IR 05000456/1987027
| ML20238F672 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 09/08/1987 |
| From: | Gardner R, Holmes J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20238F661 | List: |
| References | |
| 50-456-87-27, 50-457-87-25, NUDOCS 8709160276 | |
| Download: ML20238F672 (11) | |
Text
.
.
..
U.S. NUCLEAR REGULATORY COMMISSION
_
REGION III
i Reports No. 50-456/87027(DRS); 50-457/87025(DRS)
Docket Nos. 50-456; 50-457 Licenses No. NPF-72; CPPR-133 Licensee:
Commonwealth Edison Company
,
Post Office Box 767 Chicago, IL 60690
=-
Facility Name:
Braidwood Statinn, Units 1 and 2 Inspection At:
Braidwood Site, Braidwood, Illinois Inspection Conducted:
June 10 through August 21, 1987 Inspector:
oE 8,1987
.
Dath k,h -
//
Approved By:
R. N. Gardner, Chief f/3/ 67 Plant Systems Section Date Inspection Summary Inspection on June 10 through August 21, 1987 (Reports No. 50-456/87027(DRS);
No. 50-457/87025(0RS))
Areas Inspected:
Routine, announced safety inspection of licensee action on previous inspection findings, licensee SER commitments, emergency lighting and unprotected opening.
(92701, 64704')
Results:
Of the four areas inspected, no violations or deviations were identified.
8709160276 070909 PDR ADOCK 05000456 G
,
- _ _ _ _ _ _ _ _ _ _ _ _ - - _ _
-
,,
en
.
DETAILS-
,
- 1.'
- Persons: Contacted CECO Personnel
- P. Barnes, Regulatory Assurance Supervisor
.
- M..~Lohmann,iProject Startup Superintendent T. Meyer,. Fire Marshal Y
- G. 0'Donnell, Fire Protection Engineer
' *G. Orlov, Staff Assistant to Project Manager
- K. Radke, Assistant Fire Marshal USNRC Personnel
'*T. Taylor, Resident-Inspector (OPS)
-
'* Denotes'those in attendance at the exit meeting conducted on I
June 25, 1987.
'** Denotes individual contacted at the conclusion of the inspection
.t on August 21, 1987.
- 2.
Licer.see Actien on Previously Identified Items
!
q a.
(0 pen) Open Item (456/86045-01):
Walkdown of procedure IBWOA PRI-5, Revision'1, " Control. Room Inaccessibility," 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 for access to and egress from safety shutdown related components should be reviewed.
During this inspection, the inspector determined the following:
Obstructions L
The licensee provided the inspector with an internal Ceco letter dated January 14,'1987 from E. Fitzpatrick to J. Deress (EEF/87-69; File: -SAF-5A) which indicated that Braidwood personnel have verified by a physical walkdown that all components required to maintain hot standby are accessible.
The licensee walkdown identified two components (in containment) that will be utilized to achieve cold shutdown conditions and which are not fully accessible.
The licensee
,
' demonstrated by climbing pipes and pipe supports that the components
'
could be operated.
The licensee internal CECO letter (previously mentioned) indicated that galleries will be installed for these
,
'
components during the next refueling outage.
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _
_ _ -
_ - _ _ _ - _ _ _.
_-
.
.
During the walkdown by the inspector and the licensee's staff on June 11, 1987 of sample portions of IBWOA PRI-5, the inspector verified that the equipment was accessible. The inspector indicated to the licensee that at location M-23 there was an obstruction that might not be readily seen by the shift foreman and other personnel in transit to the remote shutdown panel.
It was recommended that the licensee take corrective action to reduce the probability of head injury to an individual in transit to the safe shutdown panel.
During this inspection, the licensee committed to remove and reposition the obstruction.
In addition, the inspector also recommended that the licensee consider reducing the probability of head injury due to the duct work in the general area located outside of the IB Auxiliary feedwater diesel pump room. The licensee acknowledged the inspectors concern.
This portion of _the item remains open pending the completion of the gallery work in containment (for cold shutdown),
b.
