IR 05000461/1989028

Insp Rept 50-461/89-28 on 890911-15.Violations Noted.Major Areas Inspected:Fire Protection Program,Including Review of Fire Protection Organization,Administrative Controls & Fire Protection Sys Surveillance Test Program

ML20248H078
Person / Time
Site:	Clinton
Issue date:	10/04/1989
From:	Gardner R, Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20248H019	List: IR 05000461/1989028 ML20248H015 ML20248H057
References
50-461-89-28, NUDOCS 8910110167
Download: ML20248H078 (10)

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'U.S.~ NUCLEAR REGULATORY COMMISSION-

REGION III

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Report No.~ 50-461/89028(DRS)

Docket No. 50-4611 ,

License No. NPF-62

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9 Licensee: Illinois-Power Company 500 South 27th Street Decatur,'IL: 62525 Facility Name: _Clinton Power Station Inspection At: Clinton Site, Clinton, IL 61727 Inspection Conducted: September 11-15, 1989 R.ii. 36 it,b -

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Inspector: Joseph M. Ulie W 81 Date Approved By:

_h0A bb Ronald N. Gardner, Chief IC- $/

Plant Systems Section Date Inspection Summary Inspection on September 11-15, 1989 (Report No. 50-461/89028(DRS)) .

Areas Inspected: Routine, unannounced inspection.to review the implementation

'of the licensee's-fire protection program including a review of the fire

- protection organization; administrative controls; fire protection system surveillance. test program; facility tour observations; cable separation adequacy; evaluations of selective information notices and a quality assurance review relative to fire protection. The inspector utilize modules 30703 and 6470 Results: Of the areas inspected, one violation was identified (failure to maintain records to verify that the fire detector sensitivity checks were

., being performed - Paragraph 4.a). One open item was also identified in the report. The open item regards two low pressure carbon dioxide storage tank

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level gauges which were not included in the preventive maintenance progra j Strengths observed in the licensee's program consisted of:

• Staffing of the fire protection organization in the operations and training areas was considered goo * Implementation of the fire protection administrative controls program, including control of combustibles and plant cleanliness, was determined to be goo PDR ADOCK 05000461 Q PDC

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DETAILS Persons Contacted Illinois Power Company

• K. A. Baker, Supervisor, Inspection and Enforcement Interface W. Bogasz, Electrician D."Brendley, Instructor, General

• R. E. Campbell, Manager, Quality Assurance

• J. C. Cook, Plant Manager R. Fernald,. Senior Instructor, General S. Fischer, Electrician

• R. D. Freeman, Manager, Nuclear Station _ Engineering Department

• S. P. Hall,. Director, Nuclear Program Assessment

• D. L. Holtzscher, Acting Manager, Licensing and Safety

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• J. A. Miller, Manager, Station Outage and Maintenance

• R. W.'Morgenstern, Director, Plant Technical

• J. F. Palchak, Manager, Nuclear' Planning and Scheduling

• J. S. Perry, Assistant Vice-President

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

• F. A. Spangenberg, Manager, Licensing and Safety M. Stookey, Fire Protection Engineer

• J. D. Weaver, Director, Licensing

• R. E. Wyatt, Manager, Nuclear Training Department U.-S. Nuclear Regulatory Commission (U.S. NRC)

• P. G. Brochman, Senior Resident Inspector

• S. P. Ray, Resident Inspector The inspector also contacted other licensee personnel during the course of the inspectio * Denotes those persons present during the exit _ interview on September 15, 198 . Fire Protection Organizatic; The inspector interviewed c.., licensee individual conducting an hourly fire watch patro The inspector determined, after discussions with this individual, that she was adequately trained. This determination was based on the fact that the fire watch individual was able to describe the required emergency actions to be taken upon spotting a fire conditio In addition, the inspector attended a respiratory protection training session while portions of the self-contained breathing apparatus classroom and practical training were occurring. The instructor's performance was evaluated during this session. Based on the students' abilities to properly implement the instructor's instructions, related student

