IR 05000461/1986028

Insp Rept 50-461/86-28 on 860428-0606.Violation Noted: Failure to Install Solid Stream Nozzle on Fire Hose in Fuel Bldg as Required by License SNM-1886

ML20211N704
Person / Time
Site:	Clinton, 07002947
Issue date:	06/27/1986
From:	Hodor R, Holmes J, Muffett J, Thomas H, Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211N693	List: IR 05000461/1986028 ML20211N690 ML20211N699
References
50-461-86-28, NUDOCS 8607030195
Download: ML20211N704 (40)

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION III

Report No. 50-461/86028 Docket No. 50-461 License No. CPPR-137 .

Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 1 .

Facility Naite: Clinton Nuclear Power Station, Unit 1 Inspection At: Clinton Site, Clinton, IL Inspection Conducted: April 28 through June 6, 1986

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Inspectors: . Hol s M @ % . LLOh UJ. Ulie M ) li "

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. Thom . Rfo y l$.

\,N R. Hodo _ M ,, Af l JJ Approved By: James W. Muffett, Chi bt 2.1,19 t%

Plant Systems Section Date

Inspection Summary Inspection on April 28 through June 6, 1986 _(Report e No.

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A_r_ea_s Inspected: Special, announceTlnspection Fy~lfeglin~DT a baseT in and their ccnsultants of licensee progress in implementation of the requirements of 10 CFR 50, Appendix R, the fire protection pre-operational test program, and i a review of allegations received by the NRC relative to pressure barrier seal This inspection was conducted in accordance with Inspection Procedures 30703, 37301, 41700, 42700, 64704, 70311, 70329, 92700, 92701, 92718, 92703 and 99014.

Results

Of the areas inspected, no violations were identified in five areas; i one violation was identified in the remaining area (failure to install a solid

' stream nozzle on a fire hose located in the Fuel Building as required by the Material License - Paragraph 2).

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9607030195 B60627 PDR ADOCK0500g1 i

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DETAILS

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1. Per_ sons Contacted Illinois Power Company ,

K. A. Baker, Supervisor Inspection and Enforcement Interface

• W. Bell, Special Assistant to Manager Scheduling and i Outage Management

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• R. P. 8 hat, Supervisor, HVAC and Fire Protection

• D. J. Brendley, Nuclear Training W. Connell, Manager Quality Assurance

• J. Cook, Assistant Plant Manager

• E. J. Corrigan, Director, Quality Engineering and Verification

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H. E. Daniels, Project Manager

• S. Fisher, Manager, Nuclear Flanning and Suppor'; .

• J. Greenwood, Manager, Power Supply

• D. L. Holtzscher, Director, Nuclear Safety

• E. W. Kant, Assistant Manager, Nuclear Station Engineering Design .

• J. Green, Manager Startup

• R. T. Kerestes, Project Manager, Fire Protection J *J. E. Loomis, Construction Manager

• J. F. Palchac, Supervisor, Plant Support SVCS

• J. S. Perry, Manager, Nuclear Program Coordinator P. Raysircor, Assistant Director, Nuclear Station Engineering Design t *W. S. Rives, Supervisor, Training Development

• J. V. Sipek, Supervisor, Plant Fire Protection

• F. A. Spangenberg, Manager, Licensing and Safety

• D. G. Tucker, Acting Director S/V Programs J. D. Weaver, Director, Licensing D. Wilson, Supervisor, Licensing Administrator Sargent and Lundy R. A. Parson, Mechanical Project Engineer

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D. K. Schofer, Site Manager

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Bisco, In L. Zimmerman, Engineer W. Alexander, Quality Control Supervisor USNRC Personnel

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P. Gwynn, Senior Resident Inspector

• P. Hiland, Resident Inspector The inspector also contacted other plant and contractor personnel including construction, training, maintenance, and operations personnel and licensee consultants during the inspection visi * Denotes persons attending the exit meeting on June 6, 1986.

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I 2. Actions on Previ_o_us _Insp_e_c_ tion _ Finding _

' (0 pen) 10 CF_R 50_.55_(eLRep_or_t_,_D_eficiency 55_-_84-23_Rus_k_i_n_Fi_re Dampers

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During a previous inspection the follcwing concerns were identified:

(1) By letter dated August 28, 1985 from D. H. Hall, IPC to J. Keppler, NRC indicated that " Illinois Power investigation of this matter is complete." This letter also described the investigation results, corrective action, and attached engineering change notices. The corrective action taken consisted of the following:

I Twenty horizontal dampers in the designated "VC" System (Control Building) are not acceptable. Heat detectors are to be provided within selected ducts so that administrative controls can be implemented to manually shut the fan off to prevent transmission of fire from one fire area to the othe ,

One verticale damper in the designated "VA" System (Auxiliary Building) is acceptable per the test results with the recommended change to larger springs. This change has been issued to the Zack Company on Field Engineering Change Notice (FECN)10503,datedJune 26, 198 Nine vertical dampers in the non-safety related areas designated "VF", "VJ", "V0", "VT", and "VW" Systems (Fuel Building, Machine shop, Off gas, Drywell, Turbine, and Radwaste Building, respectively) are not acceptable. Heat detectors are to be provided within the ducts to trip the fans off to prevent transmission of fire from one fire area

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to the othe During this inspection the licensee agreed to test several dampers in the most severe configuration to insure that dampers will close under air flow conditions (as conducted at the Ruskin

. test facilities). The licensee indicated that the test will be completed by the end of the first refueling outage. The inspector identified two open items regarding the same concerns, therefore, to avoid duplication of inspection effort, Open Item 461/85047-07 is being closed. This items concerns will be tracked as part of Deficiency 55-84-2 (2) Damaer Pr_e_operat_io_na_1 Te The licensee provided the inspector witi C&l0 Test Proced~ure_s XTP-00-10 and results for Partial Test Release No. I through No. 5, which identified the applicable HVAC system fire dampers that are required to be operable for fuel load, and those testing activities encompassed by individual General Testing Procedures GTP-38 which are satisfie The inspector reviewed several samples of Procedures XTP-00-10 and GTP-38 test for fire dampers. The inspector also compared the list of tested dampers (systems designated "VC" and "VL")

against the fire damper status list dated (January 22,1986).

No deviations were observe ~

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Based on the information provided this concern is considered resolve (3) er IVD 0948 Was Installed Backwards Which S-Hook For Fire Damp ~ Closure. TFe Ticensee provided tWe

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Could Prevent M id~e TnspectorTilli s an internal memo dated December 30, 1985 from D. G. Tucker to K. A. Baker which states "GTP-38 Revision 1, Step 7.3.1 (Attachment A) requires QC verification for proper installation of all "S" hooks. This verification will be recorded on Data Sheet "A" of GTP-38. The inspector noted that GTP-38 Test Procedure Revision 1 indicates that "S" hooks should be installed with the open end facing away from the fire damper. The inspector also observed several dampers in the field and did not observe any deviations. Based on the infor-mation provided by the licensee and the observations of the inspector, this concern is considered resolve b. (Closed) 10 CFR 50.5_5_(_e) Reporb Deficiency 55-85-07 Seismic Design

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and Construction of ASCOLs ~ Fire}oteci~ionTSysism On December 9, 1985, the licensee's correspondence No. U-600349, reported a potential design deficiency concerning the seismic design and construction of Automatic Sprinkler Company of America's (ASC0A's) sprinkler system in seismic Category I Buildings. The correspondence indicates that contract specifications were misinter-preted by ASC0A's engineers, such that no lateral supports were installed on sprinkler pipin To address this potential design deficency, Sargent and Lundy (S&L)

reviewed ASC0A's drawings for fire protection piping in Category I Buildings and identified on these drawings the location and direction of additional supports that would bring the ASC0A piping system into s compliance with the Specifications K-2856 and K-2857. The licensee indicated that when the Technical Specifications for the hangers *

could not be met, actual piping load calculations for that portion of the system were performed. For further information regarding these calculations, see NRC Report 461/8602 The NRC inspector observed several hangers from various fire protection piping in Category I buildings and compared them to the S&L revised as-built ASC0A drawings in which no discrepancies were identified. Based on the information provided to inspectors, and the observations made by the inspectors, this item is considered close (0 pen) IE Circular 78-18 dated November 6,1978 identified three concerns as follows:

(1) absorb flammable Flamastic liquid from77 anFire Retardant inadvertent CoatingsTFe spiTT~on may~issTde orire barrTe~r'~alilie bottom of vertiFaTlTay T ~Tttached to the licensee's internal memorandum dated August 6,n1984 from E. Haagar to D. Herborn (LO8-84[08-06]-6) is NSED review and response which indicated that the fire barrier sealing sub-l 4 1

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contractor anticipated that the proposed fire stops for vertical cable tray runs will be of a different (other than ceramic fiber) UL approved material. The licensee indicated to the inspector that Bisco Silicone Foam SF-20, SF-60, SF-150 NH -is fire rated and is nonabsorben The licensee provided the inspector with Bisco detail No. 107 through 112 and No. 126. The inspector noted that 9 inches of silicone foam is used above 1 inch of ceramic material in Bisco detail No. 107 and 110. Based on the fact that there is no gap between the silicone foam and the steel sleeve, the flammable liquid from a potential spill could not.be absorbed by the 1 inch of ceramic material. The concern regarding the absorption of flammable liquid into the fire barrier is considered close (2) Small fires may not-actuate _ Sprinkler Heads. To reduce the possibility of siriaWfires not actuating sprinkler heads, fast response sprinkler heads should be considered. In the August 6, 1984 memorandum (L0 8-84 [08-06]-6), the licensee indicated that all sprinkler heads installed by the CPS sub-contractor " Automatic Sprinkler Corporation" are UL listed and meet the requirements of UL Standard 199. Based

. on the licensee's internal response, it is not clear that the licensee considered in the system layout the concern for small fires not actuating sprinkler heads. This concern will '

remain open pending review and acceptance of the licensee's revised respons (3) Path of Air Movement Influences _ the Actuation _ of Detection Devices The tentative conclusion from the test also identified the concern that the location of fire detection devices is of great importance. The path of air movement in the area influences the actuation of such devices and should be considered in the system layout In the August 6, .1984 nemorandum (LO8-84[08-06]), the licensee states, " fire detection devices are installed as required by NFPA 72E which establishes the rules for location and spacing in high air moving areas." Based on the licensee's response, the concern regarding actuation of detection devices 'is considered close d. (Closed) Open Item (461/85-05-37): Paragraph 8.5.6 of SSER No. 1 !

documented a licensee commitment to have the plant administrative controls and procedures related to the fire protection program in !

