ML18283B788

List of Various Inspection Reports in 1975

ML18283B788
Person / Time
Site:	Browns Ferry
Issue date:	10/10/2018
From:	Advisory Committee on the Medical Uses of Isotopes
To:
References
Download: ML18283B788 (783)

Text

~~>P//C74n ~7. . ~ +~~I 4/ Pf

/

~M/~.- PRON TO TYPE ZmZCT lr~--os

.C: 4//< /15 ~@4J~~=@~

W)p. <O-

~ 5/15/75

~&/6/75 Region II V

II Gas 6 Electric 4tt t r >

Inspection Rpt. 050-le/7Af3 Co.

Inspection Rpt . 850-312/75-04 Pacific Sacramento Municipal Utility District It It Inspection Rpt. 850-206/75-03 Southern Califovnia Edison Company I

~/9/75 Region IV Inspection Rpt. $ 50-267/75-04 Public Sevvice Co. of Colorado 8/75 II II Inspection Rpt. 850-298/75-07 - Nebraska Public Powev District P4X8l75 Region III Inspection Rpt. $ 050-315/75-07 - American Electvic Powev Sew. Covp.

'~/27/75 II It Inspection Rpx. 8050-010/75-09 8050-237/75-14 8050-249/75-12 Commonwealth Edison Co., 8 Dvesden Nuclear Power Station II 'II Inspection Rpt. 8050-155/75-06 Consumevs 919/75 Power Co. 6 Big Rock Point Nuclear Plant 5/27/75 II II Inspection Rpt. 8050-331/75-05 Iowa Electvic Light 8 Powev Co. E Duane Arnold Energy Centev 5/16/75 II It Inspection Rpt. 8050-255/75-09 Consumevs Power Co., 8 Palisades Nuclear Generating Plant

/8/75 lt II Inspection Rpt. 8050-263/75-08 Northern States Power Co., 8 Honticello Nuclear Generating Plant

~/21/75 II II Inspection Rpt. $ 050-305/75 Wisconsin Public Serv. Covp. 6 Kewaunee Nucleav Powev Plant 5/28/75 II II Inspection Rpt. f050-254/75-09 Common-wealth Edison Co., 8 Quad-Cities Nucleav Powev Station

0 DATE 5/22/75 Region I IE Inspection Rpt. $ 50-03/75-, 02 Consolidated Edison of New York S 'ndian Point 1

+5/20/75 IE Inspection Rpt. $ 50-23.3/75-04 Connecticut Yankee Atomic Power Company

~/16/75 11 II IE Inspection Rpt. 850-317/75-11 Baltimore Gas 8 Electric Corqany

~/16/75 11 11 IE Inspection Rpt. 850-244/75-07 Rochestev Gas 6 Electric Covporation

~56/75 IE Inspection Rpt. 850-333/75-07 Niagara

. Mohawk Power Corporation v 5/14/75 tt It IE Inspection Rpt. 850-277/75-08 and 50-278/75-11 Philadelphia Electvic Company

~5/20/75 11 II IE Inspection Rpt. 850-219/75-13 Jersey Central Power and Light Co.

~5/19/75 II II IE Inspection Rpt. 850-220/75-06 Niagara Mohawk Powev Corpovation 5/13/75 It 11 'IE Inspection Rpt. 850-245/75-09 Northeast Nuclear Energy Company

~/22/75 tI II IE Inspection Rpt. $ 50-309/75-07 Maine Yankee Atomic Power Company

~22/75 11 II IE Inspection Rpt. $ 50-247/75-06 Consolidated Edison Company Indian Point 2 W/12/75 II II IE Inspection Rpt. 875-11 Boston Edison Company Pilgvim Nucleav Powev Station 85/19/75 tt tt IE Inspection Rpt 850-271/75-03 Vermont Yartkee Nucleav Power Corp.

J lg't/19/75 II II IE Inspection Rpt 850-29/75-05 , Yankee Atomic tI Electric Company Q/22/75 11 tt IE Inspection Rpt $ 50-289/75-10 Metropolitan Edison Company, Middletcxm, Pa., 3 Mile Islan'd 1

(

"4~ +'p DATE FROH TO P/7/75 Region III IE Inspection Rpt. 8050-295/75-04 and

$ 050-304/75-03 Commonwealth Edison Company 6 Zion Nucleav Pwv Station, Units 1 6 2 tt IE Inspection Rpt III050-282/75-06 and 2/75 11 8050-306/75-04 Novthevn States Powev Co~t y 6 Prairie Island Nucleav Generating Plant

'lt 11 IE Inspection Rpt N050-409/75-04 Dairyland Power Cooperative and v5/7/75'17/75 LaCrosse Boiling Water Reactov IE Inspection Rpt 8050-331/75-11 Iowa Electvic IA Light 6 Power Company W/25/75 II tt IE Inspection Rpt $ 50-321/75-6 Georgia Powe Co,

~8/75 IE Inspection Rpt if50-324/75-06 8 Light Carolina Power Company u <<'/13/75 Region Il IE Inspection Rpt.F50-269/75-6, 50-270/75-7 and 50-287/75-7 Duke Powe Company Oconee Units 1, 2 and 3 5/22/75 II IE Inspection Rpt $ 50-261/75-8 Carolina Powev 6 11 Light Co. H.B. Robinson 2 Il 'll IE Inspection Rpt $ 50-250/75-7 Flovida Powev

/21/75 8 Light Company Turkey Point 3 6 4 5/19/75 lt tl IE Inspection Rpt III50-280/75-7 and 50-281/75-6 Virginia Electvic S Power Co.

Suvvy Powev Station P

9/12/75 \I 11 IE Inspection Rpt 850-259/75-11 Tennessee Valley-Authovity, Browns Fevry

~

Unit 1

FROH

~/21/75, G.L. Hadsen T.E. Short A'. h4hwg N.C. Hoseley L~

R.E. Uhrig 4'/Z 2/gj

• u <. Howl~

J.H. Pilant P/29I75 1/2A 1$ g.,g, ~zen N.C. Hoseley C,,k.~

J.A. Jones u<<

g, ]t, ~i'd/zg g, jv. /4~~cl /6

~/19/75 G.L. Hadsen C.K. Hillen Ltv

~7/> 8)~> d-. ~>'ore. Ii/ 8, Lee, Jn L+r

~8/7)75 J.P. O'Reilly L.D. Mhite Ltr 4/20/75 G. Fiorelli L. Nachtev Ltv P/27/75 . J.G. Davis C.K. Hillen Ltr P'/29/75 , R.T. Cavlson G. Carl Andognini Ltr

/29/75 G. Piovelli B. Lee

+/2-5/75 Rancho Seco m~ spection Rpt.

850-312/75-08

~ 9/8/75 J.p. O'Reilly Leon D. White Ref ltr dtd 8/29/75 in Resp to ltv dtd 8/7/75 ncrt, L 'a4/-

U. S. NUCLEAR REGULATORY COi~fISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV IE Inspection Report No, 50-285/75-06. Docket No. 50-285 Licensee: Omaha Public Power District License No. DPR-40 1623 Harney Street Omaha, Nebraska 68102 Category B 2 Facility: Fort Calhoun Station, Unit 1 -.

Location: Vashington County, Nebraska Type of Licensee: CE, PWR, 1420?R(t)

Type of Inspection: Routine, Announced

~

Dates of Inspection: May 7-9, 1975 Dates of Previous Inspection: April 17, 1975 (Materials)

Principal Inspector:

,H. V. Dickerson, Rea ror Inspector Date Accompanying Personnel:

R. Smith, Reactor Inspector Date

\

Reviewed By: 2 @fan

'g. L. Madsen, Chief, Reactor Construction and Date Operations Branch

~ ~ ~

>~

.'.SUÃfARY OF FINDINGS

'Enforcement 'Action A. Items of Noncompliance

l. 'iolations Hone

2. Infractions Contrary to the requirement of Technical, Specification 2.0, Table 2-1, item 5, Limiting Condition for Operation, the SIRV Low 'Level Switches were found to have drifted upwards in excess of the TS limits.

This infraction was identified by the licensee. (DETAILS, paragraph 4.b) .

b. Contrary to the requirements of Technical Specification 2.3.(1)a,

'he. required minimum SIRE tank storage was less than the required 283,000 gallons.

This infraction was identified by the licensee. (DETAILS, paragraph 4.b)

3. Deficiencies None B; Deviations Hone Licensee Action on Previousl Identified Enforcement Ifatters A. Infractions 1, Failure to Comol with AP 10.02, "Nonconformit ,Control and 'Correction" Xn compliance with QAP 10.02, a Material/Equipment Nonconformity Report (NR) No. 6-75, was processed and approved on 4/29/75. In addition, procedure change 75A340 to SP-NER-l, "New Fuel Receipt",'requiring submittal of an NR in accordance with gAP 10.02 for fuel assemblies not meeting specifications, was approved on 4/5/75. This matter is considered closed. (DETAILS, paragraph 5)

(continued)

~ ~

~~

3.

2 Failure to Com 1 'with Tool'Accountabilit and Control. Requirements

~ Q Ai individual is

.assure that all now assigned to'patrol the refueling area and loose equipment and materia'ls taken into the zefueling area are properly secured. The individual was at the time this deficiency was brought to the attention initially'ssigned of the licensee by the insoector. This matter is considered resolved. (DETAILS, paragraph 6) 30 Fuel Movement Sequence Sheets 'not Si ned

Procedure "Change 75A-277, 'dated 3/21/75, to 'refuel'ing procedure SP-CR-1 deleted the requirement for the operator sign-off at the bottom of each page of Appendix A. This matter, is considered

.resolved. (DETAILS; paragraph -7)

New Unresolved Items 75-6/1 Insoection on'ents of Structural or',Seismic Su nor't Bolts on"Class I Co (IEB 74-3)

The IEB 74-.3 information submitted by OPPD on 4/24/75 to NRC was determined to be incomplete and partially incorrect. OPPD is to submit a supplement to the 4/24/75 reply. (DETAILS, paragraph 9) 75-6/2 Leaking of Tendon Grease Tendon grease was observed to be leaking at the juncture 'of the seal between the containment and the auxiliary building. Pools of liquid from this material were observed adjacent to penetrations C-7 and D-7 represent-ing a possible fire hazard. The licensee indicated, that an investigation of methods for elimination of the potential fire .hazard would be conduct'ed.

(DETAILS, paragraph 10;b) 75-6/3 Cable Tra Slots Several of the Cable Tray Slots within the auxiliary building did not appear to be completely sealed with fiberglass. (DETAILS,. paragraph 10.b) 75-6/4 Failure of Component Coolin 4'ater Valves 'to Close (AO '75-11)

During an Engineered Safeguards Activation Test, the component cooling water valves to the Containment Air Cooling and Filtering Unit VA-1B, failed to operate properly because of a high flow controller setting. A means of locking the flow controller set,point is being investigated. (DETAILS, paragraph 4.g)

(continued)

~

~

<<4 Desi n Chanc es Installation of design change 75A-45 was completed on 5/3/75 for the.-

installation of secondary pressure interlocks on cooling valves HCV-347 and 348 to inhibit their opening. This change to the PSAR requirements is in the process of being submitted to Licensing for their review.

(DETAILS, paragraph ll.c)

Abnormal Occurrences AO 75-05 On March 11, 1975, during performance of surveillance test ST-ESF-?,

F.3, it was discovered that the SIRE Tank Level pressure switch settings for the, Recirculation Actuation Signal had drifted upward in excess of the allowed TS limit. In'ddition, the SIRE Tank Volume of water was below the required TS minimum requirement. (DETAILS, paragraph 4.b)

AO 75-07 On March 13, 1975, main transformer Tl tripped on an indicated internal fault. Both diesel generators'uto started and came to rated speed and voltage. Diesel Generator ~r'2 breaker 1AD2 auto closed on bus 1AA, however, Diesel Generator lADl failed to auto close on bus lA3. (DETAILS, paragraph 4.c)

AO 75-08 On March 12, 1975, High Pressure Safety'njection Valve, HCV-311, failed to open on a signal from the control room. (DETAILS, paragraph 4.d)

AO 75-09 On March 31, 1975, during performance of surveillance test ST-RMS-1, raw water backup valves HCV-401E and HCV-2808D .failed to operate. (DETAILS, paragraph 4.e)

AO 75-10 On April 3, 1975, during performance of surveillance test ST-ESF-2, charging pump, .CH-1C and'o'ntainment ventilation fan, VA-7C, failed to

.sequentially start from the backup sequence. (DETAILS, paragraph 4.f) .

AO 75-11 J

On April 4, 1975, during performance of surveillance test ST-ESF-2, section F.3 and F.4, inlet and outlet valves HCV-401A'nd HCV-401C to containment cooling and filterning unit VA'-1B failed to operate properly. (DETAILS, paragraph 4.g)

(continued)

4

~ ~

<<5 Other Si nificant Findin s:

'3

~ "

During the inspection the reactor was determined to be at twenty percent power with approximately ten percent load on the generator.. Post refueling low power physics testing had been completed and power ascension testing was in progress.

Mana ement Interview On May 9, 1975, a meeting was held with OPPD management to identify the scope of the inspection and to summarize the findings of the inspection.

the following individuals were in attendance:

Omaha Public Power District (OPPD)

T. E. Short, Manager Production Operations W. C. Jones, Operations Manager F. A. Thurtell, Manager Quality Assurance W D. Dermyer, Plant Supervisor

.The inspector described the scope of the inspection and the findings. The significant items discussed are given below:

A. New A arent Item of Noncompliance The infraction for exceeding the TS limits of Table 2-1, item 5, on the SIRE Low Level Switches and not meeting TS 2.3(1)a, requirements relative to minimum volume (AO 75-05).

B. Corrective Action for Previously Identified Matters or other Inspection Items that Require Followuo

1. Failure to comply with JAP 10.02 "Nonconformity. Control and Correction".

2. Failure to comply with tool accountability and control requirements.

3. Fuel movement sheets not signed.

4. ROB 74-3 Inspection of Components.

Structural or Seismic Support Bolts on Class I

'5. ROB 75-04A Cable Fire at Browns Ferry.

6. AO 74 Failure of STS Relay 86-OR/1AD1.

7. -

AO 75-03 << Failure of STS Relay 86-OR/1AD1.

8. AO 75-07 Diesel Generator Breaker. 1ADl Failure to Auto Close on Bus lA3.

'continued)

0 9, AO 75-08 - High Pressure Safety'In5ection Valve, HCU<<311 Failure to Open.

10. AO 75-09 Raw Water Backup Valves HCV-401E and HCV-2808D Failure to Operate.

ll. AO 75 Failure of Backup Sequencer.

12. AO 75-11 Failure of Component Cooling Valves HCV-401A and HCV-401C to Operate Properly.

13. Leaking of tendon grease.

14. SARC and PRC review of TS changes.

(continued)

&geO

~ li

DETAILS Prepared by M. V. Dickerson and K. Smith, Jr.

<f

~5 1. 'Persons'Contacted I ~

The following individuals, in addition to those listed under the Manage-ment Interview section of this repoxt, were contacted during the inspection.

Omaha Public Power'District'(OPPD)

R. L. Andrews, Plant Operations Supervisor S. C. Stevens, Technical Supervisor S. M. Moyer, Plant Maintenance Supervisor Dr. R. L. Jaworski, Reactor Engineer J. E. Bentzenger, Engineer-Quality Assurance J. M. Nagl, Electrical Engineer N. L. Marfice, Instrument & Control & Electrical Field Maintenance Engineer J. J. Fisicaro, Assistant to Plant Supervisor J. C. Riley, Shift Supervisor R. C. DeHeulmeester, Shift Supervisor R. F. Johnston, Shift Supervisor 0 2~

J. L. Connolley, Test Engineer I

General The purpose of this routine announced inspection.was to review the corrective actions for previously identified matters; items reported by the licensee; reactor startup operations; act-'on on reactor operations.

bulletins; maintenance activities during shutdown; and an inspection relative to fire stops for electrical cables and penetrations.

~

3. Post Refuelin Startu Testin The inspector examined procedures and associated test data to verify that post refueling startup testing was conducted in accordance with require-ments.

Procedures and data relating to the following were reviewed:

a., Contxol Element'ssembly position checks.

b. Boron reactivity worth.

c. Measurement of temperature coefficient of reactivity worth.

d. Minimum shutdown boron concentration with a control element assembly completely withdrawn from the reactor core.

.(continued)

e. Control Element Assembly worth for each bank.

f. Checkout of the recently installed variable over power, trip circuitry.

g. Partial power ascension testing.

Completion of this review will be performed during a future inspection.

The post refueling testing procedures were reviewed for adequate definition of scope, objective, prerequisites, precautions, limitations,,acceptance criteria checkoff lists, deficiency control and resolution, valve lineups, plant conditions, and proper approvals. No deficiencies were identified by the inspector.

4~ Abnormal Occurrence'Re orts '(AOR's)

. Abnormal Occurrence 74-18, 75-03, 7S-OS and 75-07 thro+'e ?5-11 were reviewed during this inspection. The details of each are summarized in the following paragraphs. The inspector's effort was directed't verification that:

a. the details of the event were clearly reported in the 10-day letter;.

b. 'he cause was clearly identified;.

c. the corrective action indicated had been completed; 'and

,d. the event and indicated corrective. action was reviewed and evaluated in accordance with the Technical Specification.

