IR 05000461/1986015
| ML20215C868 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 10/02/1986 |
| From: | Holmes J, Muffett J, Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20215C864 | List: |
| References | |
| 50-461-86-15, NUDOCS 8610100506 | |
| Download: ML20215C868 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-461/86015(DRS)
Docket No. 50-461 Construction Permit No. CPPR-137 Licensee:
Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Nuclear Power Station, Unit 1 Inspection At: Clinton Site, Clinton, IL Inspection Conducted: September 9-12 and 17-18, 1986 m. d
. Inspectors:
oseph M. Ulie
/o - 2- %
Date Y L85L h Jeffrey Holme%
lo - 2-%
Date Approved By ames W. Muffett, Chief
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S Plant Systems Section Date Inspection Summary Inspection on September 9-12 and 17-18, 1986 (Report No. 50-461/86015(DRS))
Areas Inspected: Routine, announced inspection by Region III based inspectors to determine the licensee's readiness of their fire protection program in preparation to 1 cad fuel. This review included a continuing review of the fire protection construction and preoperational test program, and a followup of items opened during previous inspection visits including Inspection Reports (IR)
(461/85047, 461/86017, and 461/86028). This inspection was conducted in accordance with Inspection Procedures No. 30703, 37301, 70329, 92701, 92702, and 92718.
Results: No violations or deviations were identified.
8610100506 861002 PDR ADOCK 05000461
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Persons Contacted
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Illinois Power Company
- K. A. Baker, Supervisor, Inspection and Enforcement Interface
- G. W. Bell, Assistant-to the Plant Manager
- R. E. Campbell, Manager,-Quality Assurance
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- J. G. Cook, Assistant Plant Manager J. Emmert, Supervisor, Electrical Engineering J. Ertman, Startup Engineer
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- W. C. Gerstner, Executive Vice President
- J. Greene, Manager, NSED
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- J. Greenwood, Manager Power Supply
- D. P. Hall, Vice President
- J. S. Perry, Manager, Nuclear Program Coordination
- R. F. Schaller, Director, Nuclear Training
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- J. V. Sipek, Supervisor, Plant Fire Protection
- F. A. Spangenberg, III, Manager, Licensing and Safety
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- J. D. Weaver, Director, Licensing USNRC Personnel
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- T. P. Gwynn., Senior Resident Inspector
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The inspectors also contacted other plant' personnel including plant staff,
training, and construction personnel.
- Denotes persons attending the exit meeting on September 18, 1986.
2.
Actions on Previous Inspection Findings a.
(Closed) Open Item (461/85047-18): The NRR Fire Protection Reviewer observed that cable trays outside of the cable spreading room are not
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of Appendix A to BTP APCSB 9.5-1.
By licensee letter dated March 7, 1986, the licensee provided an analysis of the plant areas containing F
concentrations of cables and cable trays. Accordingly, automatic sprinkler systems have been installed in the zones delineated in the Safe Shutdown Analysis (SSA) and Fire Protection Evaluation Report (FPER). Based on NRR review of the SSA, FPER, and the cable tray analysis as discussed in Supplemental Safety Evaluation Report (SSER)
No. 6, the cable tray protection meets the intent of Section C.5.e of Branch Technical Position (BTP) - Chemical Engineering Branch (CMEB)
9.5-1, and is, therefore, acceptable.
b.
(Closed) Open Item (461/85047-21): During the September 1985
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inspection visit, the NRR reviewer observed that in many safety-related areas it was not possible to reach all locations with 75 feet i
of fire hose in accordance with Section E.3(d) of Appendix A to BTP APCSB 9.5-1.
By letter dated March 7, 1986, the licensee i
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indicated that corrective actions were taken to resolve this concern.
During the inspection conducted the week of April 28, 1986, three discrepancies regarding fire hose station installations were observed by.the inspectors.
Consequently, on September 10, 1986, an inspector while performing a plant tour of safety-related areas,- visually inspected seven fire hose stations including an actual measurement of one length of: fire hose.
attached'to the hose station standpipe.