place prior to fuel load. The administrative controls for fire  ;

protection as accepted by the Nuclear Reactor Regulation Division t (NRR) consist of the fire protection organization, fire brigade training, the controls over combustibles and ignition sources, the ' j pre-fire plans and procedures for fighting fires, and quality assuranc i l

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The inspector reviewed the following procedures as they relate to Clinton Power Station (CPS) administrative controls for fire protection:

(1) CNP No. 4.13 " Fire Protection Program," Revision 0, dated August 5, 1985; (2) CPS No. 1014.04, "Clinton Power Station Plant Staff Responsibilities Concerning Fire Protection," Revision 0, dated

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March 1, 1985; (3) CPS No. 1001.06, " CPS Fire Brigade," Revision 2, dated February 18, 1986; (4) NTD No. 2.3, " Nuclear Training Department Fire Brigade Training," Revision 2, dated February 10, 1986; (5) CPS No.1893.03, " Control of Flannable and Combustible Liquids and Combustible Materials," Revision 4, dated January 20, 1986; (6) CPS No. 1893.02, " Fire Prevention - Control of Ignition Sources," Revision 2, dated February 6, 1986; (7) CPS No. 1893.04, "Firefighting," Revision 3, dated April 25, 1986, including six plant pre-fire plans; (8) Section 9.5.1.5.4 of the FSAR, " Quality Assurance Raquirements,"

Amendment 37, dated March 1986; including Appendix B of the licensee's Operational Quality Assurance Manual as it applies to fire protectio The inspector concluded that these procedures as written meet the NRC,, supplemental guidance as delineated in the !' Nuclear Plant Fire i

Protection Functional Responsibilities, Administrative Controls and Quality Assurance" document as conunitted to by licensee letter, dated November 19, 1981 and Final Safety Analysis Report (FSAR)

Amendment No.14, although, implementation of these procedures could not be verified due to the licensee's fire protection program not having been fully implemented. This subject is discussed in more detail in Paragraph 4.k of this repor e. (0 pen)OpenItem(461/85-05-45): In the Clinton Supplemental Safety Evaluation Report (SSER) No.3 it stated "the applicant by letter dated April 29, 1982, has committed to install redundant fire alarm circuits for all circuits running between local supervisory fire

.i alarm control panel and the main fire alarm indicator in building that contain safety related equipment. One circuit will be supervised so that a single break or ground fault condition on the circuit will be indicated at the main fire alarm indicator in the control roo The redundant circuit will provide alarm indication at the main fire alarm indicator if the supervised circuit becomes disabled."

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In the Clinton SSER No. 5 it states, "In Section 9.5.1.2.2.1 of FSAR Amendment 29, the licensee identified the fire detection circuit supervision as Class A and in Section 9.5.1.2.2.7 as Class B. This is not consistent with either the licensee's commitment or the staff's findin By letter dated June 11, 1985, the licensee informed the staff that the proprietary protective signaling system circuits are wired so that a single break or ground fault will produce distinct audible and visual trouble indications in the control room, but will cause a false alarm signal or inhibit the emergency function of the transmitters connected to the circui The information submitted by the licensee in the June 11, 1985 letter, NRC concluded that the electrical supervision of the station's proprietary protective signaling system circuits is a Class A system as identified by M' a 72D-1975. This class of system is in accordance with Section E. NRC guidelines in Appendix A to Branch Technical Position (BTP) APCSE 9.5- On June 6,1986 the inspector requested that the licensee demonstrate that the fire alarm system is a Class A system. The licensee con-ducted an open circuit test on the control room ionization detectors and it was demonstrated that a fire alarm could be transmitted to the alarm control panel on either leg of the detection system. An audible alarm, visual display, and print out of the location of the fire alarm was observed by the inspecto The licensee conducted a ground fault (positive) test. It was demonstrated that a fire alarm could be transmitted to the alarm control panel. The inspector also observed the visual display, printout, and audible alar During the ground minus test, it was observed that all detectors for the zone were identified with a trouble alarm. At this point the test was stopped. The licensee indicated to the inspector that this problem was identified during the current Preoperational Test (which is still being conducted on the detection system) and that the manu-facturer will have a solution to the problem prior to fuel loa This item will remain open pending review and acceptance of the licensee's action ' (Closed) Open Item (461/85005-46): The CPS 1982 Safe Shutdown Analysis (SSA) for fire Protection contained the requiremA t to replace certain RHR MOV cables within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in order to achieve cold shutdow SSER No. 3, Paragraph 9.5.5 requested that verification be provided that procedures were developed and materials for the cable repair be stored onsite. CPS has complied with the request and developed Procedure CPS 8522.02, Revision 1, "RHR MOV Control Cable Replacement." In addition, replacement cable material is al:;o available onsite. However, during the review of the CPS 1985 Fire Protection SSA, it was determined that no cables are required to be prepared within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, since a change in the evaluation method resulted in an alternate shutdown path. The

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inspector has reviewed the licensee's resolution of this open item and finds it satisfactor g. (Closed) Open Item (461/85047-10): This open item concerns Allegations Numbered RIII-83-A-0029-02 and 03, respectively. These allegations state that penetration seals were installed with a two inch overlap on the seal boot instead of the required three inche Also, indicating that Bisco Company Procedures Numbered SP504, SP505, SP505-1, SP505-2, and SP505-3 were deficient. The inspector deter-mined that these two allegations were interrelated, and as such are discussed together. These two allegations are in regard to flexible boot seals which are designed for use as pressure barriers. In the inspector's review of documentation provided by the licensee during the September 1985 inspection visit, the inspector was unable to determine the basis for Bisco's overlap seam criteri Subsequently, discussions between the licensee and Bisco resulted in a Bisco letter to C. Peterson, IP, providing justification for the overlap seam criteria. This justification included Pressure Test Reports Numbered 748-109, dated September 15, 1983, and 748-124, dated October 14, 1983, each identifying the overlap seam as one inch and also cited Bisco Fire Test No. 748-112, dated August 23, 1983, as a test report to support Bisco's Production / Fabrication Procedures. According to Bisco, Bisco Form FB-4, " Maximum Boot Pressure Table" was developed based on the weakest link of the design, the boot sleeve attachment. Based on information provided at CPS including test reports and the previous experience the inspector has had in this area at other Region III sites, the inspector would agree with this conservative assumption. Therefore, increasing the Overlap seam would only increase the design strengt According to Bisco, the reason for varying seam width in their procedures is for installation convenience purposes onl Regarding adequacy of the Bisco Installation and Fabrication Procedures, the inspector learned and determined the following:

(1) Bisco Procedures Numbered SP-505-2 and SP-505-3 are not being used at CP (2) Bisco Procedure Number SP-505-1 has been incorporated into SP-50 (3) Step No. 7.2.2 of Procedure No. SP-505 indicates the overlap seam should be calculated from Production (Fabrication)

Procedure No. SP-504 references Bisco Form FB-1, " Bisco Flexible Boot Work Sheet," for determining the overlap seam which is derived from the test reports mentioned above as they relate to CP The current Bisco Installation and Fabrication Procedures in use at CPS are satisfactory for determining the overlap seam as derived from test report data. The inspector performing the allegation review i also consulted with a Regional Specialist having expertise in Contain- i ment Leak Rate Testing who indicated the flexible boot seal test i 8  ;

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T pressures exceeded those anticipated containment pressures expected under the postulated accident conditions and therefore, acceptabl Further, on April 29, 1986, the in,soector performed a visual inspection of eight flexible boot seals (identified by Penetration Nos. 2019, 2022, 3043, 3044, 3049, 3052, 3053, and 3058) and performed an actual overlap seam measurement of eight additional flexible boot seals (identified by Penetration Nos. 5029A, 5043A,

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5137A, 5143A, 5002A, 5049A, 5009A, and 5053A) adequacy. All i flexible boot seals inspected were found in an acceptable condition, although the inspector did observe one seal that was located in the Fuel Building on elevation 737, in a temporary sheet metal fabrica-tion area in which sheet metal was being stored against the boot seal so as to create a hazard to the seal. The inspector requested the sheet metal be moved. The licensee agreed to move the sheet metal. Based on the above inspection results, these allegations are considered close (Closed) Open Item (461/85047-11): American Nuclear Insurer's (ANI)

letters (IP Property Insurance Carrier), both dated August 20, 1985, to their Property Insured Utilities having Bisco Fire Stop Systems which advised that insufficient documentation existed to support the fire rating of certain Bisco cable tray and conduit fire stop designs as identified by ANI Acceptance Form S-26.

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According to an internal licensee memo, dated September 24, 1985, t from 0. Villarreal to F. Spangenberg, no seals of the type which

, failed the ANI test are utilized at Clinton Power Station (CPS).

This memo is supported by a second internal licensee memo dated May

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28, 1586, providing information discussed between a member of ANI staff and IP NSED staff identifying the specific configuration (one of the configurations noted above using ANI Acceptance Fonn S-26),

which failed the fire resistance tests as identified by the August 20, 1985, ANI lette During the inspector review, additional fire stop system configurations were reviewed and determined to also be using the ANI Acceptance Form S-26 and these additional configurations have been used at the CP These additional fire stop system configurations are being used to support two Bisco fire seal details numbered 105 and 110 as identified in Bisco's Design Drawing / Testing Matrix, Revision 6, dated January 8, 1985. According to Biscos' testing matrix, the two fire test reports applicable to drawing details 105 and 110 are numbered 748-15 and 748-64. Fire Test Report 748-64 was accepted on ANI Acceptance Form S-5 The inspector reviewed these two fire test reports using the licensee's commitment to meet ASTM E-119 test standard criteria as indicated in Section 9.5 of the FSAR. The inspector's review determined that the two test reports had temperature measurements taken on the unexposed surface that exceeded ASTM E-119 test standard criteria (325 F) and NRC criteria :

as identified in Section C.5.a.(3)(b) of Branch Technical Position (BTP) Chemical Engineering Branch (CMEB) 9.5-1 as also 325 F. By licensee letters dated February 17 and March 19, 1986, the licensee l

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identified three conduit penetration fire seal designs installed at CPS where the unexposed side temperatures exceed 325 F, and provided the fire test reports for these penetration sell designs to NRR for review as deviation requests. These letters identify Fire Test

