effect all provisions of the approved Fire Protection Program as described in the Fire Protection Report for the facility through Amendment 4 (Unit 1) and Amendment 8 (Unit 2).

As part of this inspection, the inspector reviewed, on a sample basis, portions of the licensee's Fire Protection Program to verify that the licensee was implementing and maintaining the Fire Protection Program as required by the facility operating licens The inspection consisted of reviewing administrative procedures, surveillance and walkdowns of l several fire protection systems. The results of the inspector's review are as follows:

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' Administrative Controls As part of the licensee's Fire Protection Program, the licensee is required to develop and implement administrative controls to maintain the performance of the fire protection systems and personne (1) Control of Combustible Material The licensee has developed " Byron Administrative Procedure (BAP) 1100-7, Revision 4, titled, " Fire Prevention for Transient Fire Loading", to provide the necessary controls for use of combustibles in the plant and on the site property in order to assure adequate fire protection equipment is available, and/or proper compensatory measures are in effect if require The procedure required that lumber and other combustibles (e.g., plastic, tarps, etc.) used in the plant be fire retardant except as required for special applications authorized by the Fire Marshal. For safety-related areas, excess combustible materials resulting from work activity in an area must be removed following completion of the activity or at the end of the work shift. The procedure further requires other conditions and requirement The procedure allows for exceptions from the requirements of the transient fire loading procedure if approved by the Fire Marshal or appropriate designee. For example, on January 23, 1989, the inspector observed approximately 20 large bags of fire retardant plastic painter's tarps at elevation 383 feet in the Auxiliary Building at Columns Q and 17. The Fire Marshal indicated that the fire retardant plastic had been located on elevation 383 feet in the Auxiliary Building since December 20, 1988. The Fire Marshal also indicated that an hourly fire watch was provided for that area. The licensee indicated that the painting activity was not complete and in order to reduce the amount of contaminated waste, the fire retardant plastic was stored in the Auxiliary Building in an area covered by an hourly fire watch. The inspector informed the licensee that in addition to providing an hourly fire watch, the fire retardant plastic should be stored in a metal container. The licensee acknowledged the inspector's concern and planned to review this concern for future applicabilit Based on review of the licensee's transient fire loading procedure, no discrepancies were identifie (2) Flamable and Combustible Liquids The procedure titled, " Control, Use, and Storage of Flammable and Combustible Liquids and Aerosols," BAP 1100-9, Revision 3, was developed by the licensee for controlling and storing flammable and combustible liquids and aerosols in the plan . .

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The procedure indicated that flammable and combustible liquids or aerosols, when taken into the plant should be limited to only the quantity necessary to perform the job activity or the amount that can be used in one shift. Flammable and combustible liquids / aerosols shall not be stored in, near or adjacent to safety-related buildings or systems without prior approval of the Station Fire Marsha On January 23, 1989, with Unit 1 at power and Unit 2 in a refueling outage, the inspector observed seven 55-gallon drums of synthetic lubricating oil near Unit 1480 volt switchgear on elevation 426 feet, by Columns Q and.17. The temporary storage area was previously authorized by the Fire Marshal and a continuous fire watch had been established. The. licensee indicated to the inspector that the lubricant oil was required for the Maintenance Activities for the Unit 2 reactor coolant pumps. The licensee indicated that due to operational problems it became necessary to temporarily store the seven 55-gallon barrels of lubricating oil. At the request of the inspector, the licensee transferred the lubricating oil away from the Unit 1 480 volt switchgea The inspector informed the licensee that a fire protection engineer and safe shutdown systems engineer should evaluate temporary storage of the lubricating oil in a safety-related area required for refueling operations when the opposite unit is at power. This evaluation should consider and not be limited to providing additional fire protection and/or system upgrades in addition to the continuous fire watch. This is considered an open item (454/89002-01(DRS); 455/89002-01(DRS)) pending review of the licensee's action (3) Degraded Fire Barriers The licensee developed procedure BAP 1100-2, Revision 4, titled,