(Closed) Open Item (456/86045-02):
The licensee was requested to provide an analysis that ensured that communication is available when control room inaccessibility procedure IB0WA PRI-5 is utilized during a fire and loss of offsite power.
To address this concern, the
' inspector requested the licensee to demonstrate that communication is available from the remote shutdown panel to the following areas:
1.
Containment 2.
Fire Hazards Panel 3.
1B Diesel Generator Room 4.
Residual Heat Exchanger Room The licensee indicated to the inspector that the telephone and portable radio repeaters are connected to the security diesel which would provide power should a loss of offsite power occur.
The Public Address System is connected to the 1B Diesel Generator which would provide power in the event of a loss of offsite power.
The sound powered phone obtains its power from the operator generated sound, and requires no additional energy source.
In the areas tested for communication, there was at least a telephone and sound powered phone connection in the area or easily accessible in a nearby area.
No noncompliance were identified, however, it was observed that during the communication test Channel 1 and 7 of the sound powered phone did not function properly. The inspector recommended that the licensee correct this minor deficiency.
Based upon the communication test, licensee statements and review of the applicable portions of procedure titled " Control Room Inaccessibility," this item is considered closed.
l
____ _
- -. _ - - - _ - _ _ _ _ - _.. _ _ _ _ _ _ -
-.
g.
..
.
c.
(Closed) Open Item (456/85045-03): L The fire wraps which are. required i.
to protect redundant trains were not. installed. The_ licensee 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, Paragraph.III.G.2 is incomplete.
The inspector sampled three locations on elevations 346, 364, and-383.(General Area) and visually observed that the fire wraps were installed. The licensee indicated'that'approximately two feet of fire wrap was not completed and that compensatory measures would be in. affect until the; fire wrap was completed.' Based on the inspector's observation, this item is considered closed.
,
,
d.
(Closed) Open Item'(456/86045-04):
In the auxiliary building, elevation 346, the; inspectors observed that redundant RHR systems l
(including pumps, motors, unit coolers and cables) were not. separated /-
protected as required. _The Braidwood: Safety Evaluation Report (SER),
.
!
Supplement No.-2,-dated October 1986, stated " Safe Shutdown Capability" by letter dated September 22, 1986, the applicant committed to-upgrade the wall between the redundant RHR pumps to one having aLli hour fire rating."'
Based on the visual observation' of-the upgraded wall by the inspector this item is considered closed.
e.
(Closed) Open Item (456/86045-06):
In response to this item the licensee made several recommendations (Technical Justifications)
and relocated some of the obstructed fire sprinkler system heads.
An inspection / review of these items was made with the licensee and their NFPA code consultant (M&M Protection Consultants). Listed below are the results.of that review:
Area-1-GG Waste Oil Tank - Head Nos. 1 and 2 are now i
satisfactorily located.
The response regarding Head
!
No. 3 is acceptable.
Area 1-JJ Component Cooling Pumps 4 For all of the heads identified, except No. 40, the action taken or the technical response is acceptable.
Head No. 40 was moved, but needs to be repositioned.
Area 1-LL, Pipe Penetration Area - Of the fire sprinkler
"
heads identified, Nos. 1, 2, 4, 10', 12, 13, 14, 16, 17, 18, and 19 have been either satisfactorily relocated or technical response is acceptable. Heads No. 6, 11, and 15 were moved, but need to be repositioned again. Head No. 20 still needs to be moved.
The inspector and the licensee toured the area where sprinklers were
,
required to be repositioned.
Based on the inspector's observations of the licensee actions taken in regards to the above concerns, this it?m is considered closed.
i
)
_ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _
l
.
.
L.
l f.
,(0 pen) Open Item (456/86045-08):
Gaps and holes existed in the I
steel diamond plate at the hatchway in the auxiliary building,
!
elevation 426, which under fire conditions could allow heat and products of combustion to rise into the vertical adjoining areas.