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Reports No. 748-15 and 748-64 having been included in those submittals. According to SSER No. 6, temperatures in excess of 325 F were reached on the unexposed side of each of the three penetration seals at about two-hours. However, all of the test specimens remained in place without passage of flame or ignition of cables on the unexposed side throughout the three-hour fire exposure period, and remained intact and prevented the projection of water beyond the unexposed surface during the hose stream test. In addition, the temperatures of the unexposed faces of each penetration were less than both the self-ignition temperature of the cable insulation and the limiting end point temperature specified in IEEE Standard 634, "IEEE Standard Cable Penetration Fire Stop Qualification Test," at the end of the three-hour fire exposure and therefore, the temperature deviations are acceptable. The inspector has no further concerns in this area. Closure of this open item also closes Inspection Report Item No. 461/85012-E (Closed) Open Item (461/85047-14): During the September 1985 site inspection of the licensee's fire protection program for the CPS, the NRR reviewer observed that bus duct penetrations through fire barriers were not sealed to provide a fire resistive rating at least equal to that of the barrier in accordance with Section D.1.(j) of Appendix A to BTP Auxiliary Power Conversion and Systems Branch (APCSB) 9.5- In SSA, Amendment 1, the licensee requested a deviation from Section D.1.(j) of Appendix A to BTP APCSB 9.5-1 and provided justi-fication that adequate protection provided for safe shutdown components without the installation of fire rated seals in the bus ducts. The licensee's justification was based primarily on the equivalent design features of fire dampers and bus ducts and the fact that redundant safe shutdown components or methods of shutdown are not located within twenty feet of any bus duct penetration. Based on the licensee's justification, the fuel loads in the areas through which bus ducts are routed, and the protection provided, the licensee's deviation is accepted in SSER No. 6, in that the installa-tions of fire rated seals in the bus duct penetrations identified in Tables 4.2.2.15-2 of Amendment 1 of the licensee's SSA would not significantly increase the level of fire safet (Closed) Open Item (461/85047-16): It was identified during a previous inspection that some ventilation duct penetrating fire barriers were not equipped with fire rated dampers (Section D.1(j)

of Appendix A to BTP APCSB 9.5-1). The licensee provided the inspector with a package detailing the action completed to address this open item and it was verified complete by the responsible engineer, responsible supervisor, design engineer director, and NSED managed dated May 1, 1986. In the section titled, " completion", the licensee stated, " Illinois Power Company has completed a survey of the plant and concluded that all rated barriers required in the FPER have fire rated dampers either installed or will be installed prior to fuel load, except where specific deviations have been identifie .

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As of February 12, 1986, all Fire Dampers have been installed."

In addition, the package contained the HVAC Fire Damper status list, which listed the dampers at the CPS. The inspector observed several fire dampers in the field as identified in the Damper Status List and observed these dampers to be in place. Based on the licensee's previously stated commitment and the inspector's observations this toncern is considered resolve (Closed) Open Item (461/85047-17): During a previous inspection the tracks and blades of fire damper assemblies are loaded with dirt and debris (Section C.8 of Appendix A to BTP APCSB 9.5-1).

In the licensee internal memo dated December 30, 1985, from D. Tucker to K. Baker, it states "GTP-38, Revision 1, Step 7.1.1 in Attachment A, requires QC verification for cleanliness of all fire dampers for

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obstruction of any kind, which would interface with the free operation of the blade .

The inspector observed several dampers and did not observe a l condition that would interfere with the closing operation of the dampers. Based on the licensee's actions and the inspector's observations, this item is considered close . (Closed) Open Item (461/85047-19): The location of the fire pump flow meter discharge outlet relative to the pump intake may adversely

affect the fire flow test results (Section E.2.(c) of Appendix A to '

l BTP APCSB 9.5-1). The inspector was provided with a package detailing the action completed to address the open item which was verified complete by the responsible engir,eer, responsible supervisor, design engineer director, and NSED manager. The package contained Centrifugal Pump Checkout Procedure GTP-01, Revision 6, dated November 13, 1982, with Pump "A" and Pump "B" flow test results which were found satisfactor (Closed) Open Item (461/85047-20): During the September 1985, inspection visit, the NRR reviewer observed that the fire hydrant spacing exceeded the 250 feet NRC guideline as identified in Section E.2 of Appendix A to BTP APCSB 9.5-1. By letter dated March 7,1986, the licensee stated that the yard hydrants are installed at intervals of about 325 feet. The licensee further stated that additional hose lengths will be provided so that the j

installations will meet NFPA 24 and that the fire brigade will be trained to handle the size and lengths of hose provided. Based on the licensee's conmitments, SSER No. 6 indicates that the existing yard hydrant spacing meets the intent of Section E.2 of Appendix A to BTP APCSB 9.5-1 and is acceptabl During the April 1986, inspection visit, the inspector verified implementation of the licensee's commitment including a visual inspection of hose houses numbered 25, 29, and 30 having the specified lengths of hose as required by CPS Procedure No. 9017.18, and a review of fire brigade training attendance records, dated

. July 3,1985; June 6,1985; August 5,1985; and October 7,1985.

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Based on the above, the inspector concluded the licensee met their commitment as stated in their March 7,1986 transmittal to NR n. (0 pen) Open Item (461/85047-21): During the September 1985, inspection visit, the NRR reviewer observed that in many safety-related areas it was not possible to reach all locations with 75 feet 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 stated that the following corrective actions were taken to resolve this concern: (1) hose replacement with proper lengths of hose, (2) relocation of hose stations, and (3) installation of additional hose stations. To verify implementation of this licensee connitment, the inspector arbitrarily chose five hose stations through Engineering Change Requests (ECN) No. 6660, No. 6669, No. 6661, or No. 6671 having i

one of the three mentioned corrective actions related to particular plant hose stations. During the visual inspection of the five hose stations, the inspector observed the following (Inspection Concerns No. I and 2):

! (1) Radwaste Building, Elevation 737', 100' length of fire hose as specified by ECN No. 6669 was found satisfactor '

(2) Radwaste Building, Elevation 737', 50' length of fire hose as specified by ECN No. 6671 was found satisfactory, however, the hose length was stenciled incorrectly as being a 100' lengt (3) Fuel Building, Elevation 737', 50' length of fire hose, was found but a 75' length of fire hose is needed as specified by ECN No. 666 (4) Fuel Building, Elevation 755', a 75' length of fire hose, as specified by ECN No. 6660 was found satisfactor (5) Fuel Building, Elevation 755', a 100' length of fire hose as specified by ECN No. 6661; however, this hose station had a fog nozzle installed instead of a solid (straight) stream nozzle as required by Materials License No. SNM-1886, Item 1 The purpose of the materials license requirement relates to a concern

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of applying water from a fire hose in a fog pattern having an affect

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to cause the fuel to go critical, thereby, potentially releasing fission products from the fuel pool. Installation of the incorrect fire hose station nozzle is considered a violation (461/56028-01)

of the licensee's Material License No. SNM-1886. Regarding the other noted problems, the licensee planned corrective action is scheduled to be performed under Maintenance Work Request C0 123 At the exit meeting of May 2,1986, the inspector addressed the specific deficiencies identified above as being a concern; however, of equal importance is the programmatic breakdown to ensure licensee commitments and design criteria are reviewed so as to install and maintain properly the required plant fire protection equipmen This is the second such breakdown identified during a Region III l fire protection inspectio ,

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In addition, the licensee indicated that with the exception of the drywell, the control room, and the main steam tunnel, a maximum of 100 feet of fire hose will be provided for each hose connectio The use of 100 feet of fire hose meets Section C.6.c.(4) of BTP CMEB 9.50-1. For the drywell, the control room, and the steam tunnel, additional hose will be available. The inspectors verified an additional rolled length of fire hose is available at the nearest hose station protecting the control room. The licensee indicated that not all of the ECN's were completed and would have to be inspected at a later dat (Closed) Open Item (461/85047-23): The Turbine Building contains conduits identified as being safety-related (various sections of Appendix A to Branch Technical Position APCSB 9.5-1 and Appendix R to 10 CFR 50 apply to areas containing safety-related equipment)

which may have an adverse effect on a safe shutdown of the plan The licensee addressed this concern in Section 4.2.3.1.11 of the SSA. The inspectors reviewed this section of the SSA and also verified through a partial drawing review which concluded that the conduits and cables in the Turbine Bui.lding although classified as safety-related do not include any cables that will affect a post fire safe shutdown. The safety-related cables are associated with the main steam turbine and the leak detection system. The licensee's response to the above concern is satisfactor . Aypen_d_ix R_Backyound Information On May 23, 1980, the Commission issued a Memorandum and Order (CLI-80-21),

which states:

"The combination of the guidance contained in Appendix A to BTP

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(Auxiliary Systems Branch) (ASB) 9.5-1 and the requirements set forth in this proposed rule define the essential elements for an acceptable fire protection program at nuclear power plants docketed for a Construction Permit prior to July 1,1976, for demonstration of compliance with General Design Criterion 3 of Appendix A to 10 CFR Part 50."

On October 27, 1980, the Commission approved the final rule concerning fire protection. The rule and its Appendix R to 10 CFR 50 were developed to establish the minimum acceptable fire protection requirements necessary

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to resolve certain areas of concern in contest between staff and licensees of plants operating before January 1, 1979. On April 27, 1981, the Conmission required that operating licenses issued after January 1, 1979, contain a condition requiring compliance with commitments made by a licensee and agreed to by the staff after differences between the licensee's program and the guidelines set forth in Appendix A to BTP 9.5-1 and Appendix R to licensee's 10 CFR 50 have been identified and cvaluate The licensee has conmitted to comply with Appendix R in its entirety or provide equivalent protection as identified in Amendment 37 of the CPS FSAR dated March 1986, as stated in " Questions and Responses for Chapter 9," Question 410.7 (Chapter 9.5.1) whereby the NRC requested the