" Breaching of Fire Barriers, Fire Penetrations, Fire Dampers, Fire Doors and Fire Floor Plugs" to provide guidelines and l to define the actions necessary when breaching fire barriers, I fire penetrations, fire dampers, fire doors or when removing plugs from fire rated floor l l

The procedure indicates that all fire doors, fire dampers, fire !

seals and fire rated floor plugs, cable penetrations and piping penetrations are required to be operable. The procedure ]

q indicates that technical specifications or the applicable i Limiting Condition for Operation (LCO) shall be followed if any fire rated assembly, which separates safety systems or I systems important to safe shutdown, becomes inoperable. The Fire l Marshal, according to the procedure, will determine the compensatory measures to be taken, if any, for those fire rated assemblies which separate nonsafety-related areas. The procedure also contains additional instructions and detail l During the plant walkdown, no discrepancies were identifie i

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(4) Control of Ignition Sources Improperly used portable heaters,' cutting and welding:

operations have been known to initiate destructive and costly fires. The licensee' addresses the use of equipment.that normally creates an ignition source as listed below:

(a) Heat Generation Equipment and Heat Sources The licensee provided the inspector with the procedure title, "Use of Heat Generating Equipment and Heat Sources," BAP 1100-5, Revision.0, which was developed by the licensee to provide fire safety considerations and set forth guidelines concerning the use of any heat generating or heat source equipment used in the plant. The procedur provided general information such as removing spilled 011',

' dust, dirt, or combustible liquids from the work. area. The procedure also indicated that the heat generating or heat source equipment must not be left unat; ended while it is warm enough to cause ignition of any surrounding combustible material. In addition, the Fire Marshal must be contacted prior to the use of any heat generating equipment in the plant. During the review of this procedure, no discrepancies were identifie (b) Cutting and Welding The licensee's procedure BAP. 1100-20, Revision 4, titled,

" Fire Prevention When Welding, Cutting and Grinding" requires preparation of the area and inspection for fire prevention when any welding, cutting or grinding is to be performe The procedure requires a cutting,. welding and grinding permit if work is to be performed in areas not designated by the station Fire Marshal as welding areas. The procedure consists of general requirements, area preparation and fire prevention / fire watc In discussions with the licensee, the licensee indicated to the inspector that scaffolding used for welding operations is composed of fire retardant wood. The licensee, in some cases, does not provide a welder's protective blanket to protect the fire retardant woo The licensee contends that the fire resistive characteristicsofthewoodarethesame(ifnotbetter)

than the fire characteristics of the welder's protective blanket. The licensee indicated that the fire retardant wood is a limited combustible and will not support combustion if an impinging fire or ignition source is removed from contact with the fire retardant wood. At the

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request of the inspector the licensee agreed to review the use of fire retardant wood in conjunction with welding operations and to upgrade their responses to branch technical position Cl4EB 9.5-1, titled, " Fire Protection Program Requirements".

During the review of the licensee's cutting and welding procedure, no discrepancies were identifie Fire Protection System Surveillance The licensee's Fire Protection Program requires that the licensee test fire protection equipment and systems that are included in regularly scheduled station operating surveillance procedures. The inspector selected a sample of the completed licensee's surveillance procedures for review. During the review, the inspector determined the following:

(1) Quarterly Fire Protection System Sprinkler Alarm Surveillance The licensee's Quarterly Fire Protection System Sprinkler Alarm Surveillance, BAP 1400-T5, Revision 5, incorporated cycling the isolation valve and opening the inspector's test valve to ensure proper trouble and fire alarm conditions are indicated. The inspector reviewed completed Quarterly Fire Protection System Sprinkler Alarm Surveillance, dated April 20, 1988, August 26, 1988 and November 26, 1988. The surveillance were found to be acceptabl (2) Walkdown of lionthly Fire Protection Valve Lineup Surveillance During a walkdown, the NRC inspector identified four sprinkler system valves that were not incorporated into the monthly fire protection valve lineup surveillance procedure (0BOS 7.10.1.1.C-1).