)
l During a recent inspection by NRC consultants it was noted that the l
licensee was to provide removable concrete panels for hatchways and I
caulk with DOW RT 96-081 sealant.
The licensee indicated the present status of the affected hatches was as listed below:
'
For Unit 1 Only
Location Type of Barrier Completed Elevation 426 Column Q-12 Concrete Panels Yes Elevation 426 Column U-13 Diamond Steel Plate Yes
Common For Unit 1 and Unit 2 Location Type of Barrier Completed Elevation 364 Column N & 18 Concrete Panel No 1.
The licensee indicated that compensatory measures would be in affect while the concrete panel on Elevation 364 at Columns N & 18 are not installed.
This item will remain open pending completion of installation of the concrete panel.
3.
Licensee's Commitments In Supplemental Safety Evaluation Report No. 2 In the Braidwood Supplemental Safety Evaluation Report (SSER) No. 2, the licensee made commitments regarding certain fire protection features in the following areas:
a.
Building Design b.
Alternative Shutdown Capability c.
Safe-Shutdown Capability
,
d.
Control of Combustibles i
e.
Electric Cable Construction, Cabie Trays, I
and Cable Penetrations.
l Listed below are the licensee's commitments in the Braidwood SSER No. 2 and status regarding these commitments for Braidwood Unit 1.
a.
Building Design Licensee committed to provide open stairways and certain
hatchways with automatic sprinkler protection or cover I
hatchways with steel barriers.
Based on the the inspector's observation, and licensee's actions, the license has complied with this commitment.
.
_ - - _ _ _ _ - _
- - _ - _ - _
__-
...
Licensee committed to seal _ gaps and openings in steel hatch'
- -
covers with fire-resistant caulk.
Based on the inspector's
'
observations and licensee's actions', the licensee has complied
.with'this commitment.
Licensee indicated that unprotected steel. beams framed.into fire
rated barriers will be protected with " fire proofing" equivalent
.to that of the ' barrier. ' Based on the inspector's observations and the licensee's actions,'the licensee has complied with this
. commitment b.
Alternative Shutdown Capability The staff expressed concern that a fire in the control room
could result in a loss of. power to electronic card readers and'
door locks, preventing operators from reaching locations necessary for achieving safe shutdown.
The licensee committed to modify the operating procedure to instruct the operators to take keys with them when control room evacuation is required.
The inspector observed the keys in the control room and also
' reviewed the modified " Control Room Inaccessibility Unit 1"
' Procedure (IBWOA PRI-5) that instructed the operator to take the keys when evacuating the control room.
No items of'
noncompliance ~were identified.
c.'
Safe-Shutdown Capability At> elevation 364 of the auxiliary building, one division
'*
of charging pump cables was to be protected by a three-hour rated cable wrap until the cables entered the charging pump.
cubicle (Zone 11.3D-1).
The inspector observed the three-hour rated cable wrap'on.one division of charging pump cables.
Based'on the inspector's observations and discussions with the licensee, no items of noncompliance were observed.
The inspector, however, was concerned with an opening on elevation 383 that exposed the redundant cabling on that elevation.
This concern is discussed in Section 5 of this report.
Within containment, eight reactor coolant system hot-leg
temperature instrumentation cables have a minimum horizontal.
separation of approximately 15 feet.
The licensee originally committed to protect one division of cables with a one-hour fire wrap.
The licensee, however, decided to utilize a spatial separation instead of the one-hour fire wrap.
In the licensee's letter, dated November 26, 1986, from S. Hunsader to H. Denton, the licensee indicated that a design change was implemented to re-route one division of reactor coolant system hot-leg temperature instrumentation cables so that redundant divisions of the cables would be separated by a minimum horizontal distance of 52 feet.
The letter also indicated that the separation was comparable to that of other system cables inside containment
1 _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ - _
- ?
4'
.
q'
,
.,
'
as described'in other Appendix R deviations.
Based on the
.]
modifi_ cation _which re-routed one division of the reactor d
coolant system hot-leg. temperature instrumentation cables and based on discussions with the licensee and NRR, the inspector determined that' licensee has met their commitment.