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licensee to identify any exceptions the CPS program takes to the require-m ments of Appendix R as well as BTP ASB 9.5-1, and also requested the licensee to describe alternatives for providing an equivalent level of fire protection. In addition, as mentioned in SSER No. 6, the NRC fire protection guidelines of BTP CMEB 9.5-1 also present acceptable criteria for development of a fire protection program and as such are also referenced. The inspectors performed a review of the licem.ee's commitments and the inspectors conclusions of that review are discussed in detail throughout this inspection repor The NRC Safety Evaluation Report (SER) dated February 1982, stated that on the basis of certain coninitments stated above and its evaluation, the NRC concluded that the Clinton fire protection program will meet the technical requirements of Appendix R to 10 CFR 5 . _1_0_CFR_Part 50, Appendix R Compliance As a result of the background information provided above, during this inspection, the inspectors examined licensee compliance with Section III of Appendix R to 10 CFR Part 50 as committed to by the licensee and accepted by NRC including water supplies for fire suppression systems, sectional isolation valves, hydrant isolation valves, manual fire suppression, hydrostatic hose tests, automatic fire detection, fire protection of safe shutdown capability, fire brigade, fire brigade training, emergency lighting, administrative controls, alternative and dedicated shutdown capability, fire barrier cable penetration seal qualification, fire doors, oil collection system for reactor coolant pump (s) and other NRC guidelines in accordance with NRC standard inspection practic Water Supplies for_ Fir _e Suppres_sion r Sys_tejnsSection III.A of Appendix R requires two separate redundant suctions ,

in one or more intake structures from a la je body of water, and that each supply of the fire water distribution shall be capable of providing for a period of two hours the maximum expected water demands as determined by the fire hazards analysis for safety-related areas or other areas that present a fire exposure hazard to safety-related area The inspectors toured the Circulating Water Screen House containing one diesel-driven fire pump (Fire Pump A) in a separate room within the screen house (Fire Area M4) having walls fire rated for three hours except for the exterior wall which is not fire rated. A second diesel-driven fire pump (Fire Pump B) was observed housed in a building located approximately 93' from the screen house and approximately 186'

from Fire Pump According to the FSAR and FPER, each fire pump is rated for 2500 gpm at 130 psig taking suction from Lake Clinton (fire protection and ultimate heat sink water supply) which provide a redundant fire protection system water supply as determined by the design maximum fixed water spray system demand of 2000 gpm for a safety-related area (cable spreading room) with a simultaneous water demand of 500 gpm for fire hose streams totaling 2500 gp a

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Based on the above, industrial fire protection pumps as installed at the CPS are designed to be able to deliver 150% of pump capacity at 65% of rated head, thereby, being capable of providing 3750 gpm at 84 psig in accordance with the National Fire Protection Association (NFPA)

Pamphlet 20; also coninitted to by the licensee in Section 4.0.E. of the FPER and CPS Procedure No. 1893.06(InspectionConcernNo.U3).

Refer to Paragraph 2.1 of this inspection report for further detail regarding the inspectors review of the installed fire pump's adequac The inspector also visually verified that the diesel-driven fire pumps and their control panels are U.L. listed as committed to by the

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licensee in Section 3.1.2.6 of the FPE According to Section 4.0.E.2.e of the FPER, the amount of water available for fire protection is 900,000 gallons thereby exceeding NRC guidelines. The inspector reviewed Amendment 37 of the FSAR showing that approximately 900,000 gallons is available for fire i

protectio Within these areas inspected of Section III.A of Appendix R, the inspector found those areas to be acceptable, b. Sectional Isolational ValvesSection III.B of Appendix R requires sectional isolation valves such as post indicator valves or key operated valves shall be installed in the fire main loop to permit isolation of portions of the fire

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main loop for maintenance or repair without interrupting the entire water supply. During this inspection, one of the Regional inspectors performed tours of the CPS plant power block area and a review of fire main loop drawings to determine licensee adequacy in meeting this requiremen Using the licensee commitments in " Questions and Responses for Chapter 9," Question 410.7 (Chapter 9.5.1) of the FSAR, Amendment 37,

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dated March 1986, as related to Section III.B and Section 3.1.2.6 of a

the FPER which indicate that post indicator valves for sectional isolation of the loop have been installed at CPS; the inspector

, performed tours of the power block area on April 29 through May 2,

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1986, and visually verified that UL listed post indicator valves (eight inspected) were installed showing that the valves were in the

"open" position (correct position for the applicable valves). In addition, the inspector reviewed fire protection Drawings No. M-1 and No. M-2 series showing that isolation of any one section (two sections sampled) of the fire main loop could be accomplished without affecting the balance of the fire main loop syste Within these arer.s inspected of Section III.B of Appendix R, the '

j inspector found those areas to be satisfactor c. Hydrant Isolation ValvesSection III.C of Appendix R requires hydrant isolation valves be installed to permit isolation of outside hydrants from the fire main

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for maintenance or repair. Without interrupting the water supply to automatic or manual fire suppression systems in any area containing or presenting a fire hazard to safety-related or safe shutdown equipmen In an effort similar to the one mentioned in Paragraph 4.b above, one i

of the Regional inspectors inspected the CPS plant power block area

> already noted and also reviewed the same fire main loop drawings as identified above determining that the above requirements were me The inspector using the same licensee conmitments as mentioned in Paragraph 4.b, verified that the three hydrants were inspected at Hose Houses No. 25, No. 29, and No. 30 had individual curb box valves provided. Further, as committed to by the licensee, each of these hose houses contained the specified lengths of 11 inch and 21 inch ,

. fire hose, a gated wye; firefighting hose spray nozzles; spanner wranches; and other firefighting equipment as required by CPS ,

Procedure No. 9071.1 The inspector's review of fire protection drawings No. M-1 and No. M-2 series showed placement of the curb box valves as verified by field inspection and that isolation of hydrants was capable without inter-rupting the water supply to fire suppression system Within these areas inspected of Section III.C of Appendix R the inspector found those areas to be satisfactory.

i d. Manual Fire Suppressio_n

Section III.D of Appendix R requires standpipe and hose systems be installed so that at least one effective hose stream will be able to reach any location that contains or presents an exposure fire hazard to structures, systems, or components important to safety. Access is required to permit effective functioning of the. fire brigade and standpipe and hose stations shall be inside BWR containments that are not inerte As identified in Inspection Report (IR) No. 461/85047-21, the inspectors observed that in many safety-related areas it was not possible to reach all locations with 75 feet of fire hose in accordance with Section E.3(d) of Appendix A to the BTP 9.5-1 or

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with Section III.D of Appendix R. By letter dated March 7, 1986,

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the licensee stated that the following corrective actions would be taken to resolve the inspector's concern: hose replacement with proper length of hose, relocation of hose stations, and installation i of additional hose stations. The licensee also stated that with the exception of the drywell, the control room, and the main steam tunnel, a maximum of 100 feet of hose will be provided for each hose connection. For the drywell, the control room, and the steam tunnel, additional hose will be available, if needed to ensure full hose stream coverag During this inspection visit the licensee had not performed all of the necessary corrective actions, therefore, this section of Appendix R remains open pending closure of IR Item No. 46;/85047-2 r This is further discussed in Paragraph 2.n of this inspeciion report.

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e. Hydrostatic Hose TestsSection III.E of Appendix R requires fire hose to be hydrostatically tested at a pressure of 150 psi or 50 psi above the maximum fire main operating pressure, whichever is greater. Also,Section II requiring hose stored in outside hose houses to be tested annually and interior standpipe hose to be tested every three year The licensee provided the inspector copies of CPS Procedures No. 9277.12 " Yard Fire Hose Inspection / Hydrostatic Test,"

Revision 20, dated February 2,1986, and No. 9277.11, " Fire Hose Hydrostatic Test," Revision 20, dated February 2,1986, respectivel An inspector review of these two procedures determined that the minimum hydrostatic fire hose test pressure to be attained during the test is 230 psig, which is acceptable based on the maximum fire main operating pressure of 170 psig plus 50 psi totaling 220 psi Additional review of these two procedures also showed the test frequency in accordance with Section II Within those areas inspected of Section III.E of Appendix R, the inspector found those areas to be satisfactor f. Automatic Fire Detection l Section III.F of Appendix R requires automatic fire detection systems shall be installed in all areas of the plant that contain or present an exposure fire hazard to safe shutdown or safety-related systems or components. Refer to Paragraph 2.e of this inspection report for further detail regarding the use of a Class A syste In addition to Section III.F of Appendix R, Section 4.0.F.1.a.(ii)

of the FPER indicates that linear thennal detectors are provided for all cable trays containing safe shutdown cables in containment, and that these detector will alarm and annunciate in the control roo In SSER No. 6 the licensee was granted a deviation from areawide fire detection in the Containment Building based on linear thermal detection being installed as described in the FPE During this inspection, one of the Region III inscectors while touring the Containment Building, Elevation 803', observed a safety-related cable tray having linear thermal detector wire not installed in accordance with the manufacturer installation instructions (Protective Operating and Maintenance manual for Protective Fire Alarm System undated). This cable tray is a Division 1 (coded blue)

No. 17225 A-PIE at approximately Elevation 815'. This item is considered an open item (461/86028-02) pending proper installation of the detector wire and verification of such by an NRC inspecto The licensee provided the inspector with Maintenance Work Order No. C03981 dated March 27, 1986, identifying that the licensee was aware of the problem and plans to take corrective action prior to fuel load (refer to inspection concern No. U-12). Three other cable trays were inspected in the area each having the detector wire installed in accordance with the manufacturer installation instruction . _ -

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g. _ Fire Protection of Safe Shutdown Capability

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Section III.G of Appendix R requires fire protection features shall be provided for structures, systems, and components important to safe shutdown. These features shall be capable of limiting fire damage so that:

One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station (s) is free of fire damage; and systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station (s) can be repaired within 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (1) Assessment of Append _ix R_ _C_ompli_anc_e

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On a sample basis, the inspectors examined measures that the licensee took to assure safe shutdowr capability and compliance with 10 CFR 50 Appendix R. The inspection consisted of an assessment of the licensee's implementation of Appendix R requirements for physical plant conditions and required operator actions, systems and components, operator training supplementary procedures, and methodology employed to mitigate resultant adverse equipment operability due to in-plant exposure fire The results of the inspection review is as follows:

(2) Systems Required for Safe Shutdown The Clinton Power Station Unit 1 is a GE Boiling Water Reactor (BWR) designated BWR-6. For compliance with Appendix R the following goals must be met to achieve post-fire safe shutdow Reactivity control capable of achieving and maintaining cold shutdown reactivity conditions (Reactor Coolant Temperature less than or equal to 200 F).

Reactor coolant make-up capable of maintaining water level above the core at all times during shutdown operatio Process monitoring capable of providing direct readings to perform and control the above function Supporting functions capable of providing process cooling, lubrication, etc. necessary to permit operation of the equipment used for safe shutdown function In accomplishing the goals outlined above, the equipment and systems used to achieve and maintain hot shutdown conditions should be free of fire damage and capable of maintaining such conditions for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> using onsite emergency power._ The equipment and systems used to achieve and maintain cold shutdown conditions should be either free of fire damage or the damage 18 .

a to these systems should be limited such that repairs can be made and cold shutdown conditions achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, using onsite emergency power only. The licensee defines hot shutdown as a condition with the reactor mode sritch in shutdown when the reactor coolant temperature is greater than 200 F, and cold shutdown as a condition with the reactor mode switch in shutdown when the reactor. coolant temperature is less than or equal to 200 (3) Safe Shutdown System Meth_ odology The licensee has designated three methods of safe shutdown in the report entitled, " Safe Shutdown Analysis for Fire Protection" (Amendment 1, February 1986).