Three of the four valves, 2FP359A, 2FP351A, and 2FP249 were provided with either a tamper alarm or were locked in the open position. Valve 2FP348 was not provided a lock or a tamper switch. This valve serviced one hose station. The licensee indicated to the inspector that the valves were not required by Technical Specifications and did not affect safety-related areas. The inspector informed the licensee that all control valves of the sprinkler system should be inspected at regular intervals as described by NFPA 13A, Section 2-7.1.4. This document recommends that the locked valves and valves with tampers be inspected at least once a mont The licensee provided a lock for control valve 2FP348 and initiated a review of all sprinkler system control valve In addition, the licensee committed to include all sprinkler control valves in the surveillance. This is considered an open item (454/89002-02(DRS); 455/89002-02(DRS)) pending review of the licensee's action _ _ - _ _ _ _ _ - _ _ _

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(3) Fire Protection Testable Valves Yearly Cycling Surveillance The inspector reviewed the completed fire protection testable valves yearly cycling surveillance dated August 1987 and July 1988. The surveillance were found to be acceptabl (4) Semi-Annual Yard Loop Hydrant Flush and Inspection The inspector reviewed the completed semi-annual yard loop hydrant flush and inspection surveillance results (BMS FP-5, Revision 2) for October 1987, April 1988 and November 198 The surveillance results were found to be satisfactor (5) Fire Hydrant Hose Annual Hydrostatic Test The inspector reviewed the completed fire hydrant hose annual hydrostatic test for September 1986, October 1987 and November 1988. The surveillance results were found to be satisfactor Annual Inspection of Foam Concentrate The inspector reviewed the completed surveillance for the annual inspection of foam concentrate, dated October 31, 1986, November 2, 1987 and November 1, 1988. The surveillance test only requires that the bottles be properly labeled and seale !

The licensee indicated that foam is shipped to the original manufacturer where test on the foam is conducted. The inspector informed the licensee that future test results from the manufacturer should be recorded on the surveillance. The licensee agreed to incorporate the manufacturer foam test results into the surveillance of the annual inspection of foam concentrate. The licensee indicated to the inspector that in most cases the .'

results from the manufacturer's test were satisfactory and in '

cases where the foam failed, the foam was replace I (6) Carbon Dioxide System Valve Position Monthly Surveillance i l

The inspector reviewed the carbon dioxide system valve position monthly surveillance for October 1988, November 1988 and December 1988. No unsatisfactory items were identifie l (7) Semiannual Surveillance of Fire Detectors The inspector reviewed the semiannual surveillance of fire detection instrument Zones 12, 11, 62, 61, 75, 40, 17, 68, and 22, dated November 198 No unacceptable items were identifie _ _ _ _ - _

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(8) Carbon Dioxide Tank Level and Pressure The inspector reviewed the CO., tank level and pressure weekly surveillance for January 5,1989, January 12, 1989 and January 19, 1989. No unacceptable items were identifie "

(9) Safe Shutdown Fire Damper Operability The inspector reviewed the Safe Shutdown Fire Damper Operability Test for August 198a and April 1986. No unacceptable items were identified. However, the licensee was informed of the need to use a heat gun to trip the dampers instead of manually holding open and then dropping the dampers. The use of the hea gun to test the fire dampers may expose problems such as dampers freezing in place, S-hooks preventing operation due to improper installation, etc. The licensee acknowledged the inspector's concern and will review this matter for future fire damper surveillance test applicabilit c. Fire Watch Program The licensee developed a fire watch program in March 1988 that is separate from the security function and is composed of six supervisors and approximately 35 fire inspectors (fire watches) who report directly to the Fire Marshal. The fire inspectors are provided with easily identifiable uniforms. The NRC inspector observed several of the fire inspectors during plant tour It was apparent that the fire inspectors were observant and enthusiastic in performing their dutie d. Hydrogen Tank Farm According to the licensee, there are nine fixed storage vessels capable of storing 60,000 standard cubic feet (SCF) of hydrogen at 2400 pounds per square inch (psi). In addition, there are provisions for storing two tube trailers capable of storing 40,000 SCF of hydrogen at 2400 psi. The licensee normally uses only one tube trailer. The system has been designed for automatic operation; however, the licensee has decided to manually operate the hydrogen system to limit the amount of hydrogen that may be emitted at any one time into the plan According to the licensee, the general equipment for the permanently j installed hydrogen vessels has been designed in accordance with the l requirements of the ASME Code for unfired pressure vessels. The .