No discrepancies were noted. However, AOR 75-05 does constitute a, deficiency, since the decirculation actuation set point had drifted upward in excess of the TS requirement. Corrective measures have be'en taken by

. the licensee as described below.

a. AO 74-18 and AO 75-03 Failur'0 of Diesel Generator Breaker Override The two Abnormal Occurrences reported -by the 1'icensee are similar since both resulted, during Surveillance Test ST-ESF-2 (Safety Injection Activation), in the fait.ure of lockout relay 86-OR/1ADl to trip. As reported by the licensee, AO 75-03 is the fourth occurrence of a relay failing to operate due to wir'e lug interferences.

To prevent repetition of this occurrence the licensee has completed a permanent fix which would eliminate. the wire lug interference problem as follows:

(1) Removal of the relay covers and cut off all but the last 3-3/4" of the cover which protects the coil. Arrangement of the relay (continued)

IE Inspection Report No. 50-285/75-01, Details 1, paragraph 8

4 0- ~

wiring to assure sufficient contact clearance and 'installation of the covers over the coils.

(2) To prevent dust and other foreign material from falling into the relay contacts, installation of a l(8" Micarta panel above the top rows of relays. This panel was placed between the top of the relays and the bottom of the amber status lights.

(3) 'o prevent dust from collecting on the relay contacts, air filters were installed on the louvered panel doors which are intended to remove all particles larger than two microns in diameter.

This matter is considered closed.

~~

AO'75-05 Recirculation Actuation Si nal'Set Point'Drift During review of SIRH Tank I.evel Channel Can~br .+"..~s ST-ESP-7, P.3 it was discovered that the as Sound pressure switch settings for the Recirculation Actuation Signal had drifted upward in excess of the Tqchnical Specification section 2.0 setting specified in Table 2-1, Item 5. This set point is 16" + 0" 2" and initiates Safety Injection Recirculation. In addition, the level being maintained in the SIRE'ank was found to be approximately 15,000 gallons below :

the requirements of Technical Specification section 2.3(1)a which requires a minimum level of 283,000 gallons of water in the SIRE Tank.

The inspector determined that calibration procedures have been changed to provide low level'nd high level alarm set points of the SIRE Tank to 185 inches and 193 inches respectively. This low level alarm alerts the control room operator when the level decreases to approx-imately 296,000 gallons. The calibration procedures were also changed to calibrate the Safety Injection recirculation set point to 16ll + Oll 2II The calibration set point was previously set at 16" + 0.2"'which is 0.2 inches above the Technical Specification limits. A design change has been prepared to install switches with a lower pressure setting in the safety injection recirculation control circuitry. The pressure switches have not been installed. This AOR remains open.

These infractions were identified by the licensee and were reported in a timely manner. Corrective actin ha" been taken. No additional information is needed for these items of noncompliance at this time.

AO 75-07 Failure of Diesel Breaker'IADl to Close on Dead'Bus Durin I.oss of Off-Site AC Power At 0031 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> on March 13, 1975, main transformer Tl tiipped on an indicated internal fault. Both diesel generators'uto started and (continued)

<<10-came to rated speed and voltage due to loss of voltage on 4160 volt buses '1A3 and 1A4. Diesel Generator ii2 breaker lAD2 auto closed on bus lA4; however, Diesel Generator breaker 1AD1 fail.ed to auto close on bus lA3. The operator then manually. closed ,, .",

breaker lADl'by control switch. This occurrence was'caused by.

'the failure of the operator to trip SI-1A breaker.

Operating personnel were briefed by the Operations Supervisor on the operator action required during loss of off-site AC power.

It was.brought to their attention that Emergency Procedure 83 documents the action required by the operator during loss of off-site .AC power.

This matter is considered closed.

, AO 75-08 Failure of Hi h Pressure Safety In ection Valve HCV-311 to 0 en on a Sipral from the Control Room.

The High Pr'essure Safety Injection Valve HCV-311 failed to open on control switch command from the control room. The reversing interlock at the combination breaker/starter for HCV-311 was not making proper contact. Also, a normally open contact had been installed instead of a,normally closed contact. Preventative maintenance had been performed on this breaker/starter prior to this occurrence and the breaker/starter was improperly reassembled.

The inter'ock:: s reassembled and manually actuated to verify operability. HCV-311 was then electrically operated by control switch from full open to full close to full open twice. The valve, its combination breaker/starter, and the reversing interlock operated properly.

This matter is considered closed.

AO 75-09 Failure of Raw 4'ater Backu Valves HCV-401E and HCV-2808D to 0 crate During performance of Surveillance Test ST-Rfi'S-l, raw water backup valves HCU-401E (raw water supply to UA-1B) and HCV-2808D (raw water return from SI-2A) failed to operate on signal from the control room.

The failure of HCV-401E to operate 'was attributed to dirt in the valve positioner. HCV-2808D failed due to a solenoid which had failed to operate.

The pneumatic relay orifices on the positioner of HCV-401E were cleaned and the valve was retested satisfactorily. The solenoid was replaced on HCV-2808D and the valve was retested satisfactorily.

This matter is considered closed.

AO 75-10 Failure of Backu Se uenccr to Actuate huxiliar Rein Charging pump, CH-lC, and containment ventilation fan, Vh-7C, failed to sequentially start from the backup sequencer (Sl-2 and 52-2)

'(continued)

I

<<11-during Surveillance Test ESF-2. A test and inspection of the relay logic chain revealed that the contact from the timing relay which energizes the auxiliary re3ay was contaminated.

The relay contacts were burnished and the logic chain success-fully tested. CH-1C and VA-7C backup sequencer rela'ys were activated by simulating a pressurizer pressure low signal, timed out properly and did start the charging pump and containment fan' This matter, is considered closed.

g. AO 75-11 Failure of Component Coolin plater Valves to Containment Air Coolin and Filterin Unit. VA-1B to Ooerate Prooerl

'During the performance of Engineered Safeguards Actuation Test ST<<ESF-2, Sections F.3 and F.4, Inlet and Outlet Valves HCV-401A

~

and HCV-401C to Containment Cooling and Filtering Unit VA-1B opened under CIAS signal then reclosed after a fifteen second time delay.

HCU-401A and HCV-401C could not be reopened by the control switch with the CIAS signal present even though a flow of approximately 1500 gpm had been established.

The actuation set point on FC-417A was found to be set high so that normal flow could not actuate it. The set point was changed to its'proper operating point and the valves were tested to prove proper operation under a CIAS signal.

A means of locking alarm settings with a screw is being instigated by the licensee.

This matter will remain open.

5. ,Failure to Com 1 with AP 10.02, "Nonconformit Control and Correction"2/

Following the inspection of starch 4-7, 1975, material/equipment noncon-formance report (NR) No. 6-75 was initiated on 3/21/75, and was completed on 4/29/75. The NR includes a letter from Combustion Engineering which confirmes the acceptability of fuel elements B009 and OD031 for use as is.

In addition, procedure change 75A-340 to SP-NFR-l, "New Fuel Receipt", was approved by the PRC on 4/5/75. The change added step X.B.4 which requires

.that the Reactor Engineer submit an NR in accordance with QA procedure 10.02, for fuel assemblies not meeting specification.

This matter is considered resolved.

'6. Failure to Com lv with Tool Accountabilit and Control Re uirements 3/

To assure that conformance is maintained with the requirements of kfaintenance'Procedure 5P-RC-l-l and Core Refueling Procedure SP-CR-1 (continued) 2/ IE Inspection Report No. 50-285/7S-01, Details 1, paragraph 3.

3/ IE Inspection Report No. 50-285/75-01, Details 1, paragraph 4.

relative to loose material and equipment in the refueling, area, a requirement for patrol'f the area has been added. .At the time of the y '-3 70 previous inspection a health physicist was initially assigned this responsibility when the deficiency was brought to the attention of the licensee. This matter is considered resolved.

Fuel Movement Se uence Sheets Not Si ned 4/

Procedure Change 75A-277 to the Core Refueling .'Pioce'dure SP-CR-1 was approved by the PRC on 3/21/75. The change eliminates from paragraph D.3 of the procedure the requirement for the "Refueling Crew Control

. Room Operator" to sign and date the bottom of each Fuel Movement Sequence Sheet. The proce'dure still requires the operator to initial the sheet after each sequence in the fuel movement. This matter is considered resolved.

SARC Review of Technical Violations and Chan es 5/

A review of. the SARC Meeting Minutes dated 4/4/75, inaica 'ed that the SARC had co..pleted a review of all Technical Specification Change 7. In addition, meeting minutes of the PRC ind. cated that this committee had also reviewed TS Change 7. This matter is considered closed.

9. IEB 74-03 Inspection of Structural or Seismic Bolts on Class I Components 6 The required examination of the steam generator *supports and seismic xestrai s wa pe or d o aa ch 15, 22 and=April 5 1975 ~ A lel I ex summarizing this inspection was transmitted to NRC on April 24, 1975.

However, a review of the inspection report, deficiency report No. 0-24-75, dated 4/10/75 and No. 8028, dated 4/12/75, indicated that additional information relative to the inspection findings and status of correction of the deficiencies should have been included in the 4/24/75 letter to the NRC.

All deficiencies except for a reported toro missing washers were corrected prior to reactor startup. An engineering evaluation relative to the two washers has not, as yet, been performed.

The licensee is to submit a supplementary reply to IE 74-03 which will include those deficiencies found and the status relative to their correction.

This matter remains open.

10. Fire Sto s An inspection relative to the installation of fire stops on electrical cables and penetration seals was performed by the inspector to determine the extent of conformance of the existing installations with design drawings-and specifications.

(continued)

IE Inspection Report No. 50-285/75-03, Details, paragraph 2.c.

5/ IE Inspection Report No. 50-285/75-01, Details 11, paragraph 6..

6/ IE Inspection Report No. 50-285/75-01, Details 1, paragraph 14.

Drawin s and S ecifications The inspector reviewed design drawings and specifications prepared by Gibbs, Hill, Durham and Richardson, Inc., and determined the status of the licensees actions relative to IE Bulletins 75-04'and 75-04A. The specification is contained in detail in contract No. 765, dated 7/69, with Commonwealth Electrical Company. The contract (specification) also references the pertinent drawings which were reviewed by the inspector.

The specification required fire stops for vertical tr-.y runs in excess of ten feet. The method used was requ'ired to be reviewed and

.approved by the engineer. Slots and openings in walls and floors

-through which cable trays pass and conduit sleeves, .slots and open-ings were also required to be framed and sealed with fiberglass, or other suitable material. The licensee's representatives indicated

-.that only fiberglass'had been approved and utilized. The licensee also indicated that no other fire retardant materials were utilized except that fire tape manufactured by Irvington Company was utilized

=

at points within the control room cabinet base as wrapping for i individual cables at the floor penetrations.

Visual Observation The areas which were viaually examined by the inspector were:

(1) the Cable Spreading Poom; (2) portions of the Auxiliary Building, and (3) individual compartment within the Reactor Control Room.

Details of the installation'appeared to be in conformance with the specification requirements. However, it was noted that several of the wall openings did not appear to be completely sealed with fiberglass.

Small openings were observable. It was also noted that tendon grease was leaking at the juncture of the seal between the containment and the auxiliary building. This grease had leaked down and around electrical penetrations C7 and D7 and was formin pools of oil near the penedrations. This finding was also noted in the QA audit discussed in section 10.f of this report. The licensee was informed that these matters would remain as an open item.

Fire -Protection and Insnections An extensive fire and smoke detection alarm system was also installed under contract 765. The system utilizes PYR-A-LAF~1 ionization, photo-electric, and thermal detectors in combination with a main control panel in the control room, and remote alarm devices. The area system monitors 32 zones within the containment, auxiliary building and turbine rooms. The main control room panel provides annunciation and will indicate the zone. It also provides an annunciator for failure of power to the system.

(continued)

In con)unction with the detection system Oper'ational Instruction OI-FP-6-1 provides for a weekly fire protection system inspection and test. It includes operational checks of fire pumps, water systems, CO 2. chemical extinguishers, sprinkler systems, hose cabinets and a housekeeping inspection including not needed or .

unsafely stored volatile or combustible materials.

"Emergency procedure EP-10-1 provides for the steps to be taken in the event a fire occurs in or threatens reactor safeguards equip-ment, reactor protective equipment, or other equipment vital to the safe operation of the plant. This includes, use of the local fire department and a react;or trip according to emergency procedure Ep-l.

The existing fire extinguishing system provides:

Sprinkler for the turbine lube oil handling equipement; (2) Sprinkler for the turbine room basement; (3) Hose stations for the immediate vicinity outside the entire plant; (4) Hose cabinets inside the turbine building and the intake structure; (5) An automatic (heat sensing) deluge system for the main transformers two auxiliary and two house seismic transformers; and, (6) Local portable dry chemical and carbon dioxide extinguishers.

Present Installation Practices

'o determine the present OPPD practices relative to electrical instal lations, the inspector reviewed two maintenance orders for work per-formed during the refueling outage, .

MO'8182, dated 5/2/75, Installation of Shutdown Cooling Valve Inter-lock, also discussed in section ll.c of this report, utilized four conductor ~)10 AUG cable, Cerro Firewall, which was certified by the Cerro '!fire and Cabl'e Co., by type test to have exceeded the require-ments of a post steam exposure flame resistance test. Minimum post ignition burning was recorded as 23.6 minutes; circuit integrity exceeded 15 minutes and no self sustaining flame was observed. Exist-ing space containment penetrations, cable trays and new conduit were utilized. Fire stops utilized the existing fiberglass where walls and ceilings or floors were penetrated.

MO 7653, dated 3/3/75, Loose Parts Monitoring System, was installed essentially as described above except for the cable utilized. .The cable utilized was 2 conductor Raychem-Flametrol'(Firewall III}which (continued)

k was certified as exceeding the requirements of 'IEEE 383. Fire-wall III is composed of 30 mils of flame retardant XLPE'nsulation covered with 45 mils of flame retardant neoprene.

Status of Re 1'o IE 75-04 and 75-04A OPPD has indicated that they will complete their review relative to IE Bu letins 75-04 and 75-04A and submit a .reply to NRC by July.l, 1975. As part of this review a QA audit was perfo: d on March 19-20, 1975,'o examine and evaluate housekeeping, cleanliness practices, and other activities related to fire prevention and protection. As a result, one of the recommendations was to remove= the tendon grease from the containment'all and investig'ate "a 'method "o'f el'iminating'the 'source.

75A-1 Charcoal Filter Efficienc On February 21, 1975', OPPD received, from American Air Filter, verbal results of charcoal efficiency testing for charcoal filter beds. The results confirmed by letter on February 24; 1975, indicated an elemental iodine efficiency of 98.02% and 98.82% from two different lots of charcoal. The indicated efficiencies were less than the 99.5%

required by TS 3.6(5)d. This was reported to KtC by letter 2/21/75.

t A request to revise the TS acceptance criteria downward to 95% was forwarded to licensing and subsequently approved on 4/30/75.

75A-2 Deterioration of Secondar Insulation 4KV Non-Scare ated Phase Bus Duct On March 31,.1975, deterioration of secondary insulation of 4 KV non-segregated phase bus duct was discovered while performing preventative maintenance on the 4KV indoor bus duct. This was reported to NRC by UE Report 75A-2, dated 3/31/75; Primary insulation of the bus duct 'is provided by separation of the phases from, each other and from gound. The 'secondary insulation

.which failed was a redithermo-setting plastic approximately one-tenth inch thick provided .by General Electric. The failure appeared to be the result of expansion of the material to a point of cracking.

Corrective action recommended by General Electric has been compl'eted in accordance with HO 7661. The procedure called for removal of insulation except where it was ciacked three inches or less, and taping of all bus ducts with Ho. 202 Irrathane tape and then with No. 70 Scotch Silicone tape. All bus.ducts were inspected, repaired and returned to service.

(continued)

~ ~ ~

<<16-Co UE 75-3 Shutdown Coolin Valve Interlock

'On April 15, 1975 OPPD reported to the NRC in UE 75-3 that the Q ~

secondary inhibit, valve HCV-348 as described in FSAR section 9.3.2, for did not in fact exist. Paragraph 9.3.2 describes a primary and seconda'ry inhibit to prevent opening shutdown valve HCV-349 when the RCS pressure is above 250 psi. 'cooling The primary inhibit described comprises pressurizer pressure tran'smitter PT-105 and auxiliary relays in the starting circutis of each valve motor operator. The described secondary inhibit is "a torque switch in the motor operator for valve HCV-347 which wil'1 prevent the valve opening if reactor coolant pressure is excessive."

The UE report stated that a secondary pressure sensing interlock for HCV-348, in addition to the "existing interlock, would be installed during the refueling outage.

The inspector verified that redundant pressure sensing intex'locks had been installed on both HCV-347 and HCV-348.. The work was performed in accordance with YO 8182 dated 5l2/75 and approved by. the PRC. OPPD is in the process of submitting these changes to Licensing for their 'review.