In addition, a verification
'of these fire hose lengths inspected was performed by using pertinent-licensee drawings and found satisfactory. The inspector also toured portions of the Auxiliary, Containment, and Control Buildings visually checking that hose lengths on various hose stations were sufficient to reach general plant' safety-related areas as required by NFPA code which was committed to by the. licensee. The-inspectors' determination is that the licensee has met their commitment and the NFPA code by installing 50, 75, or 100 feet lengths of fire hose on hose racks or reels as described in the FPER.
In certain locations of the plant as approved by NRR, the licensee has installed additional lengths of hose separate from the installed rack and reel fire hose. Closure of this item also indicates that the licensee has met Section III.D of Appendix R as discussed in IR (461/86028).
c.
(Closed) Open Item (461/85047-22): During the NRR site audit, the Fire Protection Reviewer identified that the control room is not adequately separated from its peripheral rooms by fire rated construction and automatic sprinkler protection is not provided in the peripheral rooms
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according to Section F.2 of Appendix A to BTP APCSB 9.5-1.
In SSA Amendment 1, the licensee requested a deviation from this guideline.
As shown on SSA Figure FP-14b, the peripheral rooms are now separated from the control room by two hour fire rated construction and are
provided with complete fire detection coverage. As discussed in SSER No. 6, because the fire hazard associated with the rooms is low,
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because they are equipped with fire detectors, and because the control room is constantly attended, there is reasonable assurance that a fire L.
in any peripheral room would be promptly detected and extinguished by.
l-the operators with available equipment before threatening the control room. On these bases, the NRC staff concluded that the existing construction and protection of the control room peripheral rooms is acceptable. This item is considered closed.
d.
(Closed) Open Item (461/85047-24): During the NRR site audit, the Fire Protection Reviewer identified that fire protection for the containment and drywell have not been provided in accordance with NRC
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guidelines as specified in Section III.G of Appendix R to 10 CFR 50 and Section F.1 of Appendix A to BTP APCSB 8.5-1.
Specifically, the reviewers concern regarded Fire Area C-2 consisting of the containment building as not having an installed area wide fire detection system.
As discussed in SSER No. 6, linear thermal detectors have been installed in all cable trays containing safe-shutdown cables and in all safety-related cable trays with more than 40% fill.
In addition,
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redundant safe-shutdown divisions in this area are separated in accordance with Section III.G of Appendix R to 10 CFR 50. On the
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basis of NRR's review of the licensee's FPER and SSA, the NRC staff concluded that fire detectors have been provided on the basis of specific identified hazards in Fire Area C-2 in accordance with Section F.1 of Appendix A to BTP APCSB 9.5-1 and are, therefore, acceptable. A tour of the Containment Building, Elevation 803',
was conducted by a Regional NRC inspector and is discussed in Paragraph 2.1 of this report.
e.
(0 pen) Open Item (461/86005-EE): By licensee letter dated August 18, 1986, the licensee informed the NRC of a potentially reportable deficiency concerning unsealed penetration openings in a 3-hour rated fire wall on the 800' elevation of the Control Building.
Consequently, the licensee has performed reinspections of other designated fire barrier walls, etc., and have found additional other unsealed penetration openings.
On September 17, 1986, an inspector verified by visual inspection that those unsealed penetration openings specifically referenced in the Control Building, Elevation 800' (floor level), were found resealed with no observable opening. According to the licensee's staff, those other identified unsealed penetration openings are being resealed
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through an ongoing program by Bisco (vendor performing seal installation work). According to the licensee's letter, compensatory measures have been established in the form of hourly fire watch patrols. This item will. remain open pending licensee corrective action and NRC verification of this action prior to exceeding 5% power as committed to in the licensee's letter (U600686) to Region III dated August 18, 1986.
f.
(Closed) Unresolved Item (461/86017-01): An inspector raised a concern regarding the reportability of Licensee Construction Deficiency Report No. 55-85-03 documented in NRC IR (461/85003-EE).
By letter dated December 11, 1985, the licensee submitted documentation to substantiate the fire resistance rating of the block walls and, in SSA Amendment 1, requested a deviation from Section D.1.(j) of Appendix A to BTP APCSB 9.5-1 to the extent that it states that walls enclosing separate fire areas should have a minimum fire rating of three hours for the block walls separating these control building fire areas. As discussed in SSER No. 6, the documentation showed that the fire resistance rating of hollow concrete block walls can be estimated by an analytical method based on the aggregate type used in the block units, and the equivalent solid thicknesses of the wall.