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discussions, and inspector observations, it was determined.that the instructor was knowledgeable of the subject matter and was presenting the information in a thorough and understandable manne At the inspector's request, the licensee conducted an unannounced fire brigade dr_ill. The inspector requested a fire scenario which would include a demonstration of the fire brigade's firefighting techniques, including fire hose handling,.and which would also demonstrate the adequacy of' communication interface between the fire brigade and radiation protection personnel during fire emergency condition The fire drill selected by the licensee postulated a fire'in'the contaminated trash staging area (131-132.4/E-F) of the radwaste building at elevation 702'. The inspector reviewed both the fire drill scenario and pre-fire plan including a walkthrough of the " fire" area prior to the dril In preparing to witness the fire drill, the inspector reviewed appropriate portions of Clinton Power Station Procedure No. 1893.04, Firefighting, Revision No. 5, dated February 18, 1988, including the radwaste building basement (Elevation'702'-720') north pre-fire plan. The inspector selected the following criteria to be used in evaluating fire brigade and support personnel actions: (1) fire brigade conformance to established plant firefighting procedures; (2) assessment of the fire brigade leader's direction of the fire fighting efforts; (3) actual donning and simulated use of the self-contained breathing apparatus;.(4) actual. donning of protective clothing; (5) simulated use of~two 1\" fire hose stations; (6) use of portable radio communication equipment; (7) brigade timeliness in response and numbus of personnel responding-with proper firefighting equipment; and (8) brigade leader interaction with the radiation protection personnel and other support personnel (e.g. , security on scene).

The fire drill was an unannounced drill which was initiated on September'14, 1989, at approximately 1630 hour0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20215e-4 months <br /> The inspector was-initially stationed in the control room to observe the actions taken by the reactor operator (RO) upon receipt of the fire alarm (a roving fire watch used the gai-tronics system to notify the control room of the postulated fire condition).

The-inspector observed five members of the fire brigade assemble at one of the three fire brigade stations and followed the actions taken by

.those fire brigade members until extinguishment of the postulated fire was complete. As a result of.this review, the inspector concluded that the fire drill was conducted in a satisfactory manne The following observations were discussed during the post-fire drill critique and exit interview: Positive Observations

• Good fire brigade leadership and direction was exhibited during the dril ___

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• adiation Protection personnel coordinated with the' fire brigade leader and"took an active role during the fire drill activitie I

'e Appropriate firefighting techniques were utilized duiing 1 the' fire drill activitie * _All fire brigade, members donned the protective clothing

. including actual use of the self-contained breathing apparatu Areas Needing Improvement

• A more timely fire brigade-response could have.been exhibited from the fire brigade station to the fire scen * During one phase of the fire drill, an isolated incident regarding difficulty.in the use'of portable radio communications was note . -Administrative Controls The inspector examined, in part, the' licensee's fire protection administrative control procedures and implementation of these procedures while performing plant tours on September 12, 13.and 14, 1989. The

. procedures examined included: (1).Clinton Power Station Procedure No. 1893.02, Control of Ignition Sources, Revision No. 4, dated September 6, 1988; (2) Clinton Power Station Procedure No. 1893.03, Control of Flammable and Combustible Liquids and Combustible Materials, Revision No.'5, dated November 22, 1988;-(3) Clinton Power Station Procedure No.'1019.01, Housekeeping, Revision No. 7, dated June 15, 1989; and (4) Plant Manager Standing Order (PMS0) No. PMS0-028, Housekeeping, Revision 3, dated May 22, 1989. A review of these procedures determined that they were satisfactorily written to afford protection to vital plant equipmen On September 12, 1989, an in progress set-up of a welding operation was observed. The responsible department supervisor was at the work site ensuring that the hot work area was firesafe through completion of an

"Open Flame Permit." .According to the licensee, no other hot work

. activities were scheduled during the inspector's visi With regard to control of combustibles and plant cleanliness, a walkthrough of plant vital areas including the fuel building, auxiliary building, I control building, diesel generator building, containment (excluding drywell l area), turbine building, and the screenhouse provided indication that

! these areas were being satisfactorily maintained. The inspector did l not observe any evidence of smoking in any of the marked non-smoking areas; no transient combustibles were observed in critical locations during any of the plant tours; and adequate vital area cleanliness was evident. In addition, compressed gas cylinders required for plant operation were adequately secured in position away from likely locations