Method I utilizes only Division 1 components and essentially

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involves use of the Reactor Core Isolation Cooling (RCIC)

with the turbine driven pump exhausting to the suppression pool. Some of the power operated safety relief valves are required to control Reactor Pressure Vessel (RPV) pressure and also to depressurize to enter into the cold shutdown phase. During hot shutdown, the suppression pool cooling mode of the Residual Heat Removal System (RHR) is activated using the Division 1 RHR Loop Method 2 involves the manual actuation of the D.ivision 2 Automatic Depressurization System valves (ADS) to depres-

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surize the RPV down to about 250 psia so that the Low Pressure Coolant Injection System (LPCI) can be activated to provide RPV makeup. RHR Loop B is activated for cold shutdown in the shutdown cooling mode. Division 2 ADS valves are used to depressurize during cold shutdow For some cases while using Method 2 safe shutdown the licensee stated that the core would be uncovered for a short time during rapid depressurization. Appendix R Section III.L requires that the reactor coolant makeup function shall be capable of maintaining the reactor coolant level above the top of the core for BWR's; however, an internal NRC memorandum (R. J. Mattson to L. S. Rubinstein) accepts the GE analysis (NEDO 24780A),

which concludes that the uncovery time is short enough to preserve fission product boundary integrity. The licensee also provided CPS-FSAR Figure 6.3-52 showing the highest temperature achieved well below the maximum allowable for the fuel cladding.

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Method 3 accomplishes cooldown and depressurization of the

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reactor pressure vessel (RPV) using Division 1 and 3

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' components. The High Pressure Core Spray (HPCS) system is used in conjunction with Division 1 SRV's and RHR Loop A in the Suppression Cooling Mode. For cold shutdown RHR Loop A is used in the shutdown cooling mode. Division 1 SRV's are manually operated for RPV depressurizatio . . _ . . . - -

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(4) , Performance Goals The required perfonnance goals will be met as follows:

(a) Reactivity Control The only system required for reactivity control is the control rod drive system. The control rod drive manually scram circuits are used to insert all control rods and bring the reactor to hot shutdown. Upon less of power the rods are designed to be driven in automatically and in case of fire damage to the logic circuitry, the system is designed to fail in the safe position (rods driven in).

(b) Reac_t_or e Coolant Makeup Method 1 is the preferred method of safe shutdown and relies on the use of the RCIC (Division 1) system drawing from the RCIC storage tank for reactor coolant makeup. Method 2 employs low pressure coolant injection for makeup following rapid depressurization with the ADS Division 2 valves. The High Pressure Core Spray System (HPCS) is used in Method 3 for reactor pressure vessel makeu (c) Reactor Pres _sur_e__

r Con _ trol and Decay Heat Removal To provide initial cooling and RPV pressure control after reactor scram and to maintain hot shutdown conditions, the RCIC is used in Method 1 in conjunction with the safety relief valves and the RHR Loop A in the suppression pool cooling mode. The RCIC system exhausts decay heat to the suppression pool. Decay heat is also transferred to the lake as the Shutdown Service Water System (SSWS) is used to cool the RHR-A heat exchanger Reactor Core Isolation Cooling System Equipment

- E51-F010 RCIC Pump Suction M0V

- E51-F013 RCIC Injection Shutoff M0V

- E51-F019 Minimum Flow to Suppression Pool M0V

- E51-F031 RCIC Pump Suction from Suppression Pool MOV

- E51-F045 Steam to Turbine M0V

- E51-F046 Lube Oil Cooling M0V

- ESI-F063 Steam Supply Line Isolation Inboard MOV

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- E51-C002 Turbine Trip & Throttle Valve MOV

• Residual Heat Removal (RHR) System

- E12-C002A RHR Pump

- E12-F003A Heat Exchanger Shell Side Outlet M0V

- E12-F004A RHR Pump Suction M0V

- E12-F006A&B Shutdown Cooling M0V

- E12-F008 Outboard Shutdown Isolation M0V

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- E12-F009 Inboard Suction Isolation M0V

- E12-F014A Heat Exchanger Cooling Water MOV

- E12-F042A' RHR Injection M0V Shutdown Service Water System

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- SX-01PA Shutdown Service Water Pump-

- SX-063A Diesel Generator Cooling Water M0V Diesel Generator 1A

- Start Stop Circuit

- Remote Governor Raise Lower Circuit

- Field Flashing Circuit

- Remote Voltage Raise Lower Circuit Diesel Generator Fuel Oil Transfer Pump 1A l

Diesel Generator Room 1A Vent Fan 4160V Bus 1Al Generator Feeder Breaker The inspectors determined that the control power to circuit breaker 252A T1 AA1 and circuit breaker 1AP07El could be damaged and not function as a result of a fire in the control room (see Section 7(b) of this paragraph entitled, " General Fire Instiga ted Spurious Si This is considered an Open Item (461/86028-03) and willgnals").

remain open pending review and a:ceptance' of the licensee's action '

The licensee has provided dedicated instrumentation to monitor reactor system conditions during post-fire safe shutdown and they are installed independently of the control roo In Method 2 decay heat is removed in conjunction with rapid depressurization by activating the Automatic Depressurization System (ADS) to open seven SRV's. RHR Loop B is used first for suppression pool cooling as needed followed by shutdown cooling when an RPV pressure of 125 psig or less is reache For Method 3 pressure control and decay heat removal are achievedusingtheHighPressureCoreSpraysystem(HPCS)

and Division 1 SRV's. RHR Loop A is used as required for

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suppression pool coolin (d) Process Monitoring The following process variables are monitored for safe shutdow RPV Pressure RPV Level

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Suppression Pool Temperature Suppression Pool Level RHR Flow, Loops A, B, & C RCIC Tank Level RCIC Flow SSW Flow - A & B (e) Support Systems The support systems required for safe shutdown are listed as follow Shutdown Service Water System 4160V Division 1, 2, 3 480V Division 1, 2 120V AC Division 1 & 2 125V DC Division 1 & 2 Diesel Generator 1A, B, C (f) Cold Shutdown _

Cold shutdown is achieved by placing either the Division 1 RHR Loop A in the shutdown cooling mode (Methods 1 and 3) or Division 2 RHR Loop 8 (Method 2) in the shutdown cooling mod If necessary, LPCI RHR shut off Valves E12-F024A, 8 can be used for injecting into the vessel. Concerns that this flow path might damage the fuel or in-core instrumenta-tion due to impingment were resolved b flow deflectors (GE Dwg. No. 112D3151)y installing LPCI

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(g) Alternative Safe Shutdown The licensee has provided a remote shutdown panel which relays on the blue train (Method 1) for alternative safe shutdown when evacuation of the control room is require Transfer switches and redundant fusing capability is installed to transfer and isolate the controls for the following:

The instrumentation is as follows:

RPV Pressure C61-R510 RPV Level C61-R509 Suppression Pool Temperature C61R512, C61R513, C61R514 Suppression Pool Level C61R504, C61511 RHR Flow C61R005 RCIC Flow C61R001 RCIC Condensate Storage Tank Level C61R505 The licensee had provided the necessary transfer switches, redundant fusing and instrumentation to effect alternating safe shutdown from the remote shutdown panel with the ,

exception of the feeder Breaker 252 ATIAA1 and 1AP07E '

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(5) Areas Whe_r_e Alternative Safe Shutdown is Required The licensee has stated that a fire in the following Fire Area or zones could require safe shutdown operation from the Remote Shutdown Panel: CB-3, CB-6a (Main Control Room Complex), CB-6d, CB-Sc, and the west side of CP-l Procedures ,

Procedures CPS 4003.1, Revision 3, entitled, " Remote Shutdown,"

is used by the licensee for those cases requiring evacuation of the Main Control Room. The scope of the review by the inspection team was to ascertain that shutdown can be attained in a safe and orderly manner, to determine the level of difficult 1y involved in operating equipment, and to verify that there is no dependence on repairs to achieve hot shutdown. The procedure requires three operators for implementation plus two operators as backup in the event of unforeseen difficulties during shutdown. The procedure lists transfer switches available at the RPS to transfer control to the RPS by operating all the switches or transferring only the system (RCIC or RHR, etc.) to be operated by the associated transfer switch. Operation of any single transfer switch will not transfer controls or indication for more than one syste Other procedures referenced in CPS 4003.01, and reviewed, are listed belo CPS No. 10P3310.01, Reactor Core Isolation Cooling CPS No.10P3310.01E001, Reactor Core Isolation Cooling Electrical Lineups CPS No.10P3310.01V.001, Reactor Cooling Isolation Cooling Valve Lineup CPS No. 3312.01, Residual Heat Removal (RHR)

CPS No. 3312.01E001, RHR Electrical Lineup CPS No. 3312.01V001, RHR Valve Lineup CPS No. 3312.01V002, RHR Instrumentation Valve Lineup CPS No. 4401.01, Level Control-Emergency CPS No. 4401.01F001, Level Control-Emergency Flow Chart CPS No. 4402.01, Containment Control-Emergency The inspection team observed during the procedural walkthrough on May 1, 1986, that the Remove Shutdown Panel Room did not have a cabinet for storage of procedures, communication accessories, flashlights, etc. Also, it was apparent that physically handling the procedures was awkward for the operators without a table or desk. The licensee's subsequent response was that the required procedures and equipment for shutdown from the remote panel would be taken to the RSP by the operators and that a work table would be provided. The inspection team found this acceptabl During the walkthrough the operator simulated performing step No. 8.3.6.3.7 of CPS 3312.01 (RHR) that calls for throttling valve No.1E12-F024A (RHR Hx Outlet Valve) to achieve a flow of i aproximately 100 gpm to flush and warm-up the RHR A loop. The inspection team pointed out that because of the large range of

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the flow indicator, the 100 gpm could not be set with a reasonable degree of certainty. The licensee agreed, and will evaluate this step to determine if the step is required for

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emergency conditions. If the step is required, the procedure would be revised substituting " bump valve for two seconds" for the 100 gpm. The licensee proposed the incorporation of a safe shutdown reference matrix as an Appendix to CP1893.04 Fire Fighting that would link the prefire plan numbers to specific areas. Additionally, the prefire plans for specific areas will be modified to include the preferred method of shutdown, and the applicable Emergency Operating Procedures are also being revised to include a note informing the operator that the prefire plans

. suggest the preferred equipment priority to be used in the event of a fire. The Procedure CPS 3312.01, Safe Shutdown reference matrix to Appendix CP1893.04, modification of the prefire plans to include the preferred method of shutdown and revision of E0P will be considered an Open Item (461/86028-04) pending review and acceptance of licensee's updated document During the walkthrough the operators relied on hand held radios which performed satisfactorily however the public address system (Gaitronics) and the sound powered phone system.was not available for use. This is considered an Open Item (461/86028-05) pending verification that the public address system and sound powered phone system are available for us ! 'The inspection team concluded after reviewing the procedures and l participating in the review, that Safe Shutdown could be achieved in an orderly and timely fashion, and that the operators exhibited a good knowledge of the system and steps require ,

(6) Appendix R Criteria 10 CFR 50, Appendix R, Section III.G.1 requires that one train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control stations is free of fire damage.Section III.G.2 and III.G.3 specify four alternatives that may be implemented outside of primary contain-ment to assure that the redundant train of equipment, cabling and associated circuits, necessary to achieve and maintain hot shutdown r'emain free of fire damage. The alternatives are as follows:

Separation of redundant trains of equipment, cabling and associated circuits by a three-hour rated fire barrie Separation of redundant rains of equipment, cabling and associated circuits by one-hour rated fire barrier with fire detection and automatic suppression systems installed in the area.