The NRC staff reviewed the licensee's submittal and concurred with the licensee's statement that a nominal fire resistance rating of two hours can be attributed to the 8-inch-thick hollow concrete block walls installed at Clinton.
Each of the affected fire zones, except for Fire Zones CB-lh and CB-5b, wh? ?S have negligible fuel loads, is equipped with an automatic fire deteution system. The estimated fire resistance rating of the hollow
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concrete block wa'Is is greater than the estimated equivalent fire area and zone, except for the cable spreading rooms, the auxiliary electric equipment room, and the cable riser.
For each of these, an
' automatic sprinkler system has been provided.
The NRC staff was concerned that the degree of fire protection offered by the subject barriers would not be adequate to prevent the spread of fire from one area to another. SSER No. 6 highlighted the following:
(1) The combustible loading in the subject areas consists primarily of electrical cable insulation; (2) These cables are qualified to IEEE Standard 383-1974; (3) In view of the inherent ignition and flame spread resistance properties of IEEE Standard 383 qualified cables, and because each of the subject areas is equipped with smoke detectors, the NRC staff expects that any postulated fire would be detected during its early development stages and that appropriate fire brigade action would be initiated well before the structural integrity of the fire barriers is adversely affected; and (4) In the event that fire brigade response is delayed in those areas where the severity and duration of anticipated fires, in terms of material available to burn, is less than the estimated fire resistance rating of the barriers enclosing the area, the NRC staff expects the barriers to withstand the hazards associated with the area.
For those areas in which the estimated fire severities exceed the estimated fire resistance rating of the barriers enclosing the area, automatic sprinkler systems have been provided.
In the event of a fire in one of these areas, the NRC
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staff expects the sprinkler system to operate and control the fire until fire brigade action is initiated.
In the NRC staff's opinion, the sprinklers will provide adequate protection for the barriers until the fire is extinguished.
It is the NRC staff's judgment that with the detection and suppression provided, each of the subject fire areas is sufficiently bounded to withstand the hazards associated with the l
area and, as necessary, to protect the area from a fire outside the
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area.
On these bases, the NRC staff concluded that the 8-inch-thick hollow concrete block walls, with the fire protection provided, are adequate fire barriers for the fire areas listed in SSA Amendment I and are, therefore, occeptable. This item is considered closed, based on its technical merit; however, the inspector's position remains that this deficiency is reportable for Fire Area CB-3 under the provisions of
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10 CFR 50.55(e) and its applicable guidance documents since an automatic fire suppression system was required to be installed in this
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l area as a result of this deficiency. Closure of this item also closes IR(461/85003-EE).
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(Closed) Open Item (461/86017-02): On March 13, 1986, an inspector
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was present to witness the performance of the Diesel Generator Room l
No. 2 carbon dioxide (CO2) concentration test including an overview review of the Checkout and Initial Operations (C&IO) Test Procedure
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No. XTP-FP-CO-14, and the vendors (Chemtron) CO2 system Operation and Service Manual. During the performance of this concentration test, I
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the inspector observed the failure of one vertical ventilation duct fire damper out of three to close completely, due to the electrother-mal link (ETL) conduit having gotten wedged between the fire damper blade and the bottom of the fire damper assembly base.
In addition, the-inspector observed the failure of the CO2 te discharge into the-Diesel Generator Room due to a broken CO2 return line failing to actuate the master selector valve.
Consequently, during the licensee's investigation of the broken return line, an apparently defective solenoid was also discovered. The three deficiencies mentioned above constituted failure at this attempt for a successful C02 concentration test.
An inspector review of the Division II DG Room C&IO Test Procedure No. XTP-FP-CO-14, dated March 14, 1986, having been performed again on this date showed that the ETL's actuated satisfactorily and confirmed fire damper closure as required. The inspector also reviewed the CO2 concentration percentage readings from the strip charts used to show that a minimum concentration of 34% carbon dioxide was obtained within one minute after the start of the test; and a minimum concentration of 34% carbon dioxide was maintained for a minimum of ten minutes after the start of the test so as to satisfy the test
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acceptance criteria. The inspector confirmed these concentrations
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were met and exceeded. Therefore, this item is considered closed.
