IR 05000456/1986045

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Insp Repts 50-456/86-45 & 50-457/86-33 on 860818-1022.No Violation or Deviation Noted.Major Areas Inspected:Facility post-fire Safe Shutdown Methods & Review of Licensee Routine Fire Protection Program
ML20213E167
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 11/07/1986
From: Holmes J, Muffett J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20213E116 List:
References
50-456-86-45, 50-457-86-33, NUDOCS 8611130036
Download: ML20213E167 (9)
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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-456/86045(DRS);50-457/86033(DRS)

Docket Nos. 50-456; 50-457 License No. NPF-59 and Construction Permit No. CPPR-133 Licensee: Comonwealth Edison Company Post Office Box 767-Chicago, IL 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, Illinois

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Inspection Conducted: August 18 through October 22, 1986

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Inspectors: Je ff Holmes (RIII)

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6m Approved By: James W. Muffett, Chief r D l16 b Plant System Section Date I,

Inspec_t_i_on e Sumary I

Inspection on o 22,,_19_8_6 (R_epor_ts_ N_o_.__50-45_6/8_6045]DRS);

l 50-457/Mi(f3M

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~~ ~ RS)JD_Augus_t_18_thru October

'A'rea's Iiispec_t_e_d: Special announced inspection by Region III based inspectors

! and their consultants to determine the adequacy of the facility's post fire

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safe shutdown methods, and a review of the licensee's routine fire protection program. This inspection was conducted in accordance with Terrporary Inspection Procedure No. 2515/62, Revision 2.

Results: Of the areas inspected, no violations or deviations were identified.

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8611130036 861107 6 i PDR ADOCK 0500

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DETAILS 1. Persons Contacted

  • M. Wallace, Project Manager
  • P. Barnes, Regulatory Assurance Supervisor
  • J. Bowers, OE
  • P. Boyle, Regulatory Assurance
  • J. Bruciak, Project Construction
  • C. Diaz, Fire Protection Engineer
  • D. Elias, Project Engineer
  • P. Holland, Regulatory Assurance

+S. Hunsader,

  • J. Kinsello, Assistant Fire Marshal
  • L. Kline, Regulatory Assurance
  • R. Kyrowac, Station QA Supervisor
  • M. Lohmann, Assistant Construction Superintendent

+G. Masters, Operating Engineer

+*T. Meyer, Fire Marshal

+*G. O'Donnell, Fire Protection Engineer

+*M. Pietraszewski, Engineer

  • H. Pontious, Regulatory Assurance
  • T. Prewdergast, Construction Quality Assurance Engineer
  • K. Radke, Assistant Fire Marshall
  • B. Rybak, Station Nuclear Engineer
  • C. Schroeder, Services Superintendent

+*T. W. Simpkin, Regulatory Assurance

  • D. Thornley, Project Construction
  • L. Weber, SF Sargent and Lundy Engineers

+*E. Crass, Licensing Project Engineer

  • J. Kish, Electrical Engineer
  • B. Salsbury, Mechanical Engineer
  • J. Reuan, Electrical Project Engineer Marsh & McLennan Protection Consultants
  • S. Chingo, Fire Protection Engineer Nuclear Regulatory Commission

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  • G. Gardner, Section Chief
  • Kropp, Senior Resident Inspector (Construction)
  • T. Taylor, Resident Inspector (OPS)

+*T. Tongue, Senior Resident Inspector (OPS)

  • Denotes those persons present at the preliminary exit interview on August 22, 198 + Denotes those persons present at the exit interview on October 22, 198 *

. Alternate Safe Shutdown Procedures

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The licensee's procedure entitled " Control Room Inaccessibility - Unit'1,"

1BWOA PRI-5, Revision 1 was reviewed. This procedure for alternative shutdown from outside the control room specifies the use of electrical

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and pneumatic jumpers to maintain hot standby in the course of blocking or resetting spurious safety injection signals which may have been caused by the initiating fir Specifically, such actions are identified in Appendices C and E of the Procedure and would be taken in the Auxiliary Electrical Equipment Room (AEER) shortly after reactor trip (Step 4). However, a fire in the AEER itself requires evacuation of the control room and is a situation governed by this procedure. The licensee's intent is to terminate any uncontrolled injection into the reactor coolant system which could cause loss of control of the pressurizer level and pressure, since letdown flow can not be established at this point.