rupture discs on the pressure vessels and the relief valves on the hydrogen manifold were installed per ASME Code Section 1. The hydrogen farm piping is constructed of red brass rated at 3,000 psi servic The piping on the regulated side (hydrogen maximum operating pressure is 125 psig) of the hydrogen tank farm and system is Class D carbon steel rated at 250 psi service, and is protected by a header pressure relief valve (OHY9315) designed to operate at 150 psig. The l

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underground-(carbon steel)' piping was installed per'Sargent and Lundy Standard Specification. No cathodic protection has been provided for the underground hydrogen piping line. The tube trailers utilized the )

DOT specification and regulation under which the containers were ]

fabricated. The licensee also indicated that annual inspections of 1 the hydrogen tank farm are performed per NFPA codes and that the hydrogen storage tanks are visually inspected every three years (per ]

ASME. Code Section VIII) by a certified Nuclear Inservice Inspecto The inspector toured the hydrogen tank farm and,~in general, found it I very well maintained. Based on the information provided to the 1 inspector and based on the walkdown of-the tank farm, the inspector determined the following:

(1) Although the underground Class'D carbon steel piping has been provided with a protective coating for corrosion resistance, faults and discontinuities could develop. Because of this, corrosion could develop. The corrosion may be caused by electric current leaking from metal piping to the ground and could be accelerated by stray currents or the presence of electric fields. An engineering study should be performed to determine if cathodic protection is required. The licensee indicated that an engineering study would be performe (2) The nine fixed horizontal hydrogen tanks are mounted and clamped in an assembly which does not appear to be capable of restraining the tanks in the event of a rapid release of hydrogen gas caused by a blown rupture disc or a rupture in one end of the hydrogen storage tank. The' licensee indicated that no seismic or missile ejection analysis has been performed, but stated that the remote location of the reserve bank'does'not endanger safety-related equipment when taking into account the projected paths of any missile ejection (3) To prevent inadvertent damage to the hydrogen piping and tanks from hydrogen tube trucks entering the fenced off hydrogen tank farm, the licensee was requested to consider the need for installed barriers. Additional lighting in the area would enhance safety in the event of night time deliveries of hydroge (4) In the event of a hydrogen fire in the tank farm the licensee indicated that the cooling of exposed hydrogen tanks would be accomplished by portable monitors (located in the plant) which would be utilized by the off-site Fire Departmen If a fire would occur in the hydrogen tank farm, it would be necessary to ;

provide quick and effective cooling water to the exposed hydrogen

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vessels. The licensee was requested to consider upgrading the fire protection for the hydrogen tank farm so as to provide adequate cooling to the hydrogen vessels in the event of an impinging fir L_ - _ _ _ _ _ _

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.. Open Items Open items are matters that have been discussed with the licensee, that will be reviewed further by the inspector and that involve some action on the part of the NRC, the licensee, or both. Open items disclosed-during the . inspection are discussed in Paragraphs 3.a.(2) and 3.b.(2). Exit Meeting On January 31, 1989 and February 6, 1989,'a conference call was held between the inspector and the licensee's representative. The inspector discussed the likely content of this report and the licensee did not-indicate.that any information discussed during the inspection could be considered proprietary in nature.

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