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h.
(Closed) Violation (461/86028-01): An inspector while performing a plant tour of the Fuel Building, Elevation 755', observed that one recently installed length of fire hose had a fog nozzle attached to the fire hose instead of the required solid stream nozzle. On September 10, 1986, an inspector while touring the Fuel Building verified that solid stream nozzles have been installed on hose stations numbered IFP603B, 1FP603L, IFP603Q, IFP603H, and 1FP603E.
The inspec-tor based on this reinspection and the licensee's other corrective actions discussed in their formal response to this violation including a review of the licensee's closure package has determined that the licensee has performed satisf actory corrective actions.
1.
(Closed) Open Item (461/86028-02): While touring the Containment Building, Elevation 803', an inspector observed a safety-related cable tray having linear thermal detector wire not installed in accordance with the manufacturer installation instructions. This cable tray was a Division 1 (coded blue) No. 17225-A-PIE at approximately Elevation 815'.
An inspector verified by visual observation that the installed cable tray detection system and five additional cable trays had the linear thermal detector wire installed according to manufacturer instructions. This item is considered closed and no further action on the part of the licensee is required.
J.
(Closed) Open Item (461/86028-04): During the review and walkthrough of certain licensee procedures relative to Appendix R by the inspection team, discussions were held regarding enhancements which could be done to the procedures to improve their use by the operators.
Consequently, the licensee performed the following procedural actions:
(1) As agreed during the April 1986, inspection visit, the licensee evaluated
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Procedure No. CPS 3312.01, Residual Heat Removal (RHR) and determined the flush portion (100 gpm) of Step No. 8.3.6.3.7 for emergency operations as would be the case during a postulated Appendix R fire scenario to be unnecessary and thus, has been deleted from CPS 3312.01,
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Revision 3, dated June 24, 1986; (2) A safe shutdown reference matrix has been added to Procedure No. CPS 1893.04, Firefighting, Revision 4, dated August 2, 1986. Appendix A to this procedure links the Prefire Plans, CPS 1893.04 MXXX series, to specific plant areas; (3) Prefire Plans have been-revised to include the preferred method of safe shutdown. The safe shutdown methods are defined in Sections 2.2.4 through 2.2.6 of CPS 1893.04; and (4) Emergency Operating Procedure No. CPS 4401.01, Level Control - Emergency, has been revised to include a note informing the operator that Prefire Plans suggest the preferred equipment priority to be used in the event of a fire. This is shown in Section 3.3.2 of CPS 4401.01, Revision 7, dated August 8, 1986, indicating that CPS 1893.04 contains guidance on selecting systems to maintain Reactor Pressure Vessel water level if a fire-exists in the plant. An inspector verified on a sample basis that the above actions had been completed.
Further, the pertinent inspector (BNL) was contacted regarding the licensee's action and determined to be adequate.
k.
(Closed) Open Item (461/86028-06):
Fire Area F-1 was found not to be in compliance with Section III.G.2 of Appendix R.
Specifically, it was the inspectors concern that a fire in Fire Area F-1 would damage redundant safe shutdown related systems and adversely affect safe plant shutdown.
It is the inspectors understanding that the licensee provided additional information to NRR and the results of NRR's analysis would be addressed in a future Safety Evaluation Report (SER).
According to SSER No. 6, dated July 1986, the licensee requested a deviation from the technical requirements of Section III.G.2 of Appendix R for Fire Area F-1.
SSER No. 6 highlighted the following:
Based on low in situ fuel load present in the area, it is not expected that a fire of significant magnitude or duration to occur in the subject fire area; should a fire occur in this area, their is reasonable assurance that the fire would be detected by the fire detection system and extinguished by the plant fire brigade before damaging redundant safe shutdown components; if the fire were to spread rapidly the perimeter construction of the individual zones, the fire rated penetration seals, the partial sprinkler system coverage, and the physical separation of redundant systems would all contribute to protect redundant systems until the fire brigade extinguishes the fire or the fire burns itself out. The inspector toured Fire Zones F-la, F-1m, Elevation 737', and F-1p, Elevations 755' and 781'.