UNITED Sv,n'ES '."JCr.r SR RECUL,"nORV! CO~~,ISSIO:<

OFFXCE OF I-:sS1 ECTIO.'i A; D ENFORCE'fENZ

)

REGION XXI Report of Operations Xnspection

.XE Xnspection Report No. 050-266/75-07 XE Xnspection Report No. 050-301/75-05 Licensee: Visconsin Electric Power Company Wisconsin Hichigan Power Company 231 Vest ifichigan lH.lwaukee, Visconsin 53203 Point Beach Nuclear Plant License No. DPR-24 Units 1 and 2 License Ko. DPR-27

-Two Creeks, Visconsin Category: C Type of Licensee: PVR (V)

Type of Xnspection: Special, Announced Dates of Inspection: April 24 and 30, 1975 Dates of Previous Xnspection: April 15-17, 1975 (REP)

Principal .Inspector: D. C.

(D te)

Accompanyihg Xnspectors: None .

Other Accompanying Personnel: Hone Reviewed By: .. Jp Jordan Seni' Inspector ( ate)

Reactor Operations Branch

SUIQIARY OF FINDINGS Enforcement Action: '.lone.

Licensee Action on Previousl Id entxfzed I;nforcement Action Hot inspected.

Unusual Occurrences: None inspected.

Other Si nificant Findinns A. Current Findinr s k

Both plants at essentially. full power.

Unresolved Items: . None.

C. Status of Previously Unidentified Unresolved Items: None.

Hang ement Interview The management interview was conducted on April 27, 1975, with Hr.

Greenwood, Assistant to the Manager, and Ns. Flentje, Office Supervisor..

The items discussed included the following:

Ik A.. Construction specifications for electrical penetrations.

(Paragraph 3.a through 3.d, Report Details)

B. Results of inspection of electrical penetrations. (Paragraph 3.d, Report Details) k C. Current practices at plant.. (Paragraph 4, Report Details)

D. Compliance with final safety analysis report. (Paragraph 5, Report Details)

E. Plant fire protection system. (Paragraph 5.g, Report Details)

P. Licensee response to XE Bulletin No. 75-04 and No.75-04A, (Paragraph 6, Report Details)

REP0RT DETArLS

l. Persons Contacted

$ B.sconsin Hichiran Power Connanv G. Reed, Hanager, Nuclear Power Division J. Greenwood, Assistant to the ~fanager L. Storz, Shift Supervisor 1<. Crouch, lfaintenance Supervisor T. Deddens, Haintenance Superintendent 2.. General I

Special inspections were conducted on April 24 and 30, 1975, to deter-mine the plant status in regard to the provi ion of acceptable fire stops and flame retardant seals Eor electrical penetrations.

The ma)or inspection effort was an inspection tour of the electrical pcnetrations in the following 'area Control room Cable spreading room Auxiliary equipment and ventilation room (above control roon) 1)iesel generator roomed Portions of the Turbine building

~

Portions of th'e Auxiliary building The inspection included review of' representative sampling of completed plant work request and modirication request for..s, plus discussions with the Assistant Plant Electrical/~laintenance Supervisor, and the Assistant to the 1janager.

Also included in this inspection was a sampling co,.parison of Licensee comzittments in the "inal Safety Analysis Review (FSAR) against the actua1 conditions now existing at the plant.

3~ Penetration Seal ifaterials The following materia s and specifications utilized in providing the

- fire-stops, sealing and Eire retardant protection for the various electrical penetrations and trays.

3

P a ~ Pire-Sto s These fire-'stops aze 'g inch thick sheets of .farinite Board I

manufactured by the Johns-Manville Company. I The basic materials are cement an'd asbestos. )

I

b. Pire-Retardant ".hterial.

Plamemastic 71A manufactured by the Dyna-Therm Corporation.

This is a water base material which is non-flamable at all

. times.

C~ Sealant t<aterials The sealant materials which are packed in around the electrical cables in the electrical penetrations are all of the inorganic

'iber insulation type of material; the primary material used at this plant is an inorganic thermal insulating material manufactured by the Babcock and Wilcox Company bearing the trade'ame "Koawool". Thus, in summary, none of the materials

~

used in scaling and fire retardant coating of these electrical penetrations are at any time flamable.

d. Penetration Sealant and Flame Retardant Specifications Detailed penetration sealing, fire zeta".dane application, and fire-stop specifications aze provided for ten different types of penetrations. These specifications are provided by Bechtel

~

Company. on drawings E-178 and E-179. These specifications were reviewed by the inspector prior to the physical examination of the various electrical penetrations in the plant. Several minor deficiencies were observed as follows:

h I

(l) At several electrical penetration fire stops, the flamemastic 71A fire retardant material was observed. to be cracked, apparently due to shrinkage upon drying. This cracking up to < inch in width, did not provide a pressure/smoke seal around the Sire-stop.

(2) A diesel generator guarded cooling water line (pipe within a pipe) was not sealed at its exit from the diesel generator room. This is a 30 foot s'ection of 12 inch horizontal pipe. All other lines or openings were sealed or had automatic closure devices.

I 0

(3) One penetr"t:i.on, containing onlyI power and cont:rol cables for 'the electro-hydraulic control of .the turbine speed cont:rol, had only the marinice fl,.me stop. There were no other trays or. penetrations within t:hree feet of this pene tra t:ion.

'f At the time of thi's in p'ection the Licensee was in t: he process examining all electrical penetrations in resoonse to 1E Bulletins 4i'o. 75-0'i and 'lo. 75-O~iA. The licensee reported that they had found one penetrati'on with a missing fire-stop and others that xequired dditional I:oawool and/or "lamemastic 71A. The inspector observed that these corrective act:ions were being made using the specifications ident:ified above.

The Licensee has stat:ed the intent to correct any deficiencies found, as expeditiously as time and plant conditions allow.

l These three deficiencies are not considered as immediately serious by the inspectox'ince they pose,no .,fire propogation threat, but rather a smoke control problem. This plant utili~es a multi-..ode ventilation syst: em whi.ch is designed to assure that smoke from any other portion of the plant can be prevented from ent:ering the control room or can be swept from the control room if it originates in the control room. As a back-up measure, the inspect:or observed that there 'axe four self-supporting air breathing masks available in the cont:rol room.

Emergency procedure E.O.P.10A, control room inaccessibilit:y, p vh'0 ttl)(

~

~ 1 (tI A1ht v 4 yvavv

~ 1 ~ ass0 Phv 4 l vol va \6 I6hvaa\ I VAA%sA9 vllQ4 1 r ~~ ~ As wI I ver

\JVeo ~ 4 s t4d 444 J Vjs Vu

~

~ ~ le VL t: he control room, should this unlikely event occur, This capability was demonstrated in a start-up and power ascension test:.

. lt., Current Practices I

Discussions with the Assistant Electrical/.'faintenance Supervisor, plus a review of plant work request and modification files indicate that disturbing tnese sealed electrical penetrations to pull in new cable or re..ove old cable is an infrequent occurrence. Formal procedures or instructions are not issued, however, .according to the Licensee, the craftsmen return the penetration to its original status by using the specifications ident:ified in item 1-d above.

.The Licensee does not believe that. individual penetration seal testing to insure th .t a total pressure seal exists is necessary fox penetrations other than containment boundary penetrations-This position is based on the fact that the various plant ventilation control systems are designed with sufficient

'ndependence to permit sweeping of smoke from the various portions of the plant without the smoke being introduced into

2 I

I the control room. The separate control room ventilation system i designed with the capabili.ty i to purge any smoke originating in the con'trol room directly ty/agi/osphere, or to operate in a recirculating, filtered~ mode. -" Thus, the Licensee does not intend to perform jndividual penetration seal tests. They do intend to adhere to the penetration specifications of item 1-d above, in providing a flame stop, flame retardant, fire barrier type penetration with reasonably tight smoke limiting seal. The inspectors review of these design specifications and tne Licensee's final Safety imalysis Report indicates that neither specify that a:".casu able pressure scale:.ists, but rather that a "fire barrier" eyists.

Ho open flame is used <<n the testing of seals or penetxations at this plant.

1 5.'om liance with Final Safet Anal sis Rcport Other items inspected and compared against committments of the FSAR include the following: (sampling basis. only)

To restrict the possibility of fixe originating in the control room, negligible combustible material, trim or furn'shings are used in its construction. All electrical wiring devices are surrounded by or r ounted in metal enclosures.

b. Xn the event a fire does occur in the control roon, the operator is supplied with portable xesp ra'ory equ'pment (4/ and portable fire extinguishers sized and located in accord..nce with .'(ational Pire Protection Association specifications. The extinguishers carry the Underwriter's Laborator> label or approval, and are suitable for use on electrical fires. The contxol room, cable spreading and battery rooms contain portable fire extinguishers.

C~ To prevent the spread of fixe from the electrical rooms beneath the control room., the following provisions are made:

Cables used throughout the cable spreading room have an3/

exterior jacket that meets the IDGE test requirements, and cable .characteristics meet the following requirements:

1/ Procedure PC-314, operation and testing of control room and cable spr'eading room ventilqtion systems.

2/ Operating instruction OE 44, diesel generator room ventilation j

system.

3/ 'able specification fi'es 6.5.3 & 6.5.4 contains specifications and fi.re testing of the following: (a) Bechtel Spec for 600V insulation power and control cables for afeguards service (also for 5'nd 15KV insulated power cables), (b) BE'J Bostard cables, (c) Kerite Company 5KV 350 i~aC';1 cables,

~ \ g t pt

~

Revere cable trays pass through walls into the electrical equipment and cable spreading rooms, air spaces around the trays are sealed by field-fitted metal tray's. Each entering e' metal tray is provided with a fire stop and is coated with fire retardant material to prevent fire from propagating into these rooms.. Cable trays in the cable spreading room are provided with solid bottom -and covers, and thermal blankets of

.Koawool are provided under these metal covers at tray crossover areas.

'he I

~

electrical equipment rooms, cable sprqading room and the elqctrical switchgear room are ventilated by separate air circulating systems. in the event of a 'fire in any of these areas, the operator has control of the supply ran from the control room so that the circulating air can be cut off. The presence of fire in a cable spreading room, dies'el generator rooms, electrical s~itchgear room or the electrical equip...ent room is alarned in the control room by a product of detection system.

combust:ion'smoke)

Power cables for the diesel generators enter in conduits which.

penetrate the diesel room wall and continue 'in the electrical equipment room. These wall penetr,.tions are sealed. Each

'he diesel is in a separate room. See item 3.2(2) identification of a possible. deficiency in this area..

g~ Pla>>t Fire ProLucLion S stem

~ (1) inspector verified that applicable port-'ons of the FSAR Section 9.6.1 Eire protection system, are currently functional:

Control Room Protection Observed .following:

(a) Two 75 pound CO 2

mtinguishers with 50-75 foot hoses and nozzels (one on each side of control room).

(b) One 15 pound C02 extinguisher in kitchen.

(c) Two water spray hoses (50-75 feet of hose) located immediately outside each control room door.

~

. (d) Four. fresh air (instrument air supply) masks, each 50 to 75 feet of hose. 'ith Procedure PC-20A Monthly fire system checks. This fire protection check list identified 77 fire protection devic.s inside the building and 57 fire protection units outside the bu'lding 5/ Note of interest: The company's fire insurance inspector reviews all of these items and the penetration status each 6 months.

'I

~ ~> ~ ~

(e) Hultiple other A'tSUL and CO~ extinguishers immediately available on the turbine haXl floor.

I (f) A fire annunciator panel'for eleven portions of the building. t (2) Cable Soxoadina Roora Obeaaved following:

One 100 pound C02 cart with 75 foot hose.

(3) Diesel Generator Rooms -- Observed following:

l (a) Service water sprinkler system.

(b) 20 pound,ANSUL in 3D.

(c) . 20 pound A:<SUL in 4D.

(d) Smoke detectors and thermal detectors - annunciate in control room and isolate diesel ventilation system.

6. Licensee's Response to IE Bulletin 'Ao. 75-04 and 75-04A The licensee issued a response to these Bulletins on April 8,,1975.

Plant: personnel are approximately 90 percent complete with a compre-hensive inspection of all safety related electrical penetrations.

.Deficiencies are being corrected as they are identified. The specifications identified in 1-d above are being used (observed by inspector) No major deficiencies have been identified.

h JEST t'

~

I

~ ~

~ o ~

s ~ ~

~ ~

~ ~

~

~

a ~

~ I ~

~ II ~ ~

~

SUtPiARY Enforcement Action t

ll Hone

~

~< ~

C,:

Licensee'Action on Previousl Identified Enforcement Action Hot applicable Unusual Occurrences Hot appl icabl e Current Findin s A. The licensee responded to IE Bulletins Hos. 75-04 and 04A on April 23, 1975. The only actions required will be (1) to expand existing administrative and maintenance procedures and (2) to replace a questionable fire retardant compound (Dow Corning Silicone Compound 732 or 738) used around cabling that was disturbed during the Hovember-December 1974 refueling outage. This work will be accomplished during the June 1975 refueling outage. (Paragraphs 2-e).

B. In general, maintenance procedures were prepared and issued for usage by craft forer;.en withou addjtijonal manac ement review'nd approval. (Paragraph 7)

Hanaqe'ment Interview The results of the inspection were discussed with Messrs; Raymond, Rapp

'nd Voss. The following commitments were proffered by the licensee's representatives.

l. The silicone compound used for a fire barrier will be replaced with the more fire resistant and retardant material Flamistic 71A.

(Paragraphs 3 and 4)

2. Operations and maintenance personnel will be specifically advised not to store combustible materials on or adjacent to cable trays.

(Paragraph 4)

3. The maintenance procedures will be prepared, reviewed and approved by December 31, 1975 in accordance with the gA program, as described to the Commission in a letter dated January 10, 1975. (Paragraph 7)

DETAILS

~ ~

Persons Contacted J. Carroll, Supervising Steam Generation Engineer H. Scherrer, Senior Steam Generation Engineer F. Dan, Senior Engineer ll. Raymond, Plant Superintendent E. Weeks, Plant Engineer tl. Rapp, Senior Power Production Engineer D. Yoss, Acting Supervisor of Operations

.J. Kamberg, Instrument Haintenance Foreman D. Richardson, Hechanical Haintenance Foreman G. Tully, Electrical flaintenance Foreman R. ltindlex, Electrician S. Redeker, Power Production Engineer

2. Sco e of Ins ection of Fire Barriers for Cables The inspection included an examination of (1) construction specifica-

'ions for location and installation of fire barriers and compartment boundry seals for safety related cables and utilization of fire retardant coating on cables, (2) licensee's action pursuant to IE Bulletins Hos. 75-04 and 75-04A, and (3) a tour to determine extent of conformai>ce to overall fire barrier requirements.

3-. Construction S ecifications

~ ' In 1968-1969 that time, A program was PG&E analyzed all thermal plant load centers and, at embarked upon a program to separate units electrically.

also initiated to improve penetration and cable resistance to fire by the use of flame resistant insulation and fire stops. The Company's Engineering DepartmIent subsequently issued a manual entitled "Thermal Electric Design Standards."

Accordingly, the licensee has been backfitting Humboldt to the new construction standards. The fire and smoke barriers used between the feed pump room and the reactor control room circuit consist of kaowool, Hartinite (Johns-Hanville product composed of incom-bustible asbestos fibers, diatomaceous silica and a hydrothermally produced inorganic binder) panels and Flamistic 71A as a sealant and fire retardant on top of the Hartinite.

Barriers are only needed between the feed pump room and the control room since that is the only area where there are cable trays. All cables leaving the pump room going into the refueling building and drywell are carried inside of conduits. The conduit is frequently sealed with a moisture barrier of Dow-Corning silicone compound 732 or 738. The Construction Department mistakenly used some of this compound for the fire barriers to seal cabling that was disturbed during the last refueling outage. This will be removed during the forthcoming June refueling outage according to the licensee. (This error fuse of flamable material] was discovered subsequent to the licensee's response letter of April 23, 1975 which states, "All o seals used on floor and wall penetration seals are nonflamable.")

I

0

~ ~ 3

4. Examination of Fire Barriers

.A tour. of'he facility was conducteu 'o examine the location and installation of. 'fire barriers and the utilization of fire retarding coating (Flamemastic 71A) for safety related cables. Specifically included in .the 'examination were the penetrations leading into the control cabinets and switch gear in the control room and the penetrations leaving the feedwater pump room (cable spreading room). .The safety related cabling leaving the pump room was encased in conduit.

It was found that the licensee had adhered to the construction specifications for fire barriers, except for the cabling that was disturbed during the last refueling outage. The inspector tested a small sample of Dow-Corning silicone compound (rubber-like in appearance) with a match. It ignited easily and sustained combustion until all of the surface area had burned. It could not be reignited without first removing the outer crust that had formed. As pre-viously noted, the use of this material was a construction error and it, will be replaced with Flamastic 71A in areas where it was used as part of the'fire barrier.

Five large cardboard boxes were found stored on top of pull box Ho. 02 through which the principal. safety related cables pass that lead from the feed pump room to the refueling building. (The use='4 0 iqw c' war in rasal 1 hnv, fAp, vari])tidhnf r harm>; c les gg v rela i p(N

\/P 'vli 4

~ s ~ 6 0

cabling is discussed in the. licensee's report to the Commission "Failur i'!ode Analy'sos'of Re'c.or Protection Systems,""-'. .-'ntitled

-dated January 20,"1970.) The boxes were leaning against the ver-t'ical cable trays leading into the pull box. They were promptly removed and satisfactorily stored by the licensee.

1 Haintenance and Hodification Procedures Plant maintenance and modification procedures do not specifically require adherence to the construction procedures for fire barriers.