! Separation of redundant trains of equipment, cabling and

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associated circuits by 20 feet with no intervening ,

i combustibles and fire detection and automatic suppression I t systems installed in the area.

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• Installation of alternative or dedicated shutdown capability independent of the equipment, cabling and associated circuits under consideration and installation of fire detection and fixed fire suppression systems in the area under consideratio (a) Fire' Areas _Whic_h Meet III. The following fire areas were inspected and found to meet the requirements of 10 CFR 50, Appendix R, III.G.2. The fire areas are as follows:

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Fire Area A-2 RCIC Pump Room t RHR A Pump and Heat Exchanger

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Division 1 Switchgear Room (4160V AC 480V & 120V AC)

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Fire Area A-3 RHR B Pump, RHR C Pump

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RHR B Heat Exchanger Division 2 Switchgear Room (4160V AC, 480V AC & 120V AC)

Fire Area A-4 Division 1,125V AC Battery

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Room Fire Area A-5 Division 2, Cable Spreading Room

, Fire Area CB-2 Division 2, Cable Spreading Room Fire Area CB-4 Division 1, Cable Spreading Room Fire Area CB-5 Division 3, Switchgear Room Division 3, Battery Room t

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Fire Area D-4 Division 3, Diesel Generator

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4 Fire Area D-5 Division 1, Diesel Generator Fire Area D-6 Division 2, Diesel Generator Fire Area M-1 Division 1, Shutdown Service Water Pump Fire Area M-2 Division 2 and Division 3

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Shutdown Service Water Pump The electrical equipment which is located in these fire areas is required to provide 4160V AC, 480V AC, 125V DC, and 120V AC power for the operation and control of safe shutdown equipmert. An inspection of these areas demon-strated that the cables for redundant methods were not I

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installed in the same fire area and were separated by a three-hour fire rated barrie Fire areas that meet III.G.2 where cables for redundant Methods 1 and 2 are run in the same fire area and one method is protected by one-hour fire barriers are as follows:

Fire Areas 1-1 - This fire area encompasses fire zone Ala in which Method 1 and 2 cables are run. The licensee provided fire protection for the Division 2 cabling in fire zone la in addition to an automatic wet sprinkler system and detection. The cables provide power and control and instrumentation for the RHR A and B systems which are required for suppression pool and shutdown coolin No deviations were requested from the separation requirements of Appendix R, III.G.2. for the above fire area (b) Fire Areas Which Do Not Comply _with_ Append _ix_R, III. _

Fire Area F-1 includes two zones which contained cabling for redundant systems which could potentially be damaged due to the incidence of intervening combustible in the form of B0P cables. Fire Zone F-la contains redundant cabling for the Division 1 and 2 shutdown service water Pumps 1 and 2. The

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divisional cables are separated by approximately 100 feet, however, the B0P cables are routed between them in non interconnecting trays and there is no fire barrier protection between divisions and no suppression system installed. An ionization fire detection system is installed in this fire zone and portable fire extinguishers and hose stations are provided for manual fire fighting. A loss of both divisions of shutdown service water would eliminate the capability to cool the three divisions of the emergency diesel generator In addition, heat sink capability is lost for the residual heat removal syste Fire Zone F-1P presents a unique situation where the potential exits to lose both Divisions 1 and 2 power feeders from the emergency generator. The conduits housing the emergency generator power feeds IDG11A and B and 1DG31A and B are located on tne east wall of this fire zone and the separation between divisions is approximately 50 fee There are Division 3 cable trays in close proximity to these conduits and oriented in a manner to be considered as intervening combustibl No fire barrier protection and detection are installed in this fire zone F-IP. Portable fire extinguishers and hose stations are provided. The diesel generators are required as a source of power for safe shutdown equipment in the event of a loss of offsite powe .

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Fire Area F-1 was not found to be in compliance with Appendix R, III.G.2. It is the inspectors understanding that the licensee provided additional information to NRR and the results of their analysis will be addressed in a future safety evaluation report. This is considered an Open Item (461/86028-06) pending resolution from NR (7) Protection for Associated Circuits Appendix R,Section III.G requires that protection be provided for_ associated circuits that could prevent operation or cause mal-operation of redundant trains of systems necessary for safe shutdown. The circuits of concern are generally associated with safe shutdown circuits in one of three ways:

l Common Bus Concern Spurious Signal Concern Common Enclosure Concern The associated circuits were evaluated by the team for conmon bus, spurious signal, and common enclosure concerns. Power, control, and instrumentation circuits were examined for potential problems. A sampling basis was used in making the review, since many circuits were involved and a determination of cable routing took considerable time. The samples were selected based on the components which the licensee proposed to use for safe shutdow (a) Common Bus Concern 0 The common bus concern is found in either safety-related or non safety-related circuits where there is a common power source with shutdown equipment, and the power source is not electrically protected from the circuit of ' concer The team examined on a sampling basis, 4160 AC, 480V AC, 120V AC, and 125DC bus protective coordination. The team also examined, on a sampling basis, the protection for specific instrumentation, controls and power circuits, including the coordination of fuses and circuit breaker Samples selected for the coordination review are as follows:

4160V AC Feeder Breaker - Shutdown Service Water -

Bus 1Al of Bus 1A1 Coordination with D.G. Feeder Breaker 480V AC - Feeder Breaker - 15kVA Dist. Transformer 125V DC MCC 1A Breakers 125V DC MCC 18 Breakers )

125V DC MC 10 Breakers'and Fuses 480V AC ESF SWGR Bus 1A

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208V AC Type BQ, 3 Pole 120V AC Type BQ,1 Pole Some circuit breakers on the 480V AC, Busses IA and IB were found to be uncoordinated. Some of the breakers were as follows:

Auxiliary Building MCC 1A2 breaker 1AP73E Diesel Building MCC 1A Bre&ker 1AP60E Auxiliary Building MCC 182 Breaker IAP76E

Auxiliary Building MCC 183 Breaker 1AP776 The licensee initiated an engineering change notice No. 7179 to change the trip setting for the circuit br. sers of concer The licensee provided curves, calculations and drawings which demonstrated that the coordination of circuit breakers and fuses is normally in effect at the Clinton Power Station. No deviations were observed by the inspector The common bus concern was satisfactorily addressed by the license Spurious Sign _al Concer_n The spurious signal concern is made up of two items:

False motor, control and instrument indications can occur, such as those encountered during the Browns Ferry fire. These could be caused by fire initiated grounds, shorts, or open circuit Spurious operation of safety-related or non safety-related components can occur that would adversely affect shutdown capability (e.g., shutdown cooling system isolation valves).

Current Transform _er Secondaries The licensee had conducted an engineering review to-determine whether open circuiting the secondary of any ,

current transformer (CT) for post fire / safe shutdown I equipment would adversely impact their ability to bring the plant to safe shutdow An open circuit CT secondary would result in a failure of either the CT insulation, the terminal block or the l test switch. This type of failure would result in arching to ground and consequent shorting across the ,

CT secondary which is the desirable failure mode, i

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Open circuiting of differential relay cts will trip the related circuit breaker and transfer the ESF buses to a reserve power source.

i High-Low Pressure Interfaces The licensee had identified a number of high-low pressure interfaces which were subsequently analyzed to determine whether fire cause damage could result in a LOCA. The results of the analysis were as follows:

Components Function Resolution 1E12F052A and Steamline Isolation M0V Remove Power from 1E12F051A or 1E12F052A 1E12F087A l 1E12F052B and RCIC Steam or RHR Heat Remove Power from l

1E12,051B or Exchanger Shutoff M0V 1E12F0528 1E12F087A l

j IB2.F002 Head Vent Valve Power Removed from j 1821F001 Head Vent Valve at least one head

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vent valve i 1E12F008 and/or Shutdown Cooling Outboard Remove Power from

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1E12F009 Suction Isolation Valve 1E12F0008

(b) Ge_neral Fire _ _ Inst _ iga _ted Spurious Signals The licensee analyzed for other fire instigated spurious

signals. The type of events which were included in the analysis were as follows:

Spurious action resulting in loss of reactor coolant inventory to suppression pool Spurious opening or failure to close could result in r

loss of reactor coolant to the main steam condenser Spurious closure of the valve will isolate backup air to Division 2 ADS valves i

Failure of starting' air solenoids associated with a given diesel could make the diesel inoperabl Spurious closure of valves would cause a stoppage or service water flow Spurious opening when in shutdown cooling made would

result in loss of reactor coolant inventory to

suppression pool ,

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1L Spurious opening during LPCI mode would result in RHR flow to the suppression pool The corrective actions proposed included:

The removal of power by procedural mean's Tne use of the redundant method which was demonstrated to be free of fire damage The licensee was able to demonstrate that more than one spurious action was required in order to degrade a syste The redundant fuses required for achieving alternate shutdown when using the remote shutdown panel were included in the systems basic design and are presently installed with the exception of those for the feeder breaker for the auxiliary power transforme An equipment installation traveler No. C61-001 was presented which incorporated the installation of the isolation switches and redundant fuse which are part of the alternative safe shutdown syste During the review, it was detennined that isolation switches and redundant fusing was not installed for the 4160 V circuit breaker (25223ATIAA1) for auxiliary transfonner 1A and 480V circuit breaker (1AP07E1). This transformer supplies 480V AC power to the 480 V 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 reasonable range. The licensee is undecided as too the type of fix that is going to be made in this area. They have the alternative of handling the problem in a procedural manner or in making hardware and system changes to effect a fix. This is considered an Open Item (461/86028-07)

pending review of licensee's actions regarding nodifications required to maintain the operability of the diesel generator room 1A ventilating fa , (c) Coninon Enclosure Concern The common enclosure concern occurs when non safety-related cables are run from an enclosure for one reduendant rain to another and a fire can therby endanger both redundant train The cables installed at Clinton are separated by division, function and voltage class. All circuits are protected by coordinated circuit breakers and cables do not cross between divisional trays. The common enclosure concern was found to be satisfactorily addresse . _ _ .