I In addition to the apparent contradiction of Appendix R, Sections III. ,

and III.L requirenents that repairs in the form of applying jumpers can

! only be allowed to achieve and maintain cold shutdown and not to maintain hot standby, the procedure as currently written therefore calls for actions which are highly inadvisable by directing actions to occur in the AEER inmediately after a postulated fire in the AEER and reactor tri The licensee's contention that this is a generic problem could not be verified during the time of the audit. The licensee is requested to demonstrate that Sections III.G.1 and III C are not violated when I maintaining hot standby should a fire occur in the Control Room or the

AEE In the Braidwood Safety Evaluation Report Supplement No. 2 dated October

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1986, it states "By letters dated September 25 and 30, 1986, the

applicant revised the PRI-5 Procedures (which will prevent operators from

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using the jumpers at attain hot standby from AEER) for the safety injection system. The revised procedures will call for performing the functions manually at the SI Pumps, as stated in Attachment K of the

' PRI-5 Procedures. The staff finds this acceptable, and, therefore, this item is closed." Accessibility,to Valves Utilized for Safe Shutdown The walkdown of the procedure entitled " Control Room Inaccessibility, Revision 1," No. 1BWOA PRI-5 dated July 18, 1985 identified that the access to valves and other components was extremely difficult due to numerous obstructions. As discussed with the licensee, obstructions such as HVAC duct work, pipe supports and consideration of the planned emergency lighting (also refer to Section 17 of this report) for access to and egress from safe shutdown related components should be reviewed by human factors personne . . - - - --- - . - --- , . _ . - . . - - - - - . - . - . - - - ,

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This is considered an Open Item (456/86045-01; 457/86033-01) pending Region III verification of the proper final configuration prior to Initial Criticalit . Operators Awareness in Util_izing S_afe_Sh_utdown Procedure Based on a review and walkdown cf the procedure entitled " Control Room Inaccessibility - Unit 1," 1BWOA PRI-5, Revision 1 the licensee should clearly identify either in the procedure or on the remote stutdown panels, or both, those instruments and controls that are electricali., isolated I from the control room when the transfer switches are placed in the remote position. The transfer switches are placed in remote to prevent spurious signals. The operators should be trained to recognize the possible spurious actuations or indications caused by a fire. In particular, the procedures should indicate, and the operators should be trained to be aware, that the fire hazards panel is also electrically isolated from the control room to prevent spurious signal This concern has also been identified in the Braidwood Safety Evaluation Report Supplement (SER) No. 2, dated October 1986, and is being tracked as an Unresolved Item in the SE . _ Communications

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The walkdown of the procedure entitled " Control Room Inaccessibility, Revision 1, No. 180WA PRI-5, dated July 18, 1985 identified that the portable radios was deficient, specifically between the remote shutdown panel and containment. The licensce indicated that the deficiency of the radios was caused by the temporary removal of power to the repeater station inside containment. In a telephone conversation on October 22, 1986, the licensee indicated to the inspector that portable radios can only be used during refueling because of noise spiking. The licensee indicated that there are other means of conn:unication such as the paging system and the telephone system. The inspector questioned whether the paging system and the telephone would be available should a loss of off-site power occu The licensee indicated that the telephone system will be the only form of conniunication should a loss of offsite power occur because it receives power from the security diesel. This is considered an Open Item (456/86045-02; 457/86033-02) pending verification of adequate con;munication between the remote shutdown panel and containment by Region III prior to Initial Criticalit . High__ Low P_re_s_sure Interfaces