For Fire Zone F-la, an inspector verified by taking measurements that the Balance of Plant (B0P) cable trays that are routed between the redundant cables are horizontally separated from the Division 1 and 2 cables by distances respectively in excess of 15 feet and 6 feet, as stated in SSER No. 6.
In addition, an inspector also verified by sampling two cables located in cable trays intervening between redundant trays that the construction of those cables inside the tray
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.are in fact.IEEE Standard No. 383 qualified cable. These two. cables included an instrumentation cable (K3E) numbered 10079B located in cable tray No.1889F in the Fuel Building, Elevation 781', and a control cable (C28) numbered 1FH04B located in cable. tray No.1815E in the Fuel Building, Elevation 737'.
Further, the pertinent inspector (BNL) was contacted regarding the licensee's action and determined to be adequate.
This was accomplished by pursuing the following path: (1) obtaining the cable tray and/or cable number and then utilizing the applicable Sargent and Lundy (S&L) cable tray loadir.g documents followed by the
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pertinent S&L Pull Card Cable documents; (2) the Baldwin Associates QC Receiving Inspection Reports and Documentation Checklists; (3) review
~ f the particular type cables Certified Test-Reports; (4) traced to o
the S&L Specification Sheets; and (5) employing Clinton Form 1921-D which establishes the requirements for inspection, testing, and quali-fication of cables as identified for those cables determined.to be Class IE qualified.
In addition, an inspector while in Fire Zone-F-10 also verified by again taking measurements that the redundant Division 1 and'2 safe shutdown related' cables are separated by approximately fifty feet as referenced in SSER No. 6.
Overall the inspector also made the following observations of those
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fire zones toured:
(1) the in-situ fuel load present was low and transient fuel load was negligible; (2) the fire rated penetration seals were in place in those walls designated as fire barriers; (3) physical separation was as described in the FPER and SSA and reviewed by NRR in SSER No. 6; (4) the plant fire brigade is operational and their effectiveness was determined satisfactory during a previous inspection visit; and (5)- fire detection is provided as.
described in the FPER and SSA and approved.by NRR.
-1.
(0 pen) Open Item (461/86028-07):
It was determined that isolation
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switches and redundant fusing was not installed for the 4160V circuit
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breaker (252-AT1AA1) for auxiliary transformer 1A and 480V circuit breaker (IAP07E1).
This transformer supplies 480V AC power to the 480V Bus 1A (1AP11E) which in turn provides power to the diesel generator room 1A ventilation fan. The ventilation fan is necessary to maintain the diesel generator room 1A ambient temperatures in a
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reasonable range. At the April 1986, inspection visit, the licensee
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L was still undecided as to the resolution of this issue.
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However, subsequently the licensee did chose to revise CPS Procedure No. 4003.01 to provide operators with a method for local control of the breaker during safe shutdown from the Remote Shutdown panel. The
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inspector verified that CPS Procedure No. 4003.01, Revision 5, dated July 12, 1986, was revised as discussed above.
In addition, the
licensee's NSED has issued CCT 042413, dated May 21, 1986, to investigate the inspector's concern further and are considering t
l issuing a plant modification to isolate breaker No. 252-ATIAA1 from h
the main control room; and to provide control of the breaker from the l
Remote Shutdown Panel during the plant's first refueling outage.
Discussions with the pertinent inspector (BNL) having raised this concern believe the licensee is pursuing resolution of this item satisfactorily. This item will remain open pending inspector review
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of the licensee's final resolution to this issue.
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~Also, the licensee demonstrated satisfactorily to the inspector through a review of drawing No. E0Z-1AP14, Revision E, dated May 2, 1985, that the breaker being addressed in IR (461/86028-03) is the same breaker mentioned in IR (461/86028-07). Therefore, IR
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(461/86028-03) is being closed to avoid duplication.