General policy dictates that systems disturbed by these activities be returned to their original state as stated in the licensee's response of April 23, 1975, "All maintenance during periods of operation is reviewed by at least the Shift Foreman and the cognizant

'taintenance Foreman who assure that the work is carried out in accordance with established Company Accident Prevention and Fire Prevention rules. In addition, the Shift Foreman and Supervisor of Operations review maintenance activities to assure that the limiting conditions for reactor operation outlined in the Technical Specifications are maintained."'

Existing "Company Accident Prevention and Fire Prevention Rules" address several of the areas identified in the IE Bulletins. The licensee was examining existing policies and procedures with plans to modify or expand as appropriate the remainder of items as they apply to construction, modification or maintenance activities.

According to the licensee, these policies and procedures will be included in the Plant Administrative Control Hanual. This Hanual is a part of the operational quality assurance program scheduled to be completed by December 31, 1975. In the interim, all such activities which could adversely affect reactor safety-related equipment will be 'reviewed by the Plant staff using the guidelines of IE Bulletin 75-04 and 75-04A. This interim procedure was to commence by Hay 23, 1975.

~Emer enc Procedures for Alternate liethods of Core Coolie The alternate methods for core cooling and status of'he "spectrum of alternate paths" were reviewed with the licensee. The Plant Emergency Procedures provide alternate methods for accomplishing an orderly plant shutdown and cooldown in case of loss of normal and alternative shutdown and cooldown systems. The spectrum 'referred of alternative paths available to supply cooling water and remove decay heat 'is included in the Emergency Procedures and in the Equipment Description and Operating Instructions. In order to place this )nformarion in a more concise form, an ouLline of the spectrum of alternative paths available to supply cooling water and remove decay heat was being prepared as a part of the emergency procedures. This was scheduled to be accomplished by Hay 23, 1975.

Maintenance Plant maintenance was examined by a review of (1) mechanical, electrical and instrument maintenance records, (?) quality assurance document records, (3) equipment surveillance records, (4) Control Operator's and Shift Foremans logs and (5) discussion with maintenance and operations personnel. Haintenance activities were examined in each of the following areas as indicated.

Reactor Coolant System (l) Repair of reactor feedwater pump (out of service from 1/9/75-2/21/75)

(2) Disassembly and machining of feedwater control valve on 11/7/74

k.

~ A 5 l

b. Reactivity and Power Control

~ 4 (1) Picoammeter amplifier repair on 12/10/74 (2) Repair of picoammeter trip on 6/17/74 I

\

Co Core and Internals (1} Replacement of feedwater sparger clamps during 12/74 (2) No other activity other than routine refueling work

d. Power Conversion System (1) Replace main steam isolation valve on ll/5/75 (2) Test of reactor safety valve on 8/22/74 Auxiliary System (1) Cleanup pump repair (out of service from 12/24/74 to 2/14/75)

(2} Overhaul of condensate pump from 10/31/74 to 12/13/74

f. El ectrical System

~ ~

(1) Replacement of brushes on rotary inverter on 4/14-16/75 (2) Servicing of HCC-10 transfer switch during 11-12/74 Emergency Core Cooling System or Containment System (1) Servicing of circuit breaker for emergency condenser steam shut off valve on ll/12/74 (2) Installation of new style dry well rupture disc on 12/7/74

h. Other Engineered Safety Feature (1) Adjustment of torque setting on emergency condenser condensate return valve on 3/17/75 (2} Servicing of liquid poison system manual stop valve on 12/6-7./75

<<6-

'fhe results of the. inspection disclosed the following:

I

'a., Maintenance activities were being peri'ormed '

in conformance with limiting conditions for operations.

b. Appropriate administrative approvals were being obtained for maintenance activities. I ~

rule, procedures in use had been prepared by As a general craft foreman and/or the manufacturers maintenance manual were used for activities outside the scope of general craft know-ledge. These procedures did not always require the use of checklists for detailed work such as the calibration of the pico-ammeter amplifier. Further, these procedures had not been approved by anyone other than the craft foreman.

Equipment was being inspected in accordance with the licensee's requirements.

e. Items were functionally tested and calibrated as necessary prior to returning the component or system to an .operating statuso guality control records were available for these maintenance activities (records pertaining to items a(l), c(l), d(l) and h(2) examined).

g The maintenance activities were accomplished by qualified personnel as noted by company certification records.

~4

U. U. HUCLERR REGULayvar Gvw.".zccrvc

-.'OPPXCE OP X!LSPECZXON AHO EHPORCE!WHT

'REGION V

~ IE Inspection Report No. 50-312 75-04 Licensee Sacramento Hunici al Utilitv District Docket No. 50-312 P. 0. Box 15830 License ho. DPR-54 Sacramento Cal i forni a 95813 Priority Facility Rancho Seco Category B Location Cla Station California Type of Facility Pl'R, BG!J, 913 H!!e 2772 Yi!lt Type of Inspection Routine 5 S ecial, Announced Dates of Inspection A ri1 22-25 1975

'ates of Previous Inspection Febr uar 20 25-27 1975 N. ~

Principal Xnapecrcr N7 4<r7 PJI~~ at a mros, eaczor inspector t ~

Accompanying Inspectors Date Other Accompanying, Personnel: Hone Revleved by .~~

G. S. Spencev/

/;t' X>Ci'~.-.

Chief, Reactor Testing and Operations Branch

SUNDRY OF F I HD I HGS Enforcement Action' ~

Hone.

Licensee Action on Previousl Identified Enforcement Items Hone.

Unusual Occurrences The- circumstances and corrective action described in Abnormal Occurrence Reports Kos. 75-3 through 75-7 submitted by the licensee to Licensing were confirmed. (Paragraph 2 of Details) I!

Other Siqnificant Findinqs Current Findings 1, Design chanqes and modifications have been performed consistent with the Technical Specification requirements. (Paragraph 4 of Details) 2, Procedure revisions have been made consistent with the review and .

approval requirements of the Technical Specifications.

(Paragraph 5 of Details)

3. Reactor operation in conformance to selected Technical Specifications was verified. (Paragraph 6 of Details)

4. 'he installation, modification and maintenance of fire barriers for cable trays and penetratio'ns were consistent with specification and procedural requirements. {Section II of Details)

5. The detensioning of vertical and dome test tendons as'equired by the Technical Specifications for surveillance testing may not be possible. The licensee was evaluating the'ituation. This is designated 'as an unresolved item pending further information from the licensee. (Paragraph 7 of'etails)

6. The faci'lity has been designated in commercial operation for -power levels up to 92.6Ã. {Paragraph 8 of Details)

c. The abnormal occurrences had been reviewed by the Plant Review Committee and the Hanagement Safety Review Committee.

d. The limiting conditions for operation were met in all occurrences reported.

e. System and component failures have been reviewed by the plant staff and properly identified as abnormal occurrences when applicable.

I

f. Revision 3 to Operating Procedure A-51, "Auxiliary Feedwater

'System," was reviewed by the Plant Review Committee and approved for implementation on Harch 21, 1975. This revision implemented the corrective action coxnitment described in Abnormal Occurrence Report Ho. 74-10.

g. The initial data to determine the drift rate of the pressure transmitters as described in Abnormal Occurrence Report tio. 75-5

'ere obtained on April 18, 1975. The results of the drift rate determination program will be reviewed during the next scheduled inspection.

3. IE Bulletin Followu a ~ 75-03, ASCO Solenoid Valves Through discussions with licensee representatives and an examination of facility records, the information and corrective, .

action described in the licensee's response were verified. Th' licensee had received replacement springs and instructions directly from the manufacturer which specified, in detail, the resolution of the clearance and spring problem for Type 8300 and 8302 ASCO solenoid valves.

b.75-04A, Cable Tra Fire - Browns Ferry The action taken by the licensee regarding IE Bulletin No,75-04A is described in Section II, "Details," of this report.

C. 75-05, 0 erabilit of Category I H draulic Shock and Swa

~5 The licensee had received IE Bulletin No. 75-05 and preparation of the response was in progress.

h

~o k

I'

~ ~

~ ~

4. Desi n, Desi n Chan es and Hodifications Design, design changes and modifications were controlled by the procedural requirements of ShUD quality assurance program. The records that document the review, approvaI, installation and testing of seven design changes and modifications to safety related systems or components were examined with the following comments noted:

.a. Design changes were reviewed by the Plant Review Committee and the Hanagement Safe'ty Review Committee in accordance with the requirements of the Technical Specifications. The reviews addressed the criteria described in 10 CFR 50.59.

b. Design chang documentation contained the results of engineering reviews for the specification of applicable codes, standards and acceptance test methods which define the acceptance criteria.

c. The results of the tests performed for acceptance of the design changes and modifications had been reviewed and approved in accordance with the gA program requirements.'est records indicated that the test. results of completed modifications met the acceptance criteria.

d. Procedure revisions were made and approved when the completed modifications changed the operating methods or characteristics of the affected system or component.

Drawing change notices or vendor drawing change notices had been issued to reflect the design changes and modifications on the applicable as-buH t drawings.

5. Procedures Procedures were reviewed for compliance to the requirements of the Technical Specifications and conformance to the guidance in Regulatory Guide 1.33 and ANSI H18.7. Procedures examined consisted of safety related procedures for system operations (10), emergency conditions (3),

abnormal conditions and alarm response {10), and maintenance {3). The results of the review were as follows:

a. The review and approval of procedure revisions were in accordance with the Technical Specifications.

b. The procedures included appropriate Technical Specification limitations- and as applicable required the use of checklists with provisions for signatures and dates.

4

c. Ho Technical Specification revisions have been approved that would require changes in procedures.

d. Temporary procedu're changes (three in effect) did not conflict with the Technical Specification requirements.

6. Review of Safety Limits (SL), Limitina Safet S stem Settinqs (LSSS),

an L>mTtsnq Conditions for 0 erations LCO Records of .reactor operations wet e examined to verify conformance to the following Technical Specifications:

a. Reactor Coolant System TS 3.1.6.1 TS 3.1.6.2 TS 3.1.6.7

b. Reactivity and Power Control TS 2.3.1

c. Core and Internals TS 2.1.2 TS 3.5.2.6

d. Power Conversion Systems

. TS 3.4.1.4

e. Auxi1 iary Systems TS 3.3.1.C

f. Electrical Systems TS 3.7.1

g. Emergency Power TS 3.7.2.A TS 3.7.2.B TS 3.7.2.C TS 3.7.2.D

. h.'mergency Core Cooling System

'TS 3.3.1.8

~ ~ ~

Other Engineered Saf'ety Features TS 3.3.1.D Through direct observation of process instrumentation, reviews of control room logs (november 1974, February and triarch 1975), daily and weekly surveillance records (January through April 1975), and independent calculations of voltage settings for reactor trip set points, the operation of the facility was verified to be in conformance with the Technical Specifications listed above.

7, Inde endent Inspection

'dditional areas of facility operation were examined by the inspector .

Areas examined were as follows:

a. The results of special test, procedure (STP-021} were verified to have been reviewed and approved. The test results indicated that the isolation valves to the Makeup Tank function as described in Amendment 29 to the FSAR dated January 5, 1975, which stated that upon receipt of a safety feature signal the valves would isolate the t1akeup Tank from the high pressure injection pump injection header to prevent a loss of suction to the high pressure injection pumps.

b. The status of tendon surveillance testing was discussed with the cognizant licensee representative. The first year surveillance test was being performed by an outside contractor and was scheduled for completion in approximately two weeks.

The licensee indicated that the vertical and dome test tendons

~

may no. be capable of being completely detens-Ioned as required by Technical Specification 4.4.2.2. The specific reasons for this problem were being investigated by the licensee and would

~

be fully documented in the report of'he tendon surveillance tests. The test results and resolution of any test deficiencie's will be examined during the next scheduled inspection.

8. Power Ascension Test Pronram The power ascension testing has been completed through 92.65 of full power. The reviewed and approved test results for TP 800-40, "Shutdown Outside of the Control Room," were verified by the inspector to have

-- met the acceptance criteria of the test procedure. The test program nH 1 continue at the 100ll power level plateau,fromas required by Technical Specification 3.12, upon approval Licensing to escalate power to 2772 I';Ht. The licensee declared the plant in commercial operation fol power levels up to 92.6! of full power on April 17, 1975.

SECTION II DETAILS

1. Persons Contacted

a. Sacramento ttunici al Utilit District R.'odriguez, Hanager, Nuclear Operations J. Dunn, Supervisory Electrical Engineer

0. llheeler, Electrical Engineer L. Schwieger, guality Assurance Director J. Jewett, guality Assurance Engineer

b. Bechtel G. Jacobson, Electrical Inspector

2. Installation of Fire Sto s on Electrical Cables and Penetration Seals

a. Facilit S ecifications The requirements for the location and installation of fire barriers and compartment boundary seals for safety related cables including the application of fire retardant coatings for safety related cab!es were described in the FSAR Section 8.2.2.10, "Evaluation of the Physical Layout of Electrical Distribution System Equipment," and, in engineering drawings, and construction specifications. Through discussions with licensee representatives and an examination of the above documents, it was determined that the following requirements were imposed:

(1) Fire stops were installed at all locations where cable trays passed through a compartment boundary as indicated on Bechtel Drawing No. 734, "Conduit and Tray Arrangement Plan."

(2) llhere conduits carrying Class I instrumentation cables were installed parallel to and above power cable trays, the conduits were >>rapped with one inch thick insulation thermobestos f'r protection.

(3) Haysite polyester board fire barriers were installed between the crossovers o=. cable trays carrying different channels.

(4) Fire barriers were installed where cable trays or conduits penetrated electrical panels.

t (5) Bechtel Drawing Ho. E-783, Pevision 3, specified that fire barriers were to consist of (1) 1/4 inch polyester board f/ETR-FR-C from the Haysite Division of the Synthane-Taylor Corporation; (2) Kaowool - Bulk A high purity froml Babcock 8 Wilcox; and (3) Flamemastic 71A - sprayable from Dyna-Therm Corporation. I lI (6) The Haysite polyester board was sized to maintain a minimum of three inches and a maximum of six inch overlap of the cable tray penetration in the compartment boundary..

(7) The Haysite polyester board was to be cut to fit around the tray and cable with the remaining voids packed with Kaowool.

(8) Flamemastic 71A was applied to fill the seams between the Haysite, polyester board, seal the edges of the polyester board to the mounting ml.edium, and cover all Kaowool. and exposed cables to a distance of 12 inches from the fire stop. The Flamemastic 71A coating was a minimum of 1/8 inches thick.

b. Fire Barrier Ins ec.ions and Tests Inspections of the initial installation of the fire barriers

'ere performed by Bechtel inspectovs using Bechtel guality Control Instruction Ho. 206, "Installation Inspection of Cable Trays," The results of theso inspections were documented on Construction Ins'pection Data Reports (CIOR). Record copies of the following CIOR's were examined by the inspector and found to document a completed inspection program of initial fire barrier installation.

(1) CIDR - Installation of Five Barriers for Cable and-Conduit Penetration of Electrical Panels and Cabinets.

Inspection performed July-August 1974, (2) CIDR - Installation of Fire Barriers for >lail Penetvations and Tray Separat.'on.

Inspection performed t1ay through October 1974.

(3) CIDR - Ins&llation of Fire Barriers for Cable and Conduit Crossover Separation.

.Inspection performed July through October 1974.

Tests of fire barrier adequacy were performed by Bechtel and St<UD personnel at the Rancho Seco site on April 4-5, 1974.

Three separate tests were conducted in a test stand with various types of cables secured in six inch vertical cable trays. Fire barriers using 1/4 inch Haysite polyester board., Yaowool and Flamemastic 71A were installed on ~he cable trays. Flame temperatures of approximately 1900 F. were applied from a 10 inch ribbon burner at a 30 degree angle from the vertical to the underside of the fire barrier. The flame was applied for 30 minutes in two tests and for one hour in the last test. The test results concluded tha. the fire barrier limits the amount of heat transmitted from the fire on one side to cables on the other side and prevents cables which have been ignited from propagating the flames past the fire barrier. The fire barriers remained intact during all tests conducted, Maintenance and Hodification The maintenance and modification of fire barriers as a result of recent cable changes have remained under the supervision of Bechtel. The procedu "es and specifications including the inspection documentation methods were the sake as those used during initial installation. The licensee's response to IE Bulletin Ho.74-04A indicated that their policies and procedures for maintenance and modification control will be reviewed and changes thereto will be implemented to provide Si1UD with the equivalent requirements currently incorporated in the Bechtel procedures.

Through discussions with licensee .arid Bechtel representatives and an examination of applicable documents, 26 fire barriers were found to have required , e<<~ork as a result oi cable removal or addition. A review of the records verified that the specifica-tions and inspection requirements had been met for the fire barrier reworl; performed by Bechtel.

Visual Examination of Fire Barriers The inspector toured the facility in company with licensee representatives to visually confirm the status of cable tray and penetration seal installation. The visual examination of

0

~ ~

~

-1 2-0' barriers was P erformed in accessible. areas of the facility with the exception of the contairment building since the reactor

'ire was operating at 9'2X of full power. The following observations were made:

l (1) Fire barriers recently modified due to cable changes had been repaired to original installation specifications.

,(2) Cable tray penetrations through floor, ceiling and wall openings in the 480 and 4160 volt switch geav rooms, A, B, C and D battery vooms, diesel generator rooms, cable shafts and cable spreading area contained fir barriers.