LThe>1icensee committed to upgrade the wall.between the. redundant f
!
RHR pumps ~on elevation 346 sto a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated barrier.
The j
inspector observed the upgraded barrier between the redundant
'
RHR pumps on elevation 346._ Based on the inspector's:observatio'n u.
of the upgraded I hour rated fire wall and discussions with the-licensee, the inspector determined that the licensee has-wmplied with this commitment.
'The licensee committed to complete the installation of all
communication and' emergency lighting systems to facilitate safe-shutdown.
'
The inspector's review of this commitment is discussed in Sections 2.b and 4 of this report.
- d.
. Control'.of Combustibles The staff observed that styrofoam plastic was being used as a
_
damming material during the installation of penetration seals.
The licensee indicated that this combustible material would be removed during the Quality Assurance / Quality Control inspection of the seals as part of a standard procedure.
Based on the inspector's observation of'several penetration seals, no item of noncompliance was identified.
The staff. observed piping identified as " oxygen" and " extremely
flammable gas" routed in the turbine and auxiliary building.
The licensee committed to abandon this gas line in place.
The inspector toured the rad chemistry lab area where the flammable gas and oxygen was utilized according to the licensee.
'The inspector observed no open flame burners.
The inspector also tourad the storage area where the flammable gas was originally stored.
The inspector did not observe any flammable gas cylinders connected to fuel piping.
The licensee indicated
'to the inspector that the " lines" were purged with Nitrogen and
' capped.
Based on the inspector's observation, the licensee complied with this commitment.
e.
Electric Cable Construction, Cable Trays, and Cable Penetrations The staff noted that spare conduit sleeves with screw type metal caps were not going to be sealed.
The licensee committed to seal spare conduits with fire-resistant material to form a three-hour
_ _ _ _ - - -.__ _ _ _
y
.+
,
f i
fire-rated barrier,.' consistent.with its penetration seal program.-
Any seals not. completed before fuel load will be monitored with hourly fire watches.
-The inspector sampled several areas with spare conduits and observed fire resistant material installed.
No items of noncompliance were identified.
f.
Water Suppression And Standpipe Systems.
'
The staff observed that' sprinkler heads were. obstructed
in areas including, but not limited to elevation 364 of the auxiliary building and elevations 364 and 426 of the turbine building.
The licensee committed to relocate obstructed sprinkler heads, to clear the. obstruction in accordance with
~NFPA standards criteria or provide. technical justification-for leaving the obstruction.
The licensee provided technical justification or relocated some of the obstructed sprinkler system heads.
4.
Emergency Lighting In Section III.J. of 10 CFR Part 50, Appendix R, emergency lighting units' are required with at least an eight-hour battery power supply in all areas needed for operation of safety shutdown equipment and in access.and egress routes thereto.
In the Byon/Braidwood Fire Protection Report Section 3.5.G of Branch Technical Position (B.T.P.) CMEB 9.5-1 titled " Lighting and Communication,"
the NRC position states " Fixed self-contained lighting consisting of fluorescent or sealed beam units with individual eight-hour minimum battery power supplies should be provided in areas that must be manned for safe shutdown and for access and egress routes to and from all fire areas." The licensee response to the B.T.P 9.5-1,-Section 3.5.G(1),
stated " Comply-fixed self contained lighting will be provided in all areas where manual operation is assumed in the safe shutdown analysis in Section 2.4."
'The inspector requested and was provided with the following information to demonstrate compliance regarding emergency lighting in areas needed for operation of safe shutdown equipment and in access and egress routes thereto:
Eight Hour Discharge Test Results of the Emergency Lights
(BW SD-LL-22)
Eight Hour Battery Operated Emergency Light 18 Month Inspection
Surveillance Procedure Eight Hour Battery Operated Emergency Light Quarterly Inspection
Emergency Light Modifications
!
- _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
l
.In the emergency lighting preoperational test results, Section 11.5 Data Sheets (of BW SD-LL-22) it indicated whether equipment was adequately
_
illuminated by the emergency lights.