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The applicant's safe shutdown ar,alysis identified two high low pressure interfaces, namely, the RHR pump suction lines and the pressurizer relief isolation valves. The applicant determined that the RHR/RCS isolation valves operate spuriously only when the control switch at the main control board is closed and the reactor pressure switch interlock is closed. Since the reactor pressure switch is remotely located from the control room, this n'ethod was found to be satisfactor *

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The pressurizer isolation valves control circuitry is isolated from the control room by transfer switches and redundant fuses to provide an alternate source of 125 V DC control powe During the inspection, it was determined that the applicant has not performed a spurious signal analysis for the reactor vessel head vent valves 1RC-014A, B, C, and D. During the conference call held on August 28, 1986 between licensee and NRC, the applicant proposed the removal of power from these valves during normal operation. This concern has also been identified in the Braidwood Safety Evaluation leport (SER) Supplement No. 2 dated October 1986, and is being tracked as an Unresolved Item in the SE . Common Enclosure

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The common enclosure concern occurs when redundant circuits are routed together in a raceway or enclosure and the circuits are not electrically protected or when the circuits can be destroyed by a fire due to inadequate fire protectio At the Braidwood plant the common enclosure concern was answered satisfactorily when a sample of circuits selected were found to be 6 electrically protecte In addition, the applicant stated that non-safety related circuits were never routed from one train to anothe The applicant does not mix safety related cables in raceways and conduit Power, control and instrumentation are run in separate cable trays. The applicant analyzed for all cor. figuration in which non-safety related cables which share an enclosure with safety related cable Therefore, the common enclosure concern was addressed satisfactorily by the applicant. The fire wraps which are required to protect redundant trains were not installed. The applicant was able to demonstrate with drawings and engineering change notices that provisions are underway to have the fire wraps installed. The installation of the fire wraps required to comply with Appendix R, III.G.2, is incomplete. The applicant plans to. start installing the fire wraps on or about September 2, 1986 and should be completed prior to exceeding 5%. This is considered an Open Item (456/86045-03; 457/86033-03) pending verification of the fire wrap by Region II . Inadequate Fire Protection to Achieve and Maintain Cold Shutdown In the auxiliary building elevation 346 feet, the inspectors observed that redundant RHR Systems (including pumps, motor, unit coolers and cables) were not seperated/ protected as required per the requirements of l Section C.5.b.(2) of the sta'f fire protection guideline In Amendment No. 7, it indicates that the RHR System could be repaired with 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (which is the prescribed time to achieve and maintain shutdown, and i includes estimated times to complete any repairs). Allowance for repairs is consistent with the guidelines of Section C.5.b.(1) of BTP CMEB 9.5.1. However, the applicant's repair procedure only address repair of cables. The cable repair procedure has been reviewed and

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found acceptable. The licensee has no procedures for repairing other vulnerable components of the RHR system. The RHR System is vulnerable to fire damage. Therefore, the plant may not be able to achieve and maintain cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as stipulated in Section C.S.b.(1).

The Braidwood Safety Evaluation Report (SER) Supplement No. 2, dated October 1986 stated "By letter dated September 22, 1986, the applicant committed to upgrade the wall between the redundant RHR pumps to one having a 1-1/2 hour fire rating. Before exceeding 5% of rated power, the applicant will notify the staff if the upgrade of the wall is not complete. On the basis of limited combustible content, the staff concludes that the 1-1/2 hour rated wall is acceptable protection for the redundant RHR pumps."