(3) Flamemastic 71A was verified to have covered the specified area of the fire barrier. tleasurements for a 12 inch application along the cables and cable tray to a thickness of 1/8 inch weve made on randomly selected fire barriers in each compartment.

I (4) Crossover polyester fire barriers had'een installed.

(5) Carbon dioxide f:ve extinguishing systems weve operational.

The carbon dioxide emitting nozzles were unobstructed and the smoke and heat sensors positioned to detect cable tray fives.

~ e. IE On Bulletin Response April 23, 1975, the licensee submitted a response to IE Bulletins Hos. 74-04 and 74-04A. The review of policies and procedures described in. the licensee's response have commenced. Monthly reports will be provided to indicate the status of open items descvibed in their response. The review and resultant. changes in policies or procedures were scheduled for completion by the licensee on August 1, 1975.

~ U.- S. t(UCI YhK 8" bUMj.uh 'e~ixsvui.i

~ .. 0 }'ICE GF INSPECT OH AiXD ENFORCE."KNT

~ REGION V iIE Inspection Report No.

Socket No. 50-206 2244 Valnut Grov v IS. cense, No.DPR 13 Rosemead, California 917 0 Priority pacility San Onofre Unit 1 Category

~ca tion Cam Pendleton, California Type of Facility P'rTR (450 K<e, 1347, ii":lt Special, Announced (I' Type of Inspection 1

Dates of Inspection April 21-23, 1975

~

Dates of Previous Inspection April 7-10~ 15-17 & 21-23, 1975 r v7 Principal Inspector .

' / '

~0 0 R. ' odds, eactor Inspector Accompanying Inspectors Date Date Other AcconPanying Personnel: None RevS.med by ~/i/~

G. S. Spencer, Chief, Reactor 'Testing, & Operations Br.

g ~

Enforcement Action

~ I None Licensee Action on Previousl Identified Enforcement Action Not applicable Unusual Occurrences Not applicable Current Findin s The licensee has examined lE Bulletins Nos. 75-04 and 04A and determined that the only action required vill be to expand existing administrative and maintenance procedures to emphasize salient points of the bulletins.

This will be accomplished within 30 days. Pire barriers for vertical cable trays were found to be of asbestos sheet with Fla. emastic 71A (Dyna-Therm Corp.) applied above and below the barrier to spaces between cables.

fill the .

Examination of cabling and the use of fire barriers disclosed the following items that will be re-evaluated by the licensee and acted upon accordingly.

Ao Smoke detectors in the chem-feed and lube oil area have been shielded from cabling and lube oil filters by blast shielding installed for protection from pipe whip during the recent refueling outage. (Paragraph 4)

B. The fire barrier between the 4 kv cable spread room and the chem-feed and lube oil area consisted only of galvanized sheet through which the cable trays pass, without an air stop or use of fire retardant material on the cabling. (Paragraph 4)

C. Fire barriers had not been installed on two vertical cable trays in the 4 kv cable spread room as required by construction specifica-tion. (Paragraph 4)

Mana ement interview The results of the special inspection were discussed with Hr. Ottoson and principal members of the plant staff. A followup telephone call was made on April 25 to obtain the licensee's evaluation of the inspector's observations. The following commitments were proffered by the licensee.

0 le The smoke detectors will be relocated to assure optimum coverage.

(Paragraph 4) 20 Zt appears that additicnal protection is desirable between the 4 kv cable spread room "and the chem-feed and lube oil area. Engineering assistance has been requested. (Paragraph 4) 30 F9re stops will be installed on the vertical cable trays in the cable spread room as soon as the required barrier materials have been obtained. (Paragraph 4)

I I

The administrative procedures pertaining to maintenance and modifica-tion activities will be strengthened within 30 days to specif'cally bring attention to the need to maintain fire barriers and compart-ment boundary seals. (Paragraphs 5 and 6)

~ ~

DETAILS Persons Contacted H. L. Ottoson, Plant Superintendent J. H. Curran, Plant Engineer

, R. R. Brunnet, Supervisor Plant Operations J. F. Bankovich, Supervisor of i'faintenance P. Penseyres, Nuclear Engineer Sco e of lns ection The special inspection included an examination of (1) construction specifications for location and installation of fire barriers and compartment boundary seals for safety related cables and utiliza-tion of fire retardent coating on cables, (2) licensee's action pursuant to XE Bulletins Nos. 75-04 and 75-04A, and (3) tour to determine extent of conformance to overall fire barrier requirements.

Construction Specifications Fire barriers were added as 'a result of the cable tray fire in the plant in 1968 in accordance with Engineering Change Notice No. 222 (Plant Revision No. 68-78) as stated in Section 4.2.9 of the FSAR.

The specifications require fire barriers to be provided where cables pass from one area to another and on vertical trays with more than 10 foot change in elevation.

The specifications require the barriers to be constructed of asbestos type sheet material with a Dyna-Therm Flamemastic 71A coating applied three inches above and six inches below the barrier on vertical trays. The spaces between cables at the barrier were to be sealed with Flamemastic 71A i~iastic.

Attached to the report is a Technical Bulletin by Dyna-Therm Corporation that enumerates the properties of Flamemastic 71A.

Examination of Fire Barriers A tour of the facility, including the interior of the containment vessel, was conducted to examine the location and installation of fire barriers and the utilization of fire retarding coating (Flame-mastic 71A) for safety related cables. As a general rule, the licensee had adhered to the construction specifications for fire barriers. However, the following deviations were identified.

0,'

ai Smoke detectors in the cheu:-feed and lube oil area have been shielded from cabling and lube oil filters'y blast shielding installed for protection from pipe whip during the recent refueling outage.

The fire barrier between the 4 kv cable spread room and the chem-feed and" lube oil area consisted only of galvanized sheet through which the cable trays pass, without an air stop or use of fire retardant material on the cabling. This was also the case in the other 4 kv switchgear room.

Co Pire barriers had not been installed on vertical cable trays 60V60.and 60V61 in the 4 kv cable spread room as required by construction specification.

5. Maintenance and Modification Procedures Maintenance and modification procedures do not specifically require adherence to the construction procedures for fire barriers. General policy dictates that systems disturbed by these activities be returned to their original state. The construction engineer for the pipe whip modification stated that only one of the cables that pass through a fire barrier was disturbed. In this instance, the sealant was still malleable and was re-formed around the cable after it was replaced. The administrative, procedures will be strengthened in this area, according to the licensee.

6. Status of Licensee's Review of IE Bulletins 7S-04 and 04A The licensee has examined the subject bulletins and determined that the only action required will be to expand existing administrative and maintenance procedures to emphasize salient points of the bulletins. This will be accomplished within 30 days.

0

~

v r v',

~~>>vr~ v~~

~

e>>rseeaa~e,>> e~>>s>>r>>seve >> eve VLCh~lxCP.L I U". h""ViN

.January 1970 - 003

-~

~ I FLAMEN',573C 710 GYGVEM MYNA-THERMFLAMEMASTIC coatings are compounded of thermoplastic resinous binders, flame retardant chemicals and inorganic incombustible fibers.

VVPLCM P CP".HY)I:5 FIRE RESISTANT CHARACTERISTICS h

No bum<<through of 1/16" coating after 15 minutes exposure to propane torch. Flame temp. 2050 F. Distance from forch 2".

e>>

EFFECT ON AMPACITYOF CABLES l

Reduction of current-carrying capacity in various tests o group cc>>vs cs ceased vvI I I I F Iorriemosi c ranges Irom I "/o fo 10>>% depending on thickness and tesr procedure. Maximum temperature increase on cable jacket 2-1/Pro. Test reports on request

~

I ~

EFFECT ON CABLE JACKET None VfFATHER RESISTANCE No adverse effects after 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> in Atlas Twin Arc Weather-Ometer, DLTS-X; U.S. Testing Company Test Report No. LA 16880-2.

TOXICITY Waterbase - odorless - non-toxic WEIGHT PER GALLON h

h F I am em as t ic 71A Sprayab I e 11. 0~/Gal.

7..1A Mastic 'lamemastic 11.4</Gal.

Cjjisrarad'Tradareark ". Parcel Applied Par Page 1 of 2

~ ~'vie>>ehre ., ~>>shave>> ~

.... r, ~ -, ~ ~

~ S' h V s ~

I ~

~ ~ ~ +~ <~3 f...) C3.X'B..i C3+j YECf~iP~kCD,r BULf.L"Vt."-4

~ ~

~ ~I

'January 1970 - 003 SOLIDS I

Flamemostic 71A Sprajable 64.4%

Flamemastic 71A Mastic 67.3%

FLASH POINT Flamemastic 71A Sprayable None Flamemastic 71A Mastic None HARDNESS OF'DRY FILM Flamemastic 7IA Sprayable 86 Shore A Ffamemastic 71A Mastic 86 Shore A

'OS TEMPERATURE PERFORMANCE

' Specimens: 2 cable sections, 3/4" diameter, coated with

~ ~ ~

~ )/8" thick Flamemastic 71A.

~

' 1 Test 'escription Results

" Thermal Cycle .12 hrs. at -100 F followed Pa:ses 10 cycles by 12 hrs. at 75 F unaffected Thermal Shock 1 hr. at 300 F followed Passes '10 cycles immediately by 1/2 hr. in unaffected

-90oF alcohol bath C performance after Low Temperature Tests: All specimens displayed the same performance characteristics exhibited by coated cables which had not been subjected to low temperature testing.

! SPECIAL, taGYE Flomemastic 71A, like all waterbase materials must bc protected from freezing during shipment and storage.

e '<<onn<<~on presented herein is based on data believed to be reliable, ttowcver, The Dyno-Therm Corporation insuree that your results will be the some as those described, os the ccnditions of use orc beyond our control ~ 'onnot page 2 of 2

U. ST NUCLEAR REGULATORY COHHXSSXON OFFXCE OF XNSPECTXON AND ENFORCEHENT REGION XV XE Inspection Report No. 50-267/75-04 Docket No. 50-267 Licensee: Public Service Company of Colorado License No. DPR-34 Facility: Fort St. Vrain -Nuclear Generating Station Category B Location: Platteville, Colorado Type of Licensee: Power Reactor (HTGR 330, HHe-GGA)

Type of Inspection: Routine, Unannounced Dates of Inspection: April l7-24, l975

, -Dates of Previous Inspection: Harch 24-25, l975

,Xnspector: - A . Piv-a. <. ~g g/7>

T. F. h'esterman, Reactor Inspector Date

]h li a l

Accompanyanp Inapcctot>gk E9 E, Ga iardo, Reactor Inspector 7s'ther Accompanying Personnel: None a

Q7 Reviewed By: r Cg C'ate G. L. Hadsen, Chief, Reactor Construction and Operations Branch

SEflfARY OF FINDINGS Enforcement Action A. Items of Noncom liance

1. Contrary to 10 CFR 50, Appendix B, Criterion U; the Final Safety'nalysis Report, Appendix C.3 and guestion 7.4; and Specification 1-N-2, "Electrical Installation Work, Part 2":

(a) Vertical cable tray fire stops between floors were not specified in the construction specifications 1-N-2 and

, are not installed.

(b) Fire stops in the Reactor Confinement Building and Diesel Generator Room vertical cable risers have not been installed.

(c) The fire stops for horizontal cable trays were not installed as specified in that none of the fire stops were found to be completed units.

(d) Ventilation openings in which the vent duct passes into the battery room were not sea"ed.

(e) The fiber fill through has not been installed in conduits the auxiliary electrical equipment passing and switchgear room walls.

(f) The fire barrier installed in the bottom of the penetration into the auxiliary electrical panel floor was not as specified by Specification 1-N-2, in that the material specifications were not maintained.

(g) Separation of test cables in the cable spreading room has not been maintained.

(h) Potential flammable material is located in the cable spreading room.

(i) The battery room door was found open into the 480 vital switchgear room.

(DETAILS, paragraph 8.2.b)

(continued)

0 An abnormal occurrence (failure of lA diesel generator) on October 18, 19?4 had not been reported and the required action had not been taken by the licensee in accordance with TS AC 7.6 and TS AC 7.3. (DETAILS, paragraph B.l.c)

Contrary to Criterion U, Appendix B, 10 CFR 50:

J (a) Administrative approval was not obtained prior to commencing maintenance activities, as specified by ADH-12.

(b) Quality Assurance inspection procedures have not been established as required by QAP 1200.

(DETAILS, paragraph B.l.d(1), and B.l.e)

Contrary to TS AC 7.5(b), safety related maintenance activities had been completed without an approved procedure. (DETAILS, paragraph B.l.d(2))

Contrary to Criteriqn XVI, Appendix B, 10 CFR 50, deficiencies reported from the two QA audits of maintenance activities (which were conducted in Nay 1974) have not been responded to by plant personnel. (DETAILS, B.l.e)

Contrary to Criterion XII, Appendix B, 10 CFR .50, the licensee did not calibrate the buffer/1kelium dryer knockout pot level alarm following installation. (DETAILS, paragraph B.8.c)

Contrary to 10 CFR 50.59 and 10 CFR 50, Appendix B, Criterion XXI, facility changes are being'rocessed as Temporary Change Requests without performing a safety analysis or providing design control requirements. (DETAILS, paragraph B.10.b(1))

Contrary to Technical Specification AC 7.5.e, temporary changes were not being processed as required for Standard Operating Procedure SOP 42 on 4/16/75 and temporary changes to Surveillance Test Procedures. (DETAXLS, paragraphs B.10.b(2) and B.3.b(2))

Contrary to Technical Specification 7.1.3.d.9, violations of internal procedures identified by the licensee's QA were not forwarded to the Nuclear Facility Safety Committee for investigation. (DETAILS, paragraph B.10.b(5))

Contrary to Technical Specification 5.1.2.d, Surveillance Test.

Procedure 5.1.2.bd specifies reserve shutdown system low pressure alarm set points outside of Technical Specification requirements and as'a result eight reserve shutdown system alarm switches (continued)

0, are set less than the Technical Specification limi.t for this system. (DETAILS, paragraph B.3.b(1))

Surveillance Test Procedures were issued from the period of December,21, 1973 to December 10, 1974 without Plant Operation Review Committee review as required by TS AC 7.5.d. (DETAILS, paragraph B.3.b(3))

12. Audits by the Nuclear Facility Safety Committee had not been conducted as required by TS AC 7.1.3.d.4 and 7. (DETAILS,

,paragraph B.4)

13. Contrary to Technical Specification AC 7.1.3.d.12, only proposed tests or experiments considered to be safety signif-icant are being forwarded to the Nuclear Facility Safety Committee for review. (DETAILS, paragraph B,5)

14. Contrary to 10 CFR 50, Appendix B, Criterion III and the FSAR, Appendix C.2; the Helium bottles (37) associated with the reserve shutdown system were not seismically restrained.

(DETAILS, paragraph B.10.b(4))

15. The licensee's Semiannual Report, dated January 1975, did not provide the detailed information on maintenance activities in accordance with TS AC 7.6(c). (W'7AILS, para " ph B.l.",'

16. Contrary to TS AC 7.4(b) (8) and QAP-1200, the licensee had not prepared the required QA records 'for maintenance activities.

(DETAILS, paragraph B.l.d(5))

17. . Contrary to Criterion XVII; Appendix B, 10 CFR '50; the licensee failed to maintain the records required by Administrative 'and QA procedures with respect to inspection of maintenance activities and entries in auxiliary logs. (DETAILS, paragraph B.l.d(3),

B.lo.b(3))

18. Contrary to Criterion XI, Appendix B, 10 CFR 50; records were not available relative to functional tests performed prior to returning a systemlcomponent to normal service, following 6 of 18 safety related maintenance activities reviewed by the inspector. (DETAILS, paragraph B.l.d(4))

Licensee Action on Previousl Identified Enforcement Actions Not inspected.

('~ (continued)

None.

Other Si nificant Findin s Current Unresolved Items 7504-1 PCRV Coolin S stem b,T Based on the results of B Series testing (through sequence 7), the licensee is reviewing the adequacy of this system to maintain PCRV Cooling System AT's less than TS limits during escalation to power. (DETAXLS, paragraph B.6.a(l))

7504-2 Load Cell Data The load cell acceptance criteria is being reviewed. The licensee stated that a possible problem with two.cells may exist. (DETAILS, paragraph B.6.a(2))

7504-3 The on~c ~

Vvgrv 7504-4 Backu (AL1~ATT c'.

Bearin guua4it ue) ~

Seismic Restraints Mater VCll.QQLOIPll ~

S stem licensee is reviewing possible interplay between the Helium Circulator r w Jl ~ tl q g for Class ri

~ <,

w w

~ ~

I Bottles Other gas bottles associated with Class I Systems (i.e., circulator shut-down seal and brake) are being reviewed by the licensee to determine con-formance with the seismic criteria for Cl'ass I Systems. (DETAILS, para-graph B.10.b(4))

7504-5 Possible Unusual Event The licensee is evaluating the reportability of a failure of a bearing water accumulator isolation valve as an unusual occurrence. (DETAILS, paragraph B.l.c)

Status of Previously Identified Unresolved Items

'e 7503-2 Possible Ca abilit to Flood Pelton Wheel Cavit The licensee is continuing to review this item. (DETAILS, paragraph 7)

Mana ement Xnterview A management interview was held with Mr. Swart, Superintendent, Nuclear Production and other plant staff on April 24, 1975.

c: (continued)

A. General The areas inspected, as reported in the Details Section of this report, were summarized.

B. Xtems of Noncom liance The apparent items of noncompliance. with the Commission's requ9.rements were discussed as identified in the Fnforcement Section of this report.

r The inspector stated that a corporate management meeting would be requested in view of the significant number of items identified.