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e . Fire Brigade .

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Section III.H of Appendix R requires a site fire brigade of at least five members on each shift, trained, and equipped for fire fighting shall be established to ensure adequate manual capability for all areas of the plant containing structures systems, or components important to safety. Other requirements of this section indicate

that the shift supervisor shall not be a member of the fire brigade; the brigade leader shall ybe competent to assess the potential safety consequences of a fire an8 advise control room personnel; demonstrating such competence by the' brigade leader may be evidenced by possession of an operator's license; the minimum equipment provided for the brigade shall consist of personal protective equipment; self-contained breathing apparatus using full-face positive pressure masks approved by the National Institute for Occupational Safety and Health (NIOSH)

shail be provided for the fire brigade, damage control, and control room personnel; at least ten masks shall be available for fire brigade personnel; and an onsite six hour supply of reserve air shall be provide During this inspection, the inspectors verified that the licensee has implemented fire brigade response to fire alarms and/or report of fire by five (5) members of the operation staff identified in Step 8.3.1 of the CPS Procedure No. 1001.06 and proposed to be included in Section 6.2.2.e of technical specifications (Inspection Concern No. US). The fire brigade consists of the Assistant Shift Supervisor (Senior Reactor Operator) as the fire brigade leader, two equipment and/or auxiliary type operators, one member from radwaste and one from radiation protection. The inspector found the fire brigade protective clothing (turnout coat, gloves, fire helmets, Md boots) and self-contained breathing apparatus (SCBA) to meet NRC requirements. Further, the inspector observed approximately 12 SLBA located at the fire brigade stations and an adequate onsite six hour supply of reserve air capability composed of a cascade system and approved breathing air compressor which also met NRC requirements.

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Within those areas inspected of Section III.H of Appendix R, the inspector found those areas to be satisfactor , Fire Brigade Training Section III.I of Appendix R requires that fire brigade training program to ensure that the capability to fight potential fires is established and maintained. According to Section III.I, this pi ~

shall consist of an initial classroom instruction program followed by periodic classroom instruction, fire fighting practice, and fire drill With respect to initial classroom instruction program, subsequent A. periodic classroom instruction (Inspection Concern No. 08), and fire V?' fighting practice, the inspector has on previous inspection visits participated in certain fire protection classroom instruction which is also provided to fire brigade members. At the time of the inspectors' visits, fire watch personnel were present. Also the

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inspector has reviewed and commented on fire protection lesson plans and activities at previous inspection visit During this inspection visit, the Regional based inspectors requested the licensee to conduct an unannounced fire drill of the shift4 operations personne As committed to by the licensee,Section III.I states that fire brigade drills shall be performed in the plant so that the fire brigade can practice as a team; unannounced drills shall not be '

scheduled for periods of less than four weeks; and the drills shall be preplanned to establish the training objectives of the drill, and shall be critiqued by members of the management staff to determine how well the training objectives of the drill have been met.

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The inspector chose one of the licensee's preplanned fire drill scenario's regarding a RHR A Pump fire. The drill postulated overheating of the pump and a subsequent oil fire co.ntained in the pump casing. The inspector reviewed both the fire drill scenario and pre-fire plan for the RHR A Pump Room tinding these documents and methodology to meet NRC guidelines and ' requirements. This fire drill was an unannounced drill which was conducted on May 1,1986, at approximately 1800 hour0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> The inspector observed four members of the fire brigade assemble at one of the brigade stations, fire brigade members conformance with established plant fire fighting procedures including an assessmer.t by the inspector of the fire brigade leaders direction of the fire fighting effort; actual brigade use of SCBA protective clothing, radiation monitor, portable radio communication equipment, and simulated use of the fire hose station equipment, and portable fire extinguishers in the area of the postulated fire. Overall inspector assessment of the drill, based on inspector observations and post-drill critique discussions, concluded the fire drill was performed satisfactoril Although, an inspector did provide four comments related to his observations during the post-drill critique and exit interview of May 2, 1986, as follows:

(1) overall fire brigade response time from receipt of the fire alarm by the fire brigade to arrival at the fire area could be improved; (2) certain portable radio conmunications were garbled and not understandable, also needing improvement; (3) a size-up of the specific area involved in the fire by the brigade leader was not performed and would improve the overall understanding of the nuclear safety significance and fire

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severity of the particular event along with improved direction to the fire brigade team and communication with the Shift Supervisor.

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(4) excessive time was spent by one brigade member in donning his self-contained breathing apparatus forcing this individual not to be available to actively participate for a portion of the dril Within those areas inspected of Section III.I of Appendix R, the inspector found those areas to be satisfactor J. Em_ergency Lighting Section III.J of Appendix R requires emergency lighting units with at least eight hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes theret At the request of the inspector, the licensee conducted an eight hour discharge test on emergency lights with only battery Packs operating to provide lighting located at Plant Coordinates 125-128 + AA; 130 + AA; 124 + AA; 129 + Y; and 124 + V. After an eight hour discharge test there was sufficient lighting for the operator to perform their dutie The inspectors will review on a future inspection the signed-off copy of the Preoperational Test Procedure (PTP-LL-01) which is tentatively expected to be completed by June 1, 1986. In addition, the licensee was requested to contact the manufacture regarding extending the battery life and verifying that the battery will perform as intended by performing an eight hour discharge tes This is considered an Open Item (461/86028-08) pending review of the licensee's action k. Administrative ControlsSection III.K of Appendix R requires administrative controls shall be established to minimize fire hazards in areas containing structures, systems, and components importe.nt to safet During this inspection, an inspector reviewed eight licensee administrative control related procedures identified in Paragraph of this report and found those procedures to be acceptably writte However, the inspector concluded that the licensee's entire fire protection program including administrative controls had not been fully implemented. The inspectors' determination is based on the following observations:

(1) During a plant tour the inspectors accompanied by licensee staff observed grinding work in-process on the 707' elevation of the Auxiliary Building. According to the workman in the area, no fire watch patrol was stationed in the area as required by Step 8.7.2 of CPS Procedure No. 1893.02; (2) Due to the continuing construction activities, maintaining of plant operations housekeeping requirements was generally lacking as required by Step 8.2.1.2 of CPS Procedure No. 1019.01, although the inspector did observe improvement in specific areas from previous inspection , visit .

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i (3) Inspector discussions with offsite fire department personnel during the inspection visit identified a concern related to the maintenance of the fire brigade SCBA mentioned as an (empty cylinder found during fire drill exercise with the offsite fire departments) as required by CPS Procedure No. 7002.0 Consequently, inspector verification of the fire protection program administrative controls implementation could not be completed. This item is considered an open item (461/86028-09) pending further inspector review of the fire protection program administrative controls during a future inspectio . Alternative and Dedicated Shutdown Capabili_ty Section III.L of Appendix R requires alternative or dedicated shutdown capability provided for a specific fire area shall be able to (1) achieve and maintain subcritical reactivity conditions in the reactor; (2) maintain reactor coolant inventory; (3) achieve and maintain hot standby conditions for a PWR (hot shutdown) for a BWR);

(4) achieve cold shutdown conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; and (5) maintain cold shutdown conditions thereafter. During the postfire shutdown, the reactor coolant system process variables shall be maintained within those predicted for a loss of normal a.c. power, and the fission product boundary integrity shall not be affected; i.e.,

there shall be not fuel clad damage, rupture of any primary coolant boundary, of rupture of the containment boundar As part of the inspectors review of Section III.G,Section II requirements are also reviewed concurrently, therefore, the inspectors detailed review of Section III.L can be found in Paragraph 4.g of this inspection repor m. Fire Barrier Cable Penetration _ S_eal Qualification Section III.M of Appendix R requires that the design of penetration seal utilize only noncombustible materials and shall be qualified by tests that are comparable to tests used to rate fire barriers. The acceptance criteria for the test shall includes that:

(1) The cable fire barrier penetration seal has withstood the fire endurance test without passage of flame or ignition of cables on the unexposed side for a period of time equivalent to the fire resistance rating required of the barrier; (2) The temperature levels recorded for the unexposed side are analyzed and demonstrate that the maximum temperature is sufficiently below the cable insulation ignition temperature- ,

and (3) The fire barrier penetration seal remains intact and does not allow prbjection of water beyond the unexposed surface during

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During this inspection, one of the Region III inspectors' reviewed two fire test reports regarding wrapped conduit configurations having either a one hour or three hour fire resistance rating that has been installed at the CPS. The two test reports No. 84-12-294, dated December 1984, and No. 85-4-377, dated April 1985 were both conducted at Industrial Testing Laboratories, Inc., located in St. Louis, Missour The three hour fire endurance test was conducted on two conduit sections mounted immediately adjacent to a concrete wall and protected with the Thermo-lag 330 Fire Barrier System while the one hour fire endurance test was ccnducted on a four inch diameter of aluminum conduit test assembly with a condulet, an air drop cable installed in a three quarter inch fluid type flex conduit and a P1000 unistru protected with the Thermo-lag 330 Fire Barrier System. The inspector compared the three acceptance criteria identified in Section III.M to the test results shown in the above mentioned test reports. This l review concluded that the tests satisfactorily met the criteria identified in Section III.M and are therefore, acceptable. The

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inspector review did not specifically include a field verification of the installed tested configurations mentioned above, although throughout the inspectors' tours of the plant areas, where fire wrap was installed, the inspector did visually inspect installation adequacy to the Installers (Bisco) Installation Instructions No. SP-FBI-01, Revision 2, dated January 22, 1986. Previous inspector review of fire test reports regarding penetration fire seal configurations are discussed in Paragraph 2.h of this inspection repor Further, in SSER No. 3 dated May 1984, NRR indicated their review of licensee letters dated February 3, March 25, and April 4,1983,

,. included manufacturer's verification to substantiate the fire rating of both fire barriers arid penetration seals in accordance with ASTM E-119 for three hours and determined the test results met NRC guideline Within those areas inspected of Section'III.M of Appendix R, the inspector found those areas to be satisfactor However, the inspectors did observe numerous penetration openings in fire barriers in safety-related areas where work was completed to seal penetration openings but were reopened to perform additional plant modifications (i.e., pulling of cables, etc.). Similar observations were made for once sprayed-on structural steel fire resistive material. These items are considered an open item (461/86028-10) pending a final walkthrough of safety-related areas demonstrating work completion or adequate compensatory measures are implemented in any necessary areas as required by CPS No. 9601.01,

" Fire Rated Assemblies and Penetration Sealing Devices" which references (Step 2.1.2) CPS No.1893.01, " Fire Protection Impairment Reporting."