This is considered an Open Item (456/86045-04; 457/86033-04) pending verification of the 1-1/2 hour rated fire wall between the redundant RHR pumps by Region III inspector . Sprinkler System Adequacy The sprinkler protection provided in the auxiliary building open hatchway between elevations 401 feet and 426 feet did not provide adequate protection for the unprotected opening. The licensee was requested to design a system that would provide an adequate level of protection by the use of draft stops around the opening and sprinklers below the hatchway perimeter at floor level 426 elevation. In addition, the inspectors observed in the auxiliary building on elevation 346 feet that no sprinkler system was installed to protect the stairway and hatchway in Zone 11.2-0. The licensee was requested to provide adequate sprinkler protection by the use of sprinklers below the floor and the use of the draft stops. This is considered an Open Item (456/86045-05; 457/86033-05)

and should be completed prior to exceeding 5% of rated power and will remain open pending verification of adequate installations by Region III.

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10 Obstructions of Sprinkler Systems The inspectors observed that sprinkler heads were obstructed in areas including but not limited to elevation 364 feet and 426 feet of the turbine building. The staff requires that sprinkler heads be repositioned and/or added to provide adequate protection from an exposure fir This is considered an Open Item (456/86045-06; 457/86033-06) and will remain open pending verification of licensee's corrective action Any modifications in safety related areas should be completed prior to exceeding 5% of rated power. Turbine building sprinkler obstructions will be evaluated, and sprinklers will be relocated, as required, before the end of the first refueling outag . Manual Hose Station Coverage

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The inspector identified lack of manual hose stations (standpipes) in the cable tunnel areas including the valve galleries. The licensee was requested to demonstrate the ability to provide adequate hose coverage for cable tunnel areas and the valve gallerie The Braidwood Safety Evaluation Supplement No. 2 dated October 1986 stated "By letter dated September 22, 1986, the applicant committed to provide additional hose l

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at a hose station to provide coverage to one of the valve rooms within the tunnel, before exceeding 5% of rated power. The other valve room within the tunnel can be served by a hose from an outside hose hous The applicant has verified that adequate pressure and flow are available to accommodate the additional hose. The applicant has committed to revise its pre-fire plans to account for this additional hose before exceeding 5% of rated power." This is considered an Open Item (456/86045-07; 457/86033-07) pending review of licensee's corrective action . Detection The inspectors identified that the licensee has not installed smoke detectors in the control room main console. The licensee was requested to install detectors to insure that a fire inside the main console would be identified in it's initial stage This item is currently being reviewed by NRR and is an Open Item in the Braidwood Safety Evaluation Report, Supplement No. 2, dated October 198 . Steel Plate Hatchway Gaps The inspector observed in the auxiliary building, elevation 426 feet that gaps and holes existed in steel diamond plate at the hatchway which under fire conditions could allow heat and products of combustion to rise into the vertical adjoining areas. The Braidwood Safety Evaluation Report Supplement No. 2, dated October 1986, stated "By letter dated September 22, 1986, the applicant committed to seal gaps and openings in the steel hatch covers with fire resistant caulk before exceeding 5% of rated power."

This is considered an Open Item (456/86045-08; 457/86033-08) pending inspection of the installed fire resistant caulk by Region III inspector . Unsealed Spare Conduit Sleaves The inspectors observed unsealed conduit sleaves in rated barrier Openings through fire barriers for pipe should be sealed to prevent the passage of smoke and hot gases. The licensee was requested to insure the integrity of the fire barrier by sealing the inside of the spare sleave or provide test results from a recognized testing laboratory to justify that seals are not necessar The Braidwood Safety Evaluation Report Supplement No. 2, stated "By letter dated September 22, 1986, the applicant committed to seal spare conduits with fire resistant material to form a 3-hour fire-rated barrier." In addition it is also stated in the Safety Evaluation Report, Supplement No. 2, that "Any seals not completed before fuel load will be monitored with hourly fire watches."