(continued)

REPORT DETAILS A. Persons Contacted Public Service Com an of Colorado (PSC)

F. Swart, Superintendent, Nuclear Production L. Brey, Superintendent, Operations F. Mathie, Superintendent, Maintenance D. Warembourg, Quality Assurance Director

~

J. Reader, Resident Engineer L. McInroy, QA Supervisor R. Kishiyama, Electrical Engineering W. Hillyard, Training, Coordinator J. Simpson, Electrical Engineering D. Rogers, Operation Supervisor E. llill, Senior Results Engineer W. Franek, Results Engineer J. Liebelt, Plant Electrician General Atomic (GA)

J. Zannot, Projett Manager D. Glenn, Electrical Engineering F. Bain, Mechanical Engineering B. Re ort'f Subjects Inspected

1. Maintenance Sco e of Ins ection Maintenance activities on safety related systems and components were selectively reviewed to verify that maintenance activities were conducted in accordance with approved procedures, regulatory guides and industry standards and in conformance with'echnical Specification (TS) requirements.

The inspector selected for review two maintenance activities from each of nine major system areas. The records of these activities were reviewed in detail to verify that:

(1) the limiting conditions for operation were met while the component or system subject to the maintenance was removed from service (2) administrative approvals required by the licensee's admin-istrative procedures were obtained prior to initiating the work yC (continued).

(3) the maintenance activities were accomplished using approved procedures (4) the maintenance activities were inspected in accordance with the requirements of the licensee's Quality Assurance Plans (QAP)

(5) the components or systems affected by the maintenance were functionally tested prior to their return to an operating status (6) the quality control. records required by the licensee's administrative procedures and QAP's for each maintenance activity had been prepared and was retained in accordance with the TS

b. Re ortin of Haintenance Activities Xn preparing for this inspection effort, the inspector reviewed the licensee's Semiannual Report (dated January 1975) for the period July 1 through December 31, 19?4. The inspector had planned to select the maintenance activities for review from those listed in the above report. The inspector found that contrary to the .requirements of Technical Specification AC 7.6(c) the above semxannua rcport "'d not co"..'tain the required detailed information on sarety related maintenance activities.

c. Plant Trouble Re orts Since the, details of safety related maintenance activities were not available in the semiannual report, the inspector selected many of the maintenance activities he would review from the Plant Trouble Reports (PTR) at the site.. PTR's provide a mechanism by which licensee's personnel can inform management of an equipment or system problem. The PTR can also be used to document the corrective maintenance which was taken and the subsequent inspection and functional testing performed.

The inspector reviewed all completed PTR's from August 1974 through April 1975 for the following systems:

~Sstem No. S stem Title ll '2 Reactor Vessel and Internal Components Control Rods and Drives 18 Fuel 21 Primary Coolant System 22 Secondary Coolant System 23 Helium Purification System 92 Electrical

'93 Controls and Instrumentation (continued)

0 During the review of the PTR's, the inspector found that on October 18, 1974 .a PTR (10-220) was initiated to report a trip of the lA and lB engines to diesel generator 1A. The PTR indicated that the engines had tripped after approximately fifteen (15) minutes of operation due to high water tempera-ture. Further investigation into this incident disclosed that both engines had been given a quarterly inspection during the period October 14 through 16, 1974. The inspector reviewed the completed check-off lists for both engines and noted that the engines had been functionally tested after the inspection. The maintenance work report was completed and signed by the operator conducting the test on October 16, 1974.

The operating logs on October 17, 1974 indicated that the clearance had been'emoved from the engines and an entry was made indicating that the 1A diesel generator was operable

. and in standby. The fact that the 1A diesel generator had been declared operable and subsequently failed constitutes an abnormal occurrence as defined by Technical Specification (TS) 2.1(f). Contrary to the requirements of TS AC 7.6 (Non-Routine Reports) this abnoxmal occurxence was not reported to the NRC Regional Office, and the additional actions required by TS 7.3 in the event of an abnormal occurrence were not taken.

The inspector also found that on December 24, 1974 a PTR (17-368) was init. ated which xeportcd thc failure of YalYe na PlY 0 J-8 to op " cu to a 8 tuck so 1 euviu ~ This valve isolates the bearing water accumulator tank from its circulator after the brake and seal have been set. The licensee is reviewing the reportability of this item as an unusual event in accordance with TS AC 7.6.

S

d. Results of Maintenance Activit Review The maintenance activities which wex'e reviewed during this inspection and the results of the review are shown in Table I.

These activities were selected fxom the Semiannual Report of July 1 December 31, 1974 and from the plant trouble reports which were reviewed at the site. This review disclosed several items of noncompliance with NRC requirements and conditions of the Technical Specification. The following items of noncom-pliance were found during this review:

(1} Criterion V of Appendix B to 10 CFR SO requires, in part, that: "Activities affecting quality shall be prescribed by documented instructions, procedures, .... and shall be accomplished in accordance with these instructions, procedu~

Fort St. Vrain Administrative Procedure ADN-12 (khintenance and Repair Procedures), Section 2.1 and 2.2, establishes the requirements for the preparation and (continued)

0 approval of maintenance procedures. Thi procedure also establishes the mechanism for providing administrative approval to initiate maintenance activities. Contrary to the above requirements, administrative approval to initiate the work had not been given on thirteen (13) of the eighteen (18) maintenance activities reviewed (Table I).

Technical Specification AC 7.5(b) and administrative procedure ADM-12 requires that procedures shall be developed and approved prior to implementing safety related maintenance. Seventeen (17) of the eighteen activities reviewed were safety related and (18)'aintenance thus required, written procedures. Contrary to the above requirements, thirteen (13) of the seventeen (17) activities had been 'completed without an approved procedure.

Fort St. Vrain Quality Assurance Plan QAP-1200 (Mainte-nance or Repair of Nuclear Class'I Systems) and Quality Assurance Instruction QAI-11 (Delegation of Specific Responsibilities) establish specific xequirements for the inspection of safety related maintenance activities by an individual other than those,who performed the mainte nance activity. Contraxy to Criterion XVII of Appendix B to 10 CFR 50, documentation did not exist to vexib~

performance of the required inspection fo" thirteen (13}

of the eighteen (18) maintenance activities reviewed.

Licensee representatives interviewed stated that mainte-nance activities are inspected by the foreman or a senior technician, but these inspections are not always documented Fort St. Vrain Administrative Procedure ADM-12 and Quality Assurance Plan QAP-1200 establish requirements for post maintenance tests or operations prior to returning a component or system to service. QAP-1200 also establishes the requirement for documenting these tests. Contrary to Criterion XI of Appendix B to. 10 CFR 50, and the above procedural requirements, no records exist to verify that six (6) of the eighteen (18) maintenance activities reviewed (Table I) had been functionally tested prior to returning the system/component to normal service. Licensee representatives claimed that the'functional tests were conducted, but no records exist to verify the test performed.

Section 7.0 of Quality Assurance Plan QAP-1200 establishes the requirements for the QA reports and records to be maintained for safety related maintenance activities'.

TS AC 7.4(b)(8) further.r- requires that the records of maintenance activities be retained for the life *'rinciple (continued)

of the plant. Contrary to 10 CFR 50, Appendix B, Criterion V and the above requirements, all of the required QA records had not been prepared for any of the eighteen (18) maintenance activities reviewed.

e. ualit Assurance As past of this inspection effort, the inspector interviewed members of the licensee's QA Department to determine the extent of the QA 'involvement in maintenance activities.

Quality Assurance Plan QAP-1200, Section 6.0, requires assurance inspection procedures shall be prepared to that'uality cover routine, non-routine and special maintenance activities.

The inspector found that contrary to these requirements and those of 10 CFR 50, Appendix B, Criterion V, no quality assurance inspection procedures had been prepared as of the dates of this inspection.

During this QA review, the inspector also found that in Hay 1974 the QA Department conducted two audits of the licensee's maintenance in accordance with Quality Assurance Audit Proce-dures QAAP-1201 and QAAP 1203. The results of the audits were reported to the licensee management, but as of .the dates oz this inspection management had not responded.to the. audit reports and correct've action on the deficiencies no"cd ."."-" not "" "..

ccmplc"d. A QA Department representative stated that several informal memorandums had been sent to management reminding them of the fact that no action had been taken on the audits.

Criterion XVI to Appendix B of 10 CFR 50 requires tha" measures shall be established to assure that conditiions adverse to quality are promptly identified and corrected. The failure to respond and correct the deficiencies noted in the above audit reports is contrary to the above Appendix B requirements.

Fire Protection

a. Area of Xns ection This. inspection was conducted to determine compliance with 10 CFR 50, Appendix B, Criterion V with respect to fire protection for electrical equipment. This inspection included:

Review of facility construction specifications to determine that requirements in conformance with the FSAR, Appendix C.3 (which delineates fire protection requirements in accordance with 10 CFR 50, Appendix A, Criterion 3).

E (a) Location and installation of fire barriers and compartment boundary seals for safety related cables.

'I (b) Application and extent of application of fire retardant coating for safety rela'ted cables.

(continued)

(2) Review maintenance and modification procedures against the above requirements.

(3). Visual examination of cables and vital areas.

(4) Status of Licensee's response to IE Bulletins 75-04 and 75-04A.

(5) Other fire protection requirements of the FSAR,, Appendix C and Question 7.4, Amendment 19, concerning cable separation.

b. Ins ection Findin Review of Construction S ecification Re uirements The inspector found that the Sargent and Lundy Specification 1"N-2 (Issue A, dated January 18, 1969) for Electrical Installation Work, Part 2, and associated construction detail drawings do delineate fire stop requirements and application of fare retardant coatings; however, fare s tops on vertical cable tray runs between floors had not been specified. The FSAR, Appendix C, states that, "Adequate fire stops are used with all major cableways between floors on vertical runs."

This item was identified as an item of noncompliance at the exit meeting.

(2) Review of Maintenance and Modification Procedures Class I system changes processed through PSC Engineering Department are reviewed in accordance with ENG-1 for separation and segregation.

The inspector could find no maintenance or modification requirements with respect to maintaining fire barriers, compartment boundary seals, or application of fire retardant coatings. This item will be followed up during the review of the licensee's reply to IE Bulletin 75-04A.

(3) Ins ection of Cables and Vital Areas Sargent and Lundy Specification 1-N-2 (Issue A, dated January 18, 1969), Supplement 1 (concerning cable separation), and associated detail construction drawings were used in determining the licensee's conformance with 10 CFR 50, Appendix A, General Design Criterion 3, Fire .

Protection. The FSAR, Appendix C.3, delineates the licensee's commitment to conform to Criterion 3 of Appendix A. The cable separation requirements identified in (continued)

0 Appendix C.3 of the FSAR are further defined in Question 7'.4 of the FSAR, Amendmcnt 19.

(a) Vertical Cable Txa Risers Reactor Buildin The detail construction drawings (such as E-43, Revision J; E-41, Revision B; and E-42, Revision H, "Cable Trays Reactor Building Sec's and Det's")

specify that fixe stops axe to be installed in the Reactor Building vertical risers in accordance with Sargent and Lundy Standard STD-EA-176. STD-EA-176 specifies that a fire stop will consist of two feet of insulating material (Owens-Corning Fiberglas, Corp., Thermal Insulating Wool or equivalent) with Plamemastic 71 or other suitable material to hold the insulating material in place.

The inspector did not find that fire stops had been

.installed in any of the vertical cable tray risers in the Reactor Building. This item was identified at the exit meeting as an item of noncompliance. The licensee is initiating corxective action.

(b) Reactor Buildin to Auxiliar Buildin Cable Seals Detail construct'on dxawin E-140, Revision F Gpecif ies tha t tLansi t sleeves, as manufactured by Nelson Electric Division of Sola Basic Industries, are to be installed in multiple clusters at the point the cables pass through the Reactor Building wall into the Auxiliary Building.

The inspector found that sleeves are installed as required.

(c) Horizontal Cable Tra s I

Detail construction drawing E-54, Revision K, specifies three-eighth inch Harinite Sheets are to be cut to fit after cables are installed and placed on each side of the wall. The void on each side of the tray and between the sheets are to be packed with an inorganic fiber material.

The inspector found no horizontal tray fire stops installed in accordance with drawing E-54. The "as installed" fire stops varied from tray to tray (Harinite sheets on each side of the wall, Harinite sheets on one side, and in at least two cases, no Naxinite sheets). The inspector found no cases in (continued)

which the inorganic fiber material had been installed. The inspector stated at the exit meet-ing that this item was considered an item of non-compliance. The licensee is initiating action to install the fire stops as required by construction specification 1-N-2.

Cable Tra Risers

'd).'ertical The inspector could find no construction specification requirements for vertical cable tray risers through floors of vital rooms such as the cable spreading room.

A riser fire 'stop was specified in detail construction drawing E-54, Revision K, for the cable riser out of the diesel room ceiling. E-54 specified a one-fourth inch tfarinite sheet is to be placed approximately six inches below the top of the ceiling, with a Plamastic 871 per Sargent and Lundy Standard-175, to a fill of minimum of two inches above the cei3.ing. A cover plate was specified to seal the opening the tray passed through at the top of the ceiling.

The inspector could find no fire stops installed in the cable tray risers passing through the cable spreading room floor. Neither the cover p3.ate or fire stops were installed in the two diese3. ruvm risers. Tne inspector stated at the exit meeting that this item was considered an item of noncompliance. The licensee is initiating corrective action.

(e) Ventilation Duct to Batter Rooms The inspector found the ventilation opening into the battery room was only partially sealed by the ventilation duct entering the battery room. Detail construction drawing kf-122, Revision K, specifies that wall openings in which vent ducts pass are to be sealed by 2"X2"X<"

angle on all four sides.

The inspector stated at the exit meeting that this was considered an item of noncompliance. The licensee is initiating corrective action.

Conduit Sleeve and Cable Installation Detail construction drawing E-54, Revision K, specifies that (for a typical conduit sleeve and cable installation through the Auxiliary Electrical Equipment and Switchgear room walls after all cables are pulled) each conduit is

,(continued)

filled with inorganic fiber material. The inspector verified by telephone on Hay 2, 1975 to the site, that the fiber fill had not been installed as required.

The licensee has initiated corrective action.

~Auxiliar Electrical ui

'g)

E mant Room Panel Floor Seal and Fire Barrier Detail construction drawing E-45, Revision KK, specifies that the cables, entering through the Cable Spreading Room floors into the bottom of the Auxiliary Electrical Equipment Room, panels, are to pass through an Ebony Board covered with 'a two inch thickness of insulating wool (as made by Ovens-Corning or approved equal) and with an upper surface coating of Chicago Hasters Company Stymastic Coating.

The inspector found that .cc-.,trary to drawing E-45, a one-half inch asbestos board coated with one-half inch of Scotchcast Brand Resin No. 16 had been installed in place of the prescribed barrier. The licensee could produce n'o record of an approved deviation from specification requirements. This item was identified as an item of noncompliance at the exit meeting.

(4) Statu~ of Lice<<set 's Res unse ro TE Bulletin 75-04 and 75-04A The licensee's letter, dated April 18, 1975 (included as Attachment E to this report), has been received by IE: XV. The letter includes a schedule for completion of the licensee's review of each item.

(5) Other Fire Protection Re uirements

• (a) Se aration of Nonessential Cable Associ'ated with Test

~Pro ram The FSAR, Appendix C.3 (in response to 10 CFR 50, Appendix A, Criterion 3) states that "Redundant power, control, or instrumentation circuits are physically separated or protected to prevent damage, as a result of fire, ..." The FSAR, Question 7.4 states in part.

with respect to essential cables in the cable spread-room, "... the cables are routed from the tray system to the control boards with a minimum separation of six inches between redundant circuits. Where this physical separation cannot be maintained, due to limited space,.

one cable is enclosed in asbestos zipper tubing to maintain segregation of the redundant circuits."

(continued) I

Question 7.4 states further that with respects to nonessential circuits, "Nonessential circuits are routed in the same trays as essential circuits; and follow the separation criteria for essential cables in that tray or section."

The inspector, during a tour of the cable spreading room, noted several areas where temporary cable had been installed for the test program that did not meet the separation criteria stated above. Asanexample, in one area there were test cables which crossed within less than six inches of permanent redundant cables terminating in the Loop 1 and Loop 2 Coolant system instrument panels. Asbestos zipper tubing had not been installed.

The licensee concurred in the inspector's finding and stated at the exit meeting that separation in the cable spreading room was being reviewed. Some zipper tub-ing was installed prior to the completion of the inspection and additional zipper tubing was being ordered.

Potential Flammable Haterial in Cable S readin Room 10 CFR 50, Appendix A, Criterion 3, states in part isc t y uLTqq fs gyes 4 ~'hIep t 4wusv aivaacoaaavva a

<<2 su.a li1 calcu cd r J oao ~I an s4 Illcl

~ ~ . ~ i .

I cl JAl budl*

- ~ ~ ~

be used whenever practicable throughout the facility, particularly in areas containing critical portions of the facility...". Further, the FSAR, Appendix C.3 (in response to Criterion 3 of Appendix A) states in part, "The facility is constructed making maximum practical use of noncombustible and fire resistant material."