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n. Fire DoorsSection III.N of Appendix R requires fire doors to be self-closing or provided with closing mechanisms and shall be inspected semiannually to verify that automatic hold-open, release, and closing mechanisms and latches are operabl .

The licensee comitments in " Questions and Responses for Chapter 9,"

Question 410.7(9.5.1) of the FSAR, Amendment 37, dated March 1986, as related to Section III.N indicates that all fire doors, and the door to the records storage facility are self-closing. Further indicating that fire door inspection procedures are in compliance with Appendix R requirements. The licensee provided the inspector a copy of three CPS Procedures No. 9601.04 (draf t), No. 9601.05 (draft),

and No. 9601.6, Revision 20, dated April 25, 1986, all relating to fire door and related hardware inspection. The inspector review of these three procedures determined that when approved and implemented, the licensee will meet Section III.N of Appendix R. However, during this inspection, while on plant tours of safety-related areas the inspector observed designated fire doors being held in the open position by " automatic hold open devices" (design feature of the hardware), portable fire extinguishers, pneumatic hose assemblies, and other devices which prevented the fire doors from being maintained in the closed positio Further, Section 4.0.0.1.j of the FPER also indicates that doors to vital areas are to be closed and locked in accordance with the station security requirement The licensee agreed to remove the fusible links from the " automatic hold open devices" located on the door closers of the designated fire doors (Inspection Concern No. U6), keeping all other designated fire doors closed as committed to and to finalize approval (two procedures) and implementation of the three CPS procedures identified above. This item is considered an open item (461/8E028-11) pending completion of the above identified actions, o. Oil _Co_1_le_ction Sys_

s tem _For Reactor _ Coo _lant Pumps

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Section III.0 of Appendix R states, "The reactor coolant pump shall .

be equipped with an oil collection system if the containment is not inerted during normal operation. The oil collection system shall be so designed, engineered and installed that failure will not lead to fire during normal or design basis accident conditions and that there is reasonable assurance that the system will withstand the safe shut-down earthquake."

The reactor coolant pumps at Clinton Power Station are not located in an inerted containment and therefore should be equipped with an oil collection system per Section III.0 of Appendix R. The licensee's position is that Section 9.5.4.3 of the original SER, dated February,1982, entitled, " Containment Reactor Building" states that, "The reactor building is separated from adjacent tuildings by three-hour fire rated barriers. Containment and reactor building

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fire protection features include hose stations, ionization smoke detectors, and fire extinguisher A lube oil fire hazard was initially thought to be associated with the reactor coolant pumps located in primary containment. The pumps and motors are lubricated by oil. The lube oil systems are contained within the tretal motor housing with no external parts. Hence, an engineered oil leak collection system or additional fire protection for the pumps is not require ~

On the basis of its review, the staff concluded that the fire protection for the containment and reactor building meets the guidelines of Appendix A, Section F.1, of BTP ASB 9.5-1 and is, therefore, acceptable."

The inspector indicated to the licensee that the review process for BTP ASB 9.5-1 did not address the concern outlined in Appendix R,

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Section 111.0. The licensee indicated in Section 3.2, entitled,

" Containment Building of the Fire Protection Safe Shutdown Analysis" at the CPS states:

, "The only fixed fire hazard in this fire area is the lubricating oil contained within the two reactor recirculation pump motors. Each motor utilizes self-lubricated bearings with lubricating oil cooled by cooling coils installed within the reservoirs; therefore, a pressur-ized oil system is not utilized. This design minimizes piping connections to the oil reservoir. The heavy construction and the nonpressurized design of this lubricating system minimizes suscepti-bility to leakage. Also, if leakage were to occur, an ignition enhancing spray would be likel Therefore, an exposure fire due to ignition of the recirculation pump lubricating oil is not credible, >

and additional fire protection measures for the recirculation pumps are not required."

As discussed with the licensee staff after the June 6, 1986, exit ')

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meeting, the licensee agreed to provide the inspector with the following infonnation:

(1) Type of Lubricating 011 used in the lubricating system including

• items such as flash point, fire point, auto ignition temperature, boiling point, and other pertinent limits of flannability as may be found in the lubricating oils specification sheet, (2) Amount of oil in each lubricating pump, (3) Information regarding the Reactor Coolant Pumps such as:

Is the recirculating oil temperature monitored?

s If the temperature of the oil is monitored, what are the

. temperature limits of operation?

What actions are taken if oil exceeds those temperature limits? and

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(4) Analysis of the effects of fire, heat products of combustin, e radiation (heat), smoke resulting from a lubricating system leak and spill. In each of the two fire scenario's discuss the

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use of fire suppressants on the fire and their affects on safe shutdown equipment in the are In a telephone call on June 13, 1986 between NRR and Region III, NRR agreed to review previously submitted material from the licensee regarding the lack of an oil collection system and to document these findings in a future Safety Evaluation Repor This will be considered an Open Item (461/86028-12) pending Region III and NRR review of the licensee's analysi . Underoround fire Main In the CPS SER Section 4.0, entitled, " Compliance with BTP APCSB 9.5-1, Appendix A, Plants Under Construction and Operating Plants", it states:

"The underground yard firemain loop is designed and installed in compliance with applicable NFPA 24 requirements. NFPA code conformance is documented in the CPS NFPA Code Conformance Evaluation document. Unlined carbon steel pipe is provided in the underground yard loop. Possible tuberculation of <

pipe is accounted for in the hydraulic calculations by using a conservative C-factor of 75. The calculations demonstrate adequate fire protection water supply during the life of the plant." Dep,th of Frost The inspector selected several locations of the yard piping and requested the licensee to demonstrate that the underground fire main was located at least one foot below the depth of frost as required by NFPA-24. In the licensee's response to an Appendix R audit concern (Inspection Concern H2) dated April 29, 1986 which states, " Based on an S&L structural design criteria,0C-SD-01-CP, the maximum frost penetration for the Clinton site is 30 inche In NFPA 24 Section 8-1.1 states: "The depth of cover over water pipes shall be determined by the maximum depth of frost penetration in the locality where the pipe is laid. The top of the pipe shall be buried not less than one foot below the frost line for the locality. In Figure A-8-1.1 of NFPA-24 the frost line for Clinton appears to be 4.5 feet. In a book titled, " Foundation Engineering", Figure 6-1 on Page 531 indicates the maximum depths of frost to be 4.16 feet (50 inches). The licensee's stated depth of frost of 30 inches is not consistent with NFPA or the Foundation Engineering reference manua The licensee is requested to verify the maximum depth of frost and if necessary take corrective actions if needed. This is considered an Open Item (461/86028-13) pending review and acceptance by Region II _

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O Anc_ horage_ of Fire Main The Clinton FPER Section 3.1.2.6, " Fire Protection Water Supply System" dated February 1986 states, " Encircling the Clinton Power Station power block is an underground fire water main loop. The underground loop is constructed of 14-inch diameter, welded carbon steel pipe, and UL listed posted indicator valves for sectional isolation of the loo The underground loop is connected to each diesel-driven fire pump in the circulating water screen house by a 14-inch diameter pipe line."

l In the FPER Section 4.0 Compliance with BTP APCSB 9.5-1, Appendix A, Plants Under Construction and Operating Plants, Part E.2.a entitled,

"BTP APCSB-9.5-1 Appendix A Plants Under Construction and Operating Plants" states, "The underground yard fire main loop is designed and installed in compliance with appropriate NFPA 24 requirements."

The inspector was provided with pipe, fire hydrant, and post indicator

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valve specification data. The inspector was also provided with

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drawing No. M0-2-103.09 Revision G entitled, " Outdoor Piping Sections 4 and Details." Based on the information provided to the inspector,

the anchorage of the fire main appears to be in conformance with NFPA 24.

i Hydrostatic Test The licensee provided the inspector with safety-related Pressure

! Testing Traveler No. FP-028-H which provides information regarding i the hydrostatic test that was concucted on the underground fire train. Attachment "C" indicated that total allowable leakage for gaskets, valves and hydrants for two hour hydrostatic test was 136.93 gallons. In the attached Hydro Instruction No. HT-FP-028

Revision 0, the amount of leakage recorded 70 gallons (conducted on November 1, 1981).

The inspector noted that the fire pump shut off is 170 psi which

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indicates that the hydrostatic test should have been conducted at 220 psi. The licnesee provided the inspector with Sargent and Lundy

< Hydrotest Leakage in Buried Piping of Fire Protection Sytsem Project No. 4536-00 which reflected leakage at 250 psi. The calculated leakage was 78.26 gallons. The licensee indicated that the NFPA code compliance report will be revised to reflect this deviatio . Fire Protection Pre-Ope _ rat _ional Tests

The inspector examined the licensee's fire protection pre-operational test procedures to determine plant fire protection system readiness in

. meeting licensee conmitment Section 4.0.A.7 of the FPER indicates that the CPS fire protection program as approved by the NRC for the entire reactor unit will be implemented and fully operational prior to fuel loa . _ . - .

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The licensee's major fire protection pre-operational tests consist of three' CPS Procedures No. PTP-FP/CO-01, No. PTP-FP/CO-02, and No. PTP-FP/C0-0 These procedures include a test of the diesel-driven fire pumps, sprinkler systems, fire protection valves, PGCC Control Room Halon System, and fire detection system At the time of 'this inspection, the only test procedure completed was No. PTP-FP/C0-02 regarding the PGCC Control Room Halon System. The inspector review of the three test procedures determined that these procedures have been written, reviewed, and approved for origination of the performance of the test as required by NRC inspection procedures. The inspector review of these three procedures test results will be performed at a future inspectio . Open Items

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Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, or which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 2, 4, and 5 of the repor . Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

at the conclusion of the inspection on May 2, and June 6,1986, and sunmarized the scope and findings of the inspection. The lead inspector also discussed the likely informational content of the inspection report with regard to documents reviewed by the inspectors during the inspectio The licensee did not identify any of the documents as proprietary.

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