The inspector questioned the licensee as to how the illumination was determined to be adequate.
The licensee indicated that adequacy of the emergency lights was based on observation by the test engineer.
On August 16, 1987, the loss of offsite power test was conducted and the-only lighting available for approximately the first 15 minutes was the eight-hour battery emergency lighting and the D.C. essential service lighting which is fed from the emergency diesel generators.
The inspector and the licensee walked down sample portions of the inaccessibility to control room procedure (PRI-5).
The lighting observed at the ESF cubicles and diesel generator panels appeared to be adequate based on the lighting from the eight-hour battery emergency lighting units and the D.C. essential service lighting.
The license has been requested to demonstrate that a fire will not prevent emergency lighting of access routes and areas where shutdown functions must be performed.
In addition, it did not appear that adequate lightning was available at the following locations:
a.
Pathway utilized by the equipment operator to go to the diesel generator at location 401/L-8.
b.
Pathway utilized by the equipment operator to go to the ESF switchgear room, Division 12 at Location 426.
It is the inspector'.s concern that adequate lighting is not available for access and egress routes to areas that must be manned for safe shutdown.
The licensee is requested to demonstrate that adequate emergency j
lighting is available for areas where shutdown functions must be
]
performed as required by Appendix R.
This is considered an unresolved
item (456/87027-01) pending review of the licensee's actions.
5.
Unprotected Opening Exposing Redundant Safety Related Equipment At elevation 364 of the auxiliary building the licensee was required to protect one division of the charging pump cables (C0A 2594) by a three-hour rated cable wrap.
The inspector observed that one division of
'
the charging pump cables was protected by a three hour wrap up to the 383 level, however, several inches away there was a 12 inch opening (1AI112) which exposed the charging pump cable (C0A 2594).
The inspector questioned why the opening was not sealed to provide a f
continuous fire barrier to the charging pump cable (C0A 2594).
The
,
licensee indicated that in Appendix 5.8 of the Byron /Braidwood Station Fire Protection Report, Deviation A.4 allows this opening to be present.
_ _ _.
_ __
. _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ - - _ _ _ _ _
-_.
__ _
_ _ _ _ _ _ _
_ _ _ _
..-
.
In Deviation A.4 it states "The floor location between fire zones 11.3-0 and 11.4.0 is not fire-rated.
There are unsealed floor openings and floor openings with non fire-rated seals.
In addition, area-wide suppression is not provided in either fire zone.
This is not in accordace with the guidelines of Section III.G.2 of Appendix R."
At the exit meeting, the inspector discussed protecting the charging pump cable C0A 2594 from an exposing fire on elevation 364 feet of
~.
the auxiliary building by protecting the opening on elevation 383.
The. licensee acknowledged the inspector's concern and indicated that this concern will be reviewed.
This 'is considered an Open Item (456/87027-02) 3 pending review and acceptance of the licensee's actions.
'
6.
Open Items v.
Open Items are matters which have'been discussed with the licensee, which will be reviewed by the inspector and which involve some action on the part of the NRC or licensee or both.
An Open Item is discussed in Paragraph,5.
7.
Unresoived 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 is discussed in Paragraph 4.
8.
Exit Interview The inspector met with licensee representatives denoted in Paragraph 1 during an interim exit on June 25, 1987.
The inspector summarized the scope and results of the inspection and discussed the likely content of this inspection report.
The licensee acknowledged the information and did not indicate that any of the information disclosed during the inspection could be considered proprietary in nature.
@
At the conclusion of the inspection on August 21, 1987, the results of the emergency lighting walkdown conducted during the loss of offsite power were discussed with the licensee (as documented in this report).
_ _ _ - _ _ _ _ _ _ - _ _
_
._
_
., _ _ _ _ _
_
-
--
. _ _
t-
..
3 -
e o
M O
r m4 C3 - :
-tU
.D Cd,
-
- f.
tn-Laa D W r-
-
.
-
l l
l l
,
I
!
.
i t