The inspector, during a tour of the cable spreading room, noted approximately eight pieces of wooden plywood cabinets, tables, and stands associated with test equip-ment. Also, two wooden desks and a drawing/print file were noted. The inspector stated at the exit meeting that the introduction of flammable material in the cable spreading room was not consistent with 10 CFR 50, Appendix A. or the FSAR, Appendix C.

Batter Room Door The FSAR, Appendix C (in response to 10 CFR 50,<<

Appendix A}, states in part that, "h'here the possibility of an explosion exists in redundant equipment, ..., suit-able separation and/or missile shielding is provided to prevent an explosion in one unit from damaging the other".

(continued)

4 0

The inspector, during a tour of the 480 Vital Switchgear Room, found the door open to one of the two battery rooms.

The inspector stated at the exit meeting that leav-ing the battery room door did not assure adequate missile sI>ielding or protection from fire/explosion.

3. Calibration/Surveillance Testin

a. Areas Xns ected

.The inspector verified, that properly approved calibration/

surveillance test procedures, as required by Technical Specification (TS), have been provided for the following areas:

PCRV Overpressure Safety System Surveillance Pressure Switch/Alarm (TS SR5.2.1(c)l)

Tendon Mire Surveillance (TS SR 5.2.2.a and b)

Control Rod Drive Surveillance (TS SR 5.l.l.a)

~

Calibration, of PCRV Overpressure Safety System (TS SR 5.2.1(c)l)

Calibl 8'tion oz Reserve Shutdown $ "stc> 0 P -~fl (TS SR 5.1.2.d)

The inspector verified that associated procedures contained (as appropriate) required prerequisites, test instrumentation, acceptance criteria, and operational checks prior to returning equipment to service for accomplishing the above required tests.

Current test results were reviewed by the inspector for confor-mance with Technical Specifications and for completion of reviews by the Licensee Supervisory personnel.

b. Xns ection Pindin s The inspector's review of this area is incomplete. Additional TS surveillance requirements will be reviewed at a subsequent inspection.

(1) TS Surveillance Procedure SR 5.1.2.bd TS Surveillance Requirement 5.1.2(d) requires calibration once a year of reserve shutdown actuating pressure lines low pressure alarm and states, "Operable reserve shutdown hoppers=-shall have an actuating bottle pressure )

1500 psig."

(continued)

"18-Contrary to this requirement, Surveillance Procedure;..

5.1.2.bd established alarm limits of 1500 + 30 psig (wl>ich would allow alarm settings as low as 1470 psig) and further during the annual calibxation performed 4/7/74, eight switches are recorded as less than 1500 psig (minimum 1490 psig). The inspector stated at the exit meeting that this item was considered an item of noncompliance, (2) Tem orar Chan es TS Administrative Control 7.5.e states that, "Temporary to procedure prepared for a) and c) (1) above, 'hanges which do not change the intent of tne original procedures, may be made with the concurrence of a shift supervisor and one other person holding a senior operator's license. Such changes shall be documented and subsequently, reviewed by the PORC. Final approval or disapproval will be by the Superintendent-Operations."

Cantraxy to this requirement, the inspector was informed that temporary changes (which do not result in permanent changes) to surveillance procedures are not reviewed, by the PORC or approved by the Superintendent-Operations. Further, the inspector found no record of prior approval, by a va I $ t C ~ '\

~ I IJUQ%

t 'hhVt't JUVa

~

~

~ '1 AHA Vll%q Vlhl hA4 ((lid operator, of Temporary Changes. The inspector found that 0,

IlGL J0 JJl \ Ildt U bt ljloL J

10 Clel VL Surveillance Test Procedure 5.2.2.a-X, Tendon Mire Surveil-lance,. contained temporary changes to steps 10 and 16 for the 12-13-73 test that were not processed as required.

(3) Review of Surveillance Test Procedures The inspector found that the Plant Operations Review Committee (PORC) minutes do not indicate PORC review of the initially issued Surveillance Test Procedures, from time of licensing until 12/10/74, as required by TS AC 7.5.d, which states in part, "Procedures prepared for a) and c)(1) above shall be reviewed by the Plant Operations and Review Committee." The licensee did demonstrate that (during the December 10, 1974 PORC meeting i'Pi5) review of the surveil-lance test procedures was conducted and documented. The licensee did state that prior review of surveillance test procedure by the PORC (as a body) had not occurred; but, the licensee did demonstrate that the review and approval signatures on. each surveillance test procedure are within one of the required quorum (TS AC 7.1.2;c three members plus the chairman or designated alternate).

(continued)

This item is identified as an item of noncompliance for which no response is required based on the subsequent PORC review of the Surveillance Test Procedures.

4. Audit Records (Reference IE:IV Inspection Report 50-267/75-02)

The Technical Specification (TS) AC 7.1.3.d.4 states that the Nuclear Facility Safety Committee responsibilities include, "Conduct audits no less than semiannually of facility operators for compliance with internal rules, procedures, regulations, and license require-ments, including Technical Specifications", and TS AC 7.1.3.d.7 states that, "Follow-up action, including re-audit of deficient areas, shall be taken as required."

Contrary to the above requirements, the inspector did not find that audit schedules have been established, or audits conducted by the NFSC as required.

The inspectox did discuss with the licensee the interfacing of the NFSC and the licensee's QA Organization as i.t relates to the performance of the TS prescribed audits.

This item was identified at exit meeting as an item of noncompliance.

5. NFSC Review of Pro osed Tests and E>:oeriments (

Reference:

IE Inspection Report 50-267/75-03)

Technical Specification (TS) AC 7.1.3.d.l2 states that it is the responsibility of the NFSC to, "Review proposed tests and experiments and. their results."

Contrary to the above requirement, the inspector was informed by the licensee personnel that the NFSC reviews only those tests ox experiments considered to be safety significant. The licensee has stated his intent to amend this TS requirement, but a proposed change has not been submitted.

The inspector identified Gulf Atomic RT 320 (dated 12/20/74) which requested a test to investigate the count rate response af the start-up channels with the detectors wrapped with Cadium, as an example.

This test, although it involved safety related instruments, was

', determined by the PORC to be nonsafety si'gnificant and therefore, not subject to NFSC review prior to conducting the test.

The inspector stated, at the exit meeting, that although it was licensee's intent to submit a proposed change, this item was con-sidered an item of noncompliance with the TS.

(continued)

A0

6. Plant Status

a. B Series Testin B Series Testing has been complete through Sequence 7. The licensee has stated that additional testing will require increasing power beyond the present 2% limitation. The licensee indicated that the following problem areas have been identified during the testing program:

At a core outlet t'emperatux'e of 530oF, AT temperatures across the PCRV Cooling Coils of approximately 30 F, have been experienced in individual coolin coils associated with the top head and CRD penetxations. The licensee states that the average of the outlet versus the inlet is within the 20oF bT allowed by TS ~<.2.15.c.

(2) Load Cells Acceptance criteria for, tendon relaxation is being reviewed against current load cell data. The licensee stated that a possible problem may exist with respect to two load cells.

V uaI m\

~ MR ~

as

~

(1) Backu Bearin plater S stem The licensee has placed a hold on testing beyond 2% pending the resolution of problems experienced during testing the back-up bearing water system. (UE 50-267/75-05). The licensee stated that possible interplay between the two primary coolant loops is being investigated.

(2) Purification S stem Trouble has been experienced in the secondary side of the gas to gas heat exchanges with condensation of moisture.

The source of moisture condensation has been traced to a pexiod of time concurrent with the moisture ingress into the PCRV. Possible modifications to this system are being reviewed from the aspect of being able to decrease the time required to dry the system out.

7. Xndication of Possible Pelton Cavit Floodin The inspector confirmed, during discussions with plant and vendor personnel, that entry of bearing water into the steam turbine cavity and piping is predictable during self turbining and during pelton (continued)

0 operation vieh the Nitrogen Pressurizing Syst: em shutdorrn. The licensee stated that the bypass around the steam turbine cavity steam trap is manually opened during these periods of time. The effects the steam trap has on the operation of the Nitrogen Pressurizing System, with respect to pressure equalization betveen the Pelton Cavity and its associated drain system, remains unresolved.

The licensee seated that float type steam trap is being considered.

8. Abnormal Oocurrence Re@ore - AO 75-07/7A "Moisture In ress and Reactivit Anomal " (Reference IE Inspection Repore 50-267/75-03)

Status of licensee corrective action with respect to AO 75-07/7A is as follows:

a. Moisture Drain Pots/Level Alarm Bufi'er/Hid-Buffer Instruments The inspector verified completion of the installation of the drain poes for the bul'fer/mid-buffer instruments and 'oisture associated alarms per Field Change Notice (FCN) 2624/Work Authorization (MA) 1780 on 3/17/75. The inspector also verified completion of cold construction testing (CCT) by the licensee's electrical maintenance and results testing personnel.

Cold construction testing includes verification of alarm function and calibration.

b. kemoee See Point Control for ehe High Pressure Separator Flow Controller The licensee stated that material delivery is scheduled for 5/8/75. This item is incompleee.

C ~ Knock-out Pot for Buffer/Helium Dr ers The inspector verified completion of the installation oi the knock-out poe for the Buffer/Helium Dryers per FCN 2628/4'A 1784, Revision A, on 3/17/75. The inspector also verified completion of CCT. The inspector found that contrary to 10 CFR 50, Appendix B, Criterion XII, CCT did not include a verification of level switch calibration; however, a calibration was performed subsequent to the inspector's finding and prior to the completion of this inspection. The licensee stated, during the exit meeting, that this instrument alarm is not considered to be a Class I instrument per the definieion of the FSAR, Section 1.4.4 and therefore, is not required by the licensee's QA program eo require calibration. The inspector stated at the exit meeting, this matter would be revieved further. In a subsequent phone call on 4/29/75 to the licensee's QA personnel, the inspector stated that an instrument may be considered safety related and.not be seismic.

The inspector also stated that although the licensee had taken action with respect to this single item, it appeared that there may be a generic problem with calibration of safety related instruments.

(continued)

d. PCRV Sur e Tank ho Indication The licensee has stated that material delivery is scheduled for 5/15/75..

This item is incomplete.

e. Level Indicators and Hi Level Alarms/Pelton Turbine Drain

~cavit The inspector verified the completion of the installation of the Pelton Turbine Drain Cavity per FCN 2587, Revision A/bA 1677A on 3/15/75. The inspector verified the completion of CCT.

Modification and Procedure Change/Drain Valve Pelton Cavit The inspector was informed by the licensee that during evaluation of this item it was determined that opening of the drain valve provided only a limited flow path for leakage.

The licensee stated that in place of this modification, the main Pelton Cavity outlet isolation valve control circuitry is to be modified to allow leaving this valve open during shutdown or self turbining, and that SOP 21-02 would so be revised. Material delivery is scheduled for 5/8/75.

This item is incomplete.

g. Review with 0 eratin and Staff Personnel

'he inspector verified that a training session had been conducted

. on 3/18/75 as committed in AO 75-07A for Shift Supervisors, Reactor Operators and Assistant Reactor Operators.

e AO 75-03/3A "Failure of Moisture Monitors ta Tri at Safet S stem

~pattie " (

Reference:

XE Xnapectkon Report 50-267/25-03)

Status of corrective action with respect to AO 75-03/3A i.s as follows:

a. EG&G 440 Moisture Monitors The licensee stated that the EG&G 440 moisture monitors are on order. Delivery was estimated to be 2-3 weeks.

This item is incomplete.

b. Heat Trace of Sam le Line Installation is 'in progress. The inspector did find that

'erformance of Cold Construction Testing (CCT) was indicated (continued)'n

as not being required on the Field Change Notice/Pork Authorization located in the Control Room. The licensee stated at the exit meeting that CCT will be performed.

This item is incomplete.

co Technical S ecification Chan e

-The licensee has submitted a revised Technical Specification (TS) by letter dated 4/ll/75 to Division of Reactor Licensing.

The licensee stated that the intent of the TS is to assure that sample line 'temperature does not prevent a moisture monitor safety system trip.

This item is incomplete.

d. Procedure Cora letion The Standard Operating Procedure SOP-23 has been revised to include the analytical method for determining the moisture concentxation in the primary coolant system as described in AO 75-03A.

The inspector was informed that the licensee is also develop-incr an overal I pl ant admi nist.native svAssrfosvg gaol c4uA4 Qpl 4J 4Ap J4>>rls ne ws4 ~

~

responsibilities and detail actions in the event of moisture ingress.

This item is incomplete.

10. Review of Shift Lo s and 0 eratin Records Current 0 erations The inspector audited the Station Log and Operating Logs for completeness of entries including identification of abnormal conditions, and that log book reviews are being conducted by the plant staff. The inspector also audited the Operations Order Book, Temporary Change Request Forms and problem identi-fication reports (Station Log Summary, Plant Trouble Reports, and Quality Assurance Deficiency Reports) to determine con-formance with Technical Specification requirements. A plant tour and observations of housekeeping, monitoring instrumentation, alarm annunciator, operator personnel manning requirements, radiation controls, fluid leaks, piping vibrations, valve position, and equipment lockout tags were conducted by the inspector. Discussions were held with plant personnel regard-ing training. The conduct of plant tours by supervisory personnel was verified.

(continued)

The following administrative procedures were reviewed by the inspector during inspection of the above items:

ADN-" 06 Administrative Procedure for Use of Trouble Report Form ADH-07 Administrative Procedure for. Use of Radiation Work Permit (RMP)

ADH-OP Administrative Procedure for Use of Station Log ADH-10 Book How to fill out Administrative Procedure for Hechanical/Electrical Clearance ADH-11 Administrative Procedure for Use of Radioactive Waste Release Forms ADH-22 Administrative Procedure for Temporary Changes to Instruments (P&E)

ADH-24 Administrative Procedure for Operations Order Book OP-05 Administrative Policy for Use of Operations Order Book OP-06 Administrative Policy for Use of Log Sheets and Data Logger QAI-10 Quality Assurance Deficiency Reports Outstandin Items

() ~~L'he inspector found that facility changes are being made by use of Temporary Change Requests (TCR/ADH-22). These temporary changes are not associated with an approved test or surveillance procedure. A safety analysis has not been performed in accordance with 10 CFR 50.59. Design control measures, in accordance with 10 CFR 50, Appendix B, Criterion III, were not apparent. ADH-22 (Administrative Controls for making temporary changes) requires authorization by the Plant Superintendent and approval by the Plant Electrician or Senior Results Engineer. Design control or safety analysis is not required. Example of TCR's are as follows:

(a) TCR 1-48 The Exhaust Air Damper pneumatic controls were modified on 1/21/75 following discovery that an Exhaust Stack

~

High Radiation Trip closed the service building isolation damper only halfway.

(b) TCR 3-40 PPS circuitry was modified on 3/15/75 in that pin d on CC2A902 Pll (connector) was pulled to prevent (continued)

-25"

-HV 2204 (Pneumatic control associated with Hain Peedwater Supply to Emergency Feedwater Header) from going open when power to the A logic train is secured during surveillance testing.

(c) TCR 3-54 Pill lines were installed on 3/23/75 to provide the ability to fill the constant leg of the Pelton Cavity level alarms (LlS 21494, 21495, 21496, and 2l497).

(2) Tem orar Procedure'han e (Standard Operating Procedure (SOP) 42 Service Mater System)

The inspector found that one entry in the Station Log Book for the 8-4 watch on 4/16/75 (Assistant Reactor Operators Narrative) stated that the Shift Supervisor directed that service water inlet temperature be lowered to 50-SSoF.

SOP 42, Step 2.3.1, requires that "The Service water inlet header will be maintained at 65oF, or as close as possible, year round." The inspector did not find that a temporary change had been processed as required by Technical Specification TS AC 7.5.e) (concurred by Shift Supervisor and Senior Operator, review by PORC and approval by the Superintendent). The lic nsee initiated a change prior to the completion of this inspection, the inspector stated at at the exit meeting that no reply to this item of noncom-pliance would be required.

(3>

During the review of plant auxiliary logs, the inspector noted several incomplete log sheets. The summary of these is as follows:

Plant Protective S stem Lo 1 and 2 4/8/75 Second and third shifts partially complete 4/10/75  ; Second shift incomplete 4/12/75 Second shift incomplete Reactor Buildin Lo 1 4/12/75 4 a,m., 8 a.m., 12 a.m., 4 p.m., 12 p.m.,

entries incomplete 4/13/75 8 a.m., 4 p.m., 8 p.m., 12 p.m., entries incomplete 4/14/75 8 a.m., 4 p.m., 8 p.m., 12 p.m., entries incomplete (continued) .

4/15/75 8 a.m., 4 p.m., 8 p.m., 12, p.m., entries incomplete 4/16/75 8 a.m.) 4 p.m., 8 p.m.j 12 p.m., entries incomplete 4/17/75 8 a.m., 12 a.m., 4 p.m. 12 p.m., entries incomplete 4/18/75 4 a.m., 8 a.m., 12 a.m. 4 p.m., 12 p.m.,

entries incomplete 4/19/75 8 a.m., 12 a.m., 4 p.m. 12 p.m., entries incomplete 4/21/75 4 a,.m., 8 a.m., 12 a.m. 4 p.m., 12 p.m.,

entries incomplete OP-06 Administrative Policy for use of Log Sheets and Data Logger states that "4%en any system or portion of a system is in operation, the log sheets provided shall be filled out in their entirety. For those data blocks provided for equipment not in operation, a "No" shall be recorded."