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I which could result in an exposure hazard problem. No other bulk storage '

of flammable liquids was observed by the inspector in vital plant areas and according to the licensee, no hydrogen lines are routed through vital plant areas. The inspector confirmed the hydrogen routing information with the resident inspector-. Fire Protection System Surveillance Test Program The inspector reviewed, in part, the licensee's fire protection features surveillance test program as required by Technical Specifications (TS). l This review consisted of an examination of completed surveillance i packages, a selected sampling of specific surveillance test areas and discussions with licensee staff. Since the licensee indicated that no other surveillance were scheduled, the only surveillance test which could be witnessed regarded the fire detection system functional tes The inspector's review included the following: The semi-annual channel functional surveillance check of the fire detection system was witnessed by the inspector on September 13, 1989. During discussions with the electrical maintenance personnel performing the surveillance, the inspector determined that the workmen were unaware of a step in the procedure which required verification of the sensitivity of each ionization fire detecto During subsequent discussions with the licensee's fire protection personnel, the inspector learned that on one previous occasion following the electrical maintenance group's completion of this surveillance, the licensee had determined that the fire detector's sensitivity had not been verified to be within the specified ban Based on the above, the inspector reviewed Fire Detector Channel Functional Test Procedure No. 9337.81. Step 8.2.1 of this procedure specified a check of the sensitivity of each fire detector by obtaining a printout of detector voltages and verifying that the detector voltages are in the band specified in Appendix 0 of the procedure. However, the procedure did not require that a re ard verifying that the detector voltages were in the specified band be developed and maintaine The licensee acknowledged the deficiency and immediately verified that the sensitivities of the detectors were in the specified band. The licensee also promptly initiated necessary procedure changes in accordance with Clinton Power Station Procedure No. 1005.07. These changes now require a specific signoff for completion of this activity and the attachment of actual recorded sensitivity voltages to the procedure. The failure of the licensee to maintain records which verify that adequato: detector sensitivity checks were performed is considered a violation (461/89028-01(DRS))

as described in the Notice of Violation. Based on the actions taken by the licensee in addressing this technical deficiency, no further licensee action is deemed necessary at this time.

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An additional concern raised during the fire detection review regarded l the length of time (four to seven months) that detector No. 61-03

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(Auxiliary Building, 781' elevation) had been out of servic _ - _ _ - _ _ - - - _ _ _ _ - - - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _

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Although sufficient numbers of zone detectcrs for this area were available to meet minimum NRC requirements, the inspector was concerned about the amount of time that the detector was inoperable.

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In response to this concern, the licensee *ndicated that the reason for the extended detector inoperability was due to the unusual manner of detector failure and the unavailability of replacement components (fire detector base). No spare fire detector bases were maintained by the instrumentation grou Following the inspection visit, the licensee re-installed the fire detector base and put the detector back in service. This was confirmed by the resident inspection staff, b. The inspector reviewed completed surveillance checks of the power generation control complex halon suppression systems which were performed in accordance with Clinton Power Station Procedure No. 9071.11. The inspector confirmed the the two previous surveillance checks had been satisfactorily completed within the allotted time perio c. The inspector reviewed completed surveillance checks of the fire hose station system which were performed in accordance with Clinton Power Station Procedure No. 9071.15. The inspector confirmed that  ;

the three previous surveillance checks had been satisfactorily 1 completed within the allotted time perio d. The inspector reviewed completed surveillance checks of three charcoal bed deluge suppression systems which were performed in accordance with Clinton Power Station Procedure No. 9071.12. The inspector confirmed that the three previous surveillance checks had been satisfactorily completed within the allotted time perio e. The inspector reviewed completed surveillance checks of the carbon dioxide suppression systems which were performed in accordance with Clinton Power Station Procedure No. 9071.08. The inspector confirmed that the six previous surveillance checks had been satisfactorily completed within the allotted time perio In addition, the inspector conducted a review of the calibration of the low pressure level gauges (differential pressure) for each unit's carbon dioxide storage tank. One unit's level gauge had recently been calibrated in August 1989, while the other tank had the level gauge replaced in April of 1987 due to a faulty gauge problem. However, according to the calibration and instrumentation scheduler, neither of these level gauges were included in the preventive maintenance program. The inspector informed the licensee that the omission of these gauges from the preventive maintenance program could result in the licensee's failure to perform periodic gauge calibrations at the frequency specified by the vendor. The licensee indicated that a review would be performed of the pertinent vendor manual (or the vendor would be contacted) so as to ascertain the vendor's recommended gauge calibration frequenc _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _

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a l This is considered an Open Item (461/89028-02(DRS)) pending the licensee's review to determine the vendor's recommended level gauge calibration frequenc . Facility Tour On September 12-14, 1989, the inspector examined plant fire protection features, including a selective sampling of the fire water system valve positioning, fire barrier penetration seals, fire doors, fire detection and alarm systems, automatic and manual fixed suppression systems, interior hose stations and portable fire extinguishers. Certain minor deficiencies in the fire barrier area were noted; however, the licensee had previously identified these deficiencies and were implementing compensatory measure In general, all fire protection features examined were being adequately maintained and were ready for us As part of the facility tour, the inspector confirmed that in the following four plant areas which had been granted deviations for lack of installed fire suppression systems, the Safety Evaluation Report's basis for granting these deviations was still valid: (1) auxiliary building, 737' elevation; (2) diesel generator building, 737' elevation; (3) diesel i generator building, 762' elevation; and (4) fuel building, 755' elevatio Each of these general plant locations were toured to verify: (1) that these locations contain early warning fire detection capability; (2) that for these locations the amount of combustibles is being maintained with a low in-situ loading; and (3) through review of cable tray drawings and physical in-plant review of marked trays that adequate separation between redundant systems exists. This review concluded that the licensee was maintaining the plant configuration as committed to in the safe shutdown analysi . Verification of Redundant Cable Separation To assure that the licensee maintained required separation of redundant post-fire safe shutdown cabling in accordance with the Updated Final Safety Analysis Report (USAR), the inspector conducted a review to determine that two cable tray modifications were completed as intende Sections 3.3.1.3.4 (Fire Zone CB-lg) and 3.3.1.3.5 (Fire Zone CB-li)

of Appendix F to the USAR specifies that safe shutdown cables 1NB65C, 1RH79C, 1RP76C, LAP 28Q, LAP 34X, and 1AP28B will be rerouted. The licensee indicated that the above cables were disconnected and that affected circuits were re-connected to other cables so as to provide adequate cable separation. During a plant tour, the inspector, accompanied by licensee personnel, verified that as identified by the Nuclear Safety and Engineering Department the re-connected cables were re-routed or fire wrapped as specifie . Review of Selected Information Notices i The inspector requested licensee evaluations of Information Notice (IEN) 88-04 and Supplement 1, Inadequate Qualification and Documentation

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of Fire Barrier Penetration Seals, responses dated March 21, 1988 and October 18,,1988; IEN No. 88-05, Fire in Annunciator Control Cabinets, i

response dated July 1, 1988; IEN No. 88-56, Potential Problems with l Silicone Foam Fire Barrier Penetration Seals, response dated December 27, 1988; and IEN No. 86-24, Respirator Users Notice: Increased Inspection Frequency for Certain Self-Centained Breathing Apparatus Air Cylinders, response dated February 16, 198 IEN 88-04 focused on whather the installed configuration of fire barrier l penetration seal designs were qualified by adequate testing and i documentation. The licensee provided documentation demonstrating that i Engineering Procedure Instruction No. DE-21, Penetration Seal Design, Revision 0, dated October 31, 1988, which had been issued to provide instructions and assign responsibility for determining penetration seal design details was adequate to satisfy _the. issues addressed in IEN 88-0 Additionally, Maintenance Procedure No.~8920.01, Revision 1, has been i implemented to assure that maintenance, rework, installation and inspection of penetration seals is performed in accordance with the seal vendor's procedures and methods. The licensee also provided two' internal memos describing planned or completed reviews of the fire barrier penetration seal are The inspector's review of the licensee's response to IEN 88-04 determined that the licensee has sufficient documentation available to substantiate new and modified fire barrier penetration seal design configuration. The inspector did not perform a comparison o~f plant specific seal design details to the as-installed configuration During plant tours on September 12-14, 1989, the inspector did confirm that no i unsealed openings existed in designated fire barriers that weren't already identified and for which compensatory measures were being implemente l With regard to Supplement 1 to IEN 88-04, the notice described a potential for two misapplication of silicone foam material used in penetration fire ,

barrier opening The licensee's review determined that silicone foam  !