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(0 pen) Open Item (461/86028-09): Based on inspector observations, the inspector concluded that the licensee's entire fire protection program including administrative controls had not been fully implemented.
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During the inspectors inspection-visit a review of certain licensee administrative control related procedures were reviewed and determined to be acceptably written. On subsequent visits an inspector reviewed completed surveillances performed related to Housekeeping (CPS Proce-dure No. 1019.01), Open Flame Fermits (CPS Procedure No. 1893.02F001),
and Control of. Flammable and Combustible Liquids and Combustible Materials (CPS Procedure No. 1893.03) and no problems during this review were identified.
After an inspector performed plant tours on September 10 and 17, 1986,
of the following plantLareas: (1) Auxiliary Building, Elevations 781',
762', 737', and 707'; (2) Fuel Building, Elevations 781', 755',.737',
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and 712'; (3) Containment Building,. Elevations 828', 803', 778', and
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755'; and (4) Control Building, Elevations 825', 800', 781', 762', and
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737', it was the inspector's determination that the administrative procedures related to fire protection had been implemented since no violations of these procedures were found and since the inspector re-viewed certain completed' administrative control surveillance procedures not having identified any problems. However, the inspector was unable
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fire protection administrative controls. As a result this item will
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remain open pending further review by the resident staff.
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n.
(Closed) Open Item-(461/86028-10):
The itspectors observed numerous penetration. openings in fire barriers in safety-related areas where
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work was completed to seal penetration openings but were reopened to perform additional plant modifications such as pulling of cables and other activities. Similar observations were also made for previously
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L installed structural steel fire resistive material which was subse-quently ' observed with portions of the material removed. On
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September 10, 1986, an inspector toured the following plant areas:
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(1) Auxiliary Building, Elevations 781', 762', 737', and 707'; (2) Fuel l
Building, Elevations 781', 755', 737', and 712'; (3) Containment Building, Elevations 828', 803', 778', and 755'
and (4) Control Building, Elevations 825', 800', 781','/62', and 737'.
The inspector's general observations of designated fire barrier walls was that all openings had been sealed and that sprayed on fire resistive material
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was in place as required.
Based on the inspectors observations, this i
item is considered closed.
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(Closed) Open Item (461/86028-11): While on plant tours of safety-related areas the inspector observed doors designated as fire
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" Automatic Hold Open Devices," portable fire extinguishers, pneumatic hose
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assemblies, and other devices which prevented the ' fire doors from being maintained in the closed position. Three CPS procedures related to fire doors and hardware inspections of those doors had yet to be approved and implemented. On September 10, 1986, an inspector while touring those plant areas noted in Paragraph 2.n above; observed
' approximately eight double fire doors which had their automatic hold open devices. removed and those doors were found in the closed and latched position. This work was completed through plant modification FP-49 which was implemented by MWRs C11448 and C15442 to remove the fusible links. Further, an inspector observed an additional twenty fire doors which were also found in the closed and latched position.
However, the inspector learned that numerous other fire doors have been declared inoperable due to various mechanical problems; yet compensatory measures were implemented. The inspector made mention of-this at the exit interview of September 18, 1986, and the need for timely corrective action of inoperable fire doors.
The inspector.also reviewed CPS Procedures No. 9601.05, dated May 31, 1986, Revi_sion 20, and CPS 9601.06, dated April 25, 1986, Revision 20, utilizing the procedural information while touring the plant and found -
these procedures and use of these procedures satisfactory. CPS Proce-dure No. 9601.04 had been incorporated into CPS No. 9601.05 since the inspectors' last inspection visit. The licensee provided the
. inspector a copy of a licensee letter issued to all site personnel from the CPS Plant Manager, dated August 7,1986, regarding personnel responsibility to report unauthorized open or damaged fire doors.
Based on the above review, this item is considered closed.
3.
Exit Interview The inspector met with licensee representatives (denoted in. Paragraph 1) on September 18, 1986. The inspector sumarized the scope and findings of the inspection. The licensee acknowledged the statements made by the inspector at the exit meeting with respect to the findings. On September 19, 1986, the inspector also discussed with the Supervisor-Licensing Administrator the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. This member of the licensee's staff did not identify any such documents or processes as proprietary.
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