The inspector stated at the exit meeting that, this was an item of noncompliance.

(4) Seismic Oualiiication of Reserve Shutdown'System Hel'um Bottles Contrary to Criterion XXI, Appendix B, 10 CPR 50, and the PSAR Appendix C, the inspector, during tour of the facility, identified that the Helium Bottles (37) associated with the reserve shutdown system were not apparently seismically restrained, The licensee has initiated corrective action and the failure of the reserve shutdown system bottles to meet seismic requirement is to. be reported as an Abnormal Occurrence'in accordance with the Technical Specifications, Section AC 7.6.

The, bottles were found by the inspector to be supported by a small chain with no support rack or other seismic restraints. Review of other bottles associated with Class X systems is being conducted and is considered unresolved by IE:IV. The failure of the shutdown system bottles to meet seismic requirements was identified at the exit meeting as an item .of noncompliance by the inspector.

(continued)

(5) Nuclear Facilit Safet Committee (NFSC) Review of Violations The Technical Specifications (TS), Section 7.1.3.d.9, states in part that the NFSC is responsible to "Insure itself that it receives all information necessary for it to fulfillits obligations and respon-sibilities on a time scale such that it can take effective action." During the review of recent QA Deficiency. Reports, the inspector found certain of these reports relating to violations of internal- procedure are not being forwarded to the NFSC for investigation as required by TS; Section 7.1.

These include the following:

QADR l13 The licensee's QA organization identified violations of security and access control requirements.

'QADR 116 and 117 The licensee's QA organization identified violations of Internal Vork Procedure-1 relating to material control.

~fiDJt 119 The licensee's QA organization identified violations of QA Procedure 1100 and Administrative Procedure AD~fi 14 relating to failure to provide calibration procedures for three of 16 Class I Instruments.

This item was identified at the exit meeting as an item of noncompliance with TS.

f's TABLE I YAINTENANCE'ACTIVITIESREVIEWED SOURCE OF LCO ADJOIN APPROVED 'UNCTIONAL gA MAINTENANCE ACTIVITY INFORMATION NET APPROVAL PROCEDURE INSPECTED TEST RECORDS PCRV rupture disc replaced with Work Request dumm 610 (YZ ll-l~ Yes No No (1) Yes No (2) No Repaired wiring error in accumulator PTR 2-200 clrcui't (CN-20) Yes No No No (2) Yes No t Cleaned orifice valve and seals Work Request in CRD's 392 & 401 CWP 17 Rev 1 Yes Yes Yes Yes Yes No Replaced CRD Penetration PTR 9-89 I

Connector Yes No No (1) No (2) Yes No Fuel'Block Paint Removal No maint doc avail Yes No No No (2) NA . No Replaced valve PCV 11258 in reserve SD s stem PTR. 1-290 Yes No No (2) Yes No Rewired Electromatic Relief Valve 22168 PRT 12-95 Yes Yes NA No (2) . No (2) vo Adjusted Trip Point of Power Ran e Channels f 3 and Pi8 PTR 2-182 Yes No No No (2) Yes No Replaced Coil and Relay in 1A PHC (Purification Com ressor) PTR 3-301 Yes No No No (2) No (2) No Replacement of Porcelain Insulators in Con. ectors PTR 10-89 Yes Yes Yes Yes Yes No (3)

Re aired Al Bus in LC lA CN-21 Yes Yes Yes Yes iNo  !

D/G Trip Hechanism Inspection Work Request and Re air 510 Yes No No No (2) No (2) No Inspection of 480 V Breaker Procedure in Emer enc Power Distribution PHE-9 Yes Yes Yes No (2) No (2) No

SOURCE OF LCO ADMIN APPROVED FUNCTIONAL QA MAINTENANCE ACTIVITY INFORYiATION Yes APPROVAL PROCEDURE INSPECTED TEST RECORD~

14. Replaced Contactor for D/G Hotstarts PTR 11-322 Yes No Ho No (2) No (2) No (".

15. Replaced HEPA PTR's 2-19 Filters and 4-95 Yes No No Yes Yes No

16. Modified Emergency Feedwater FCN-FSV-GA Control Lo ic 2619 Yes No No (1) Nb (2) Yes No

17. Replaced Logic Board for Loop Ins t alla tion Shutdown Logic Instructions Logic Board Subs titution Yes Ho Ho (1) No (2) Yes No (3

18. Replaced Logic Board for Circulator Installation Shutdown Logic Instruction Logic Board Substitution Yes No No (1) No (2) Yes No (3 (1) Procedure used, but not approved by Plant Superintendent (now call Superintendent, Nuclear Production) as per ADM-12.

(2} Licensee representatives indicated that these activities were inspected and tested, but no documentation exists to verify same.

(3) Only an equipment nistory card entry was made.

LEGEND FOR TABLE I S bol Used *S bol Desi nation Al Aluminum CN Change Notice CRD Control Rod Drive D/G Diesel Generator FCN Field Change Notice LC Load Center (Electrical)

LCO 'imiting Conditions for Operation PCRV Prestressed Concrete Reactor Vessel PTR 'lant Trouble Report QA Quality Assurance SD Shutdoom

Uc ST NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV XE Inspection Report No. 50-298/75-07 License No. DRP-46 Licensee: Nebraska Public Power District Category B2 Facility: Cooper Nuclear Station Docket No. 50-298 Location: Nemaha County, Nebraska Type of Licensee: BhR-2381 Mft - 778 ERe

~

Type of Inspection: Special, Announced Dates of Inspection: ofay 5-7, 1975 and May 16, 1975 Dates of Previous In pection: March 17-19, 1975 Principal Inspector:

J E. Gag iardo, Reactor Inspector'at Other Accompanying Personnel: Hone Revieved By:

G. L. Madsen, Chief, Reactor Construction and Operations Branch

1 SUlMARX OF PllH)INGS Enforcement Action A. Noncom liance Xtems

1. Violations Hone

2. Xnfractions (a) Contrary to Criterion V, Appendix B, 10 CFR 50, and Amendment 15 to the licensee's FSAR, six (6) discrepancies with the cable separation criteria and one discrepancy involving the use of combustible materials in fire barriers for cabl~ runs were found.

(DETAXLS, Sections l.b and l.c)

(b) Contrary to TS 3.2.B, time delay relays IfS-TDR-K5A and HS-TDR-K5B in the ADS logic system failed to actuate within the setting limits of the above specification. The licensee reported this item in AO Report No. 50-298-75-10. (DETAXLS, Section 5)

(c) Contrary to TS 3.7.B.l, the Standby Gas Treatment system was not operable at rated flow conditions on March 22, 1975. The licensee reported this item in AO Report No.'0-298-75-11. (DETAILS, Section 5)

3. Deficiencies None None Licensee Action on Previousl Identified Enforcement Items Not inspected Desi n Chan,es Hone Unusual Occurrences None 4

( (continued)

C

~

3 Other Si nificant Findin s A. Current'Findin s Deviations None 20 Unresolved Items

'ritten 'Polic P

'7507-1 'on 'Electr'ical 'Cable 'Seal 'Testin'he licensee has no written policy (or pr'ocedure) to require that the .

review of maintenance and modification activities will assure the installation (or reinstallation) and testing of electrical cable seals.

(DETAXLS, Section l.a)

~ w 7507-2 Written Polic Limitin 'the 'use 'of '0 'en 'Flames or 'X,nition Sources The licensee has no written policy (or procedure) which prohibits, the use of open flames or ignition sources for. leak testing. (DETAXLS, Section l.a) 7507-3'ritten Polic to Defer Haintenance Until Shutdown Periods The licensee has no written policy (or procedure) which provides guidance on deferring, until a shutdown period, any maintenance, construction and modification work which might affect the safety of the plant or its ability to shutdown and cooldown, (DETAILS, Section l.a) I

'7507-4 Written Polic for Considerin . the Affects of Nearb Cablin The licensee has no written policy (or procedure) which establishes the attention to 'be given to affected and nearby. cabling and p"'ping during maintenance and modification activities. (DETAILS, Section l.a) 7507-5 Control of Combustible Haterials Controls have not been established in Procedure 1.6.8 for several types of combustible materials which are frequently found in the plant.

(DETAILS, Section l.a) 7507-6 Written Polic on the"Use of a Honitor'in Areas'Ad'acent to Work The licensee has no written policy (or procedure) which provides guidance as to when a monitor. will be stationed in areas 'adjacent to maintenance or modification work. "(DETAXLS, Section l.a)

(continued)

7507-7 Use of !<ater on Electrical Fires The licensee's fire fighting procedures do not address the fact that water may be used as the ultimate suppression medium for electrical fires of suGficient intensity. (DETAXLS, Section l.a) 7507-8. Fire Barriers in Reactor Buildin The licensee has not installed, nor does he plan t'o install, fire barriers in the numerous cable penetrations between floors in the Reactor. Building. (DETAXLS, .Section l.b)-

7507-9 A Refresher Trainin Records of QA refresher training were not available to the inspector during the inspection. (DETAILS, Section 6) 7507-10 Minimum ualifications for A Personnel Minimum qualification requirements have not been established for gA Department personnel. (DETAILS, Section 6)

B; Status of Previousl Re orted Xtems

1. Deviations Not inspected

2. Unresolved Items 7414-1 Xm lementation of 0 erator Reaualification 'Pro,ram The licensee has administered the annual comprehensive examination; completed the operator performance evaluations; reviewed abnormal and emergency procedures with all operators; and established a long-range training plan. This item is closed. (DETAILS, Section 6.a)

Mana ement Xnterview An exit interview was conducted with Hr. L. C. Lessor on Hay 7, 1975 and with Hr. K. L. Heyer on Hay 16, 1975. The following individuals were also present at the Hay 7 exit interview:

K. L. Heyer, NPPD R. E. Milbur, NPPD B. Hurray, NRC I

i

~ ( (continued)

(', Mr. L. C. Lessor was also inforaed inspection during of the findings of the May telephone conversation with the inspector 16, 1975 s

a oa May 17.

The following topics were discussed during the May 7 exit interview (significant comments by the inspector and/or licensee representatives axe noted where applicable):

1. Licensee's Res onse to IEB 75-04 and IEB 75-04A The inspector restated his concern about the lack of specific written guidance for reviewing maintenance and modification activities. The licensee representative stated that he did not believe such written guidance was necessary. The inspector said that this item would be identified as an unresolved item.

2 ~d Fire Barriers and Cable Se aration for Electrical Cables The inspector outlined the scope of this inspection effort and pointed out the discrepancies which were found. The .inspectox said that these items would be identified as deviations from FSAR commitments. The licensee representatives stated that the foam material ~ould be removed from the cable tray penetrations and the cable separation discrepancies would be corrected. They noted that the discrepancies which were most accessible would be corrected as soon as pv sible, but the discrepancies which were not readily accessible would be deferred'to the next scheduled outage of significant duration. The licensee representatives also stated that they did not believe the fire barriers in the cable runs of the Reactor Building were necessary and did not plan to install same.

The inspector said that this item would be identified as an unresolved item'and would be referred 'to his management for resolution.

3 '

0 erations at Reduced Power Levels Status of Power Ascension Testin The inspector noted the tests which had not been completed or reported.

The licensee representative said that these tests would be closed out by a revision to Startup Report Supplement II which would be submitted by Hay 15, 1975.

5~ Followu on IEB 75-03

6. ~Tralnin e

The d.nspector seated that refresher training in QA had not been given to supervisory personnel within the required two year interval follow-ing initial training. The licensee representatives said that they thought that the refresher training had been conducted and would try to locate the records of the training. (In a subsequent telephone

(. (continued)

conversation, a licensee representative said that the refresher training had been conducted and the records of this training were available for review; The inspector said that he would identify this item as an unresolved item pending his review of the training records indicated.)

7. Chan es in Ke Personnel The licensee representative informed the inspector that Hr. R. Clark (Shift Supervisor) had terminated employment and Hr. R. D. Creason, formerly a Unit Operator, had been promoted to Shift Supervisor.

The following topics were discussed during the May 16 (and May 17 telephone conversation) exit interview:

1. Cable Se aration in the Re .ctor Dr sell The licensee representative acknowledged the discrepancies found during the inspection in the drywell and stated that these items could not be corrected until an extended outage period. The 'inspector said that this item would be identified as a deviation from FSAR commitments.

2. Batter Room and Vital Switchpear Ventilation On Hay 20, 1975, the inspector informed the licensee in a telephone conversation with Hr. K. L. Heyer that the six discrepancies in the cable separation and the discrepancies involving the combustible material in the fire barrier has been identified as an item of non-compliance with Criterion V, Appendix B, 10 CFR 50 and would be reported as an infraction.

~ c (continued)

~

7 ea REPORT DETAILS List of Personnel Contacted Nebraska Public Power District. NPPD)

L. F. Bednar, Electrical Engineer K. L. Berrett, Site Manager R. Brungardt, Shift Supervisor R. D. Creason, Shift Supexvisor W. F. Gilbert, Training Coordinator H. M. Green, Acting Quality Assurance Supervisor M. E. Halkens, Instrument Technician G. R. Horn, Shift Supervisor H. A. Jantzen, Instrument 6 Control Supervisor A. N. Kugler, Engineering Supervisor L. C. Lessor, Station Superintendent K. L. Meyer, Assistant Station Superintendent D. Norvell, Electrical Foreman .

C. R. Noyes, lfaintenance Supervisor J. L. Peasley, Shift Supervisor Peterson, Assistant Reactor Engineer 1'.

R.

R. W. Seir, Quality Assurance Specialist J. R. Sheely, Administrative Supervisor J. E. Stresewski, Reactor Engineer

p. V. Thomason, Operations Supervisor R. E. Wilbur, .Chemistry 6 Health Physics Supervisor M. G. Williams, Shift Supervisor Burns and Roe Inc.

J. Bowles, Assistant Resident Construction 'Ifanager T. Hayes, Job Engineer L. Howell, Civil Engineering Supervisor

. G. Larson, Electrical Job Engineer Sub ects Ins ected

1. Cable Fire Prevention a.* Licensee's Res >onse to IE Bulletins 75-04 and 75-04A On March 25, 1975 the NRC Office of Inspection and Enforcement (IE) issued IE Bulletin (IEB) iNo. 75-04, entitled "CABLE FIRE AT BROWNS FFRRY NUCLEAR POWER STATIOii". This bulletin provided licensees with preliminary information concerning a fire which occurred on March 22, 1975 at the Tennessee Valley Authority's Browns Feery site. The bulletin also requested the following actions of selected licensees:

I'continued)

II

1. "Review your overall procedures and system for controlling construction activities that interface with reactor operating activities, with particular attention to the installation and

'esting of seals for electrical cables between compartments of the reactor building, e.g., control room to cable spread-ing room.

2~ "Review the design of floor and wall penetration seals, with particular attention to the flammability of materials.

3~ "Evaluate your procedures for the control of ignition sources which may be used for leak testing or other purposes in areas containing flammable materials.

4. "Report to this office, in writing within 20 days of the date of this Bulletin, the results of your reviews or evaluations regarding items 1 through 3 above."

Cooper Nuclear was not one of the selected licensees requested to

.take action under IEB 75-04 at the time it was first issued.

On April 3, 1975 the Office of Xnspection and Enforcement issued XEB 75-04A (same title as that of 75-04) which provided additional information concerning the Browns Ferry fire. XEB 75-04A required all licensees to carry out the actions requested in XEB 75-04 and outlined additional actions to be taken by licensees as follows:

l. "Because the occurrence appears to have resulted from modifications being made to an operating unit, all power reactors with operating licenses should address the actions requested in Bulletin 75-04 as well as the actions described below.

2~ "Review your policies and procedures relating to construction or maintenance and modification work to assure that activities which might affect the safety of a unit in operation, including the ability to shut down and cool the unit are properly controlled.

Your review should consider particularly your policy on deferring construction, maintenance or modification work on a unit until a shutdown period except for emergency maintenance vital to continued safe operation or safe shutdown of the unit, 3~ "Review your policies and procedures to assure that for construction or modif'ication and maintenance activities during plant operation, particular attention is given to the following areas:

"a) The degree of safety significance of affected and nearby cabling and piping.

"b) The use and control of combustible materials.

(continued)

0

't "c) The use and control of equipment that may be an ignition source.

"d) The assignment of personnel, knowledgeable of plant arrangement and plant operations, whose sole temporary responsibility is monitoring the safe performance of construction or maintenance and modification work, including attention to otherwise unattended areas adjacent to the

'ork areas.

"e) Provision of installed or 'portable equipment to provide the monitoring personnel with 'prompt communication with the operating staff in the control room.

"f) Provision of adequate fire prevention and fire suppression equipment, installed or portable, for the following locations:

"(1) Areas where work is being performed.

u(2) Areas where. occurrence of a fire has high safety significance, even though the probability of occurrence is relatively small.

"g) Recognition that a fire, even one involving electrical equipment,'ay, if of sufficient intensity r'equire water the ultimate suppression medium.

as

4. "Review your emergency procedures to assure that'onsideration for.

'alternate methods o'f accomplishing an orderly plant shutdown and

'ooldown provided in case of loss of normal and preferred

" alternativeare shutdown and cooldown systems for ariy reason (e