material at Clinton is not used for one of the applications addressed in  ;

the notice. For the other application, seven penetrations were found that  ;

could be exposed to temperatures discussed in the notice. Consequently, the licensee initiated monthly surveillance of the seven penetration i The licensee found no seal degradation during the surveillance monitoring period and are now surveilling these penetrations using the previous schedule. Based on the above, the inspector is satisfied with the licensee's response to this notic IEN 88-05 addresses fires initiating in annunciator panels manufactured by Electro Devices, Inc. According to the licensee's evaluation, the  ;

Clinton Plant annunciator panels were manufactured by RONA A review J by the licensee of the plant approved supplier's list and vendor codes indicated that the licensee had not purchased any items from Electro Devices, In In addition, the licensee reiterated that, at Clinton, the j l

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annunciator panels.have product-of-combustion detectors installed which would provide early notification of a fire condition in an annunciator panel.along with manually operated halon suppression systems. The IEN also made mention that a general lack of specific emergency. procedures to address a complete loss of the annunciator system at the IEN. identified sites was noted. According to the licensee, the emergency plan implementation procedure (EC-02) does detail how to classify a situation where control room annunciation is lost; however, there is no specific procedure detailing the action that will be taken in response to such a loss. The licensee stated that the plant has experienced loss of 1 annunciation (due to loss of power at the annunciator panels) during testing prior to commercial operation. During these events, the operators continued to control the plant by utilizing increased monitoring of the main control room instrumentation. Based on the installed fire detection system and other licensee information, the inspector is satisfied with-the' licensee's response to this notic IEN 88-56 identified silicone foam fire seals having voids, shrinkage, lack of fill, etc., which were not readily apparent because the seals were masked by fire-resistant boards. The licensee's review determined that the seal details'used at the IEN subject plant were different from

.those details used by the seal installer at Clinton. For example, the seal installer at'the subject plant left damming material in place on both sides of numerous foam seals while the licensee's seal installer only allowed for damming material on one side of a penetration. Also, the seal deficiencies identified at the subject plant were more common in the larger penetrations having " blind" pours. At Clinton, accordin to the evaluation, there are very few penetrations with over 2 square feet of exposed surface which have foam installed. Of most importance, the licensee's seal installer performed a 100% quality control inspection of all penetration seal damming and installations. Based on the above, the inspector concluded that a sufficient level of quality control was conducted at Clinton to a sure that the subject deficiencies would not occu IEN 86-24 regarded self-contained breathing apparatus cylinders developing neck cracks that could create a personnel safety hazard. The licensee determined that the IEN subject cylinders are used at Clinton. Therefore, '

to comply with the applicable recommendations, the licensee has increased the cylinder inspection frequency of the self-contained breathing apparatus cylinders to a weekly schedule. No defective cylinders have been identified to date. The licensee provided the inspector with a selective sample of completed weekly cylinder checklists. No discrepancies were identified by the inspector in reviewing the checklists. Based on the licensee's increased frequency of cylinder inspection, the inspector is satisfied with the licensee's response to this notic . Quality Assurance The inspector requested the licensee to provide the last annual audit performed to satisfy TS Section 6.5.2.8.i. The licensee provided Audit Report No. Q38-88-46, dated October 26, 198 A review, in part, of this

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audit report indicated that the licensee performed the scheduled audits as required and verified a selected sample of fire protection program and implementation aspects of the in place program. The inspector concluded that the licensee was satisfying the fire protection TS audit requirement . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some actlon on the part of the NRC or licensee or both. An open item disclosed during the inspection is discussed in Paragraph . Exit Interview The inspector held an exit interview with licensee representatives (denoted in Paragraph 1) at the conclusi'on of the inspection on September 15, 1989, and summarized the scope and findings of the inspection. The inspector also discussed the likely informational -

content of the inspection report with regard to documents retiewed by the inspector during the inspection. The licensee did not identify any of the documents as proprietar I

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