This is considered an Open Item (456/86045-09; 457/86033-09) pending completion of sealing spare conduits in fire rated barriers with fire resistant materia _ _ _ _ _ __

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15. Rea c t o r 011_C_o l 1 e c_t c i op_ _Sy_s_t_em The licensee has provided an oil collection system for the reactor coolant pumps, however, it was identified by the inspector that a portion of the high pressure screwed connection on the discharge side of the oil lift pump did not appear to be adequately protected by shields to contain an oil release. As discussed in a telephone conversation between the licensee and Region III on October 22, 1986, the licensee was requested to provide a detailed engineering analysis regarding the high pressure screwed connection on the discharge side of the oil lift pump that was in question by the inspector. This is considered an Unresolved Item (456/86045-10; 457/86033-10) pending review of licensee's analysi !

16. Emergency _Ligh_tj n3 f_or Safe Shu_t_down_ _Equipmen_t '

The installation and testing of the emergency lighting required for safe

. shutdown was not completed at the time of the inspection. On October 10, 1986 in a telephone conversation between the NRR, licensee and Region III, the licensee comitted to complete the installation and testing of the emergency lights prior to Initial Criticality. This Open Item (456/86045-01;457/86033-01) was previously mentioned in Secticn 3 of this report and will remain open pending installation and testing of emergency light . ,Un_ der 3round Firemain l The underground firemain is supplied by one electric driven and one diesel drisen fire pump which under churn (test) condition develops a pressure of 230 psig. During normal operation of the fire pumps, the pressure relief valve for the fire pump is set at 170 psi The licensee conducted a hydrostatic test of the underground firemain at 235 psig which is not in accordance with NFPA-24 which indicates that

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"All new private fire service mains shall be tested hydrostatically at

! not less than 200 psi pressure for two hours, or at 50 psi in excess of the maximum static pressure when the maximum static pressure is in excess of 150 psi," (the licensee should have conducted the hydrostatic test at 280 psig).

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In a document entitled " Hydrostatic Test Pressure for the Underground Fire Protection Piping at Braidwood" dated October 1, 1986 (no author identified) it indicated that during future churn test the underground fire main will be sectionalized from the fire pumps by the use of two isolation valves in series. Pressure may be monitored downstream of the first isolation valv In a telephone conversation between the licensee and Region III on October 22, 1986, the licensee comitted to rehydrotesting the portion of the underground fire main that will not be sectionalized from the fire pump. This is considered an Unresolved Item (456/86045-11; 456/86045-11) pending review of the underground rebydrostatic test results and procedures that will be utilized for the churn test.

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1 Post Indicator Valves The inspector identified that the indicating sign for the post indicator valve was not secured in the proper position. The licensee indicated that Preoperational Tests were not completed. This is considered an Open Item (456/86045-12; 457/86033-12) which should be completed by initial criticality and will remain open pending review of Preoperational Test and inspection of Post Indicator Valves by Region II . Fire Dampers '

The inspector discussed with the licensee action taken to address the 10 CFR Part 21, report submitted by Ruskin Manufacturing Company regarding the potential problem with fire dampers failing to close under normal duct pressur The licensee should provide a valid engineering analysis which should include but not be limited to parameters such as size of damper, air flow, identification number / location and if installed in fire walls utilized for Appendix R considerations. It is recommended that it may be beneficial to review all fire dampers (regardless of manufacturer).

An option to providing the engineering analysis for the dampers would be to shut off inlet and exhaust air upon initiating the fire brigade. Should the licensee elect not to provide an engineering analysis then the licensee should provide the plant operating procedures and/or pre-fire plans for review. This is considered an Open Item (456/86045-13; 457/86033-13)

and should be completed prior to 5% powe . Open Items Open items are matters that 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 Sections 3, 5, 7, 8, 9, 10, 11, 13, 14, 18 and 1 . 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. Unresolved items disclosed during the inspection is discussed in Paragraphs 15 and 1 . Exit Meeting The inspectors met with licensee representatives denoted in Paragraph 1 at the conclusion of the inspection on October 22, 1986, and summarized the scope and findings of the inspection. The licensee acknowledged the statements made by the inspector. The inspector also discussed the likely information 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 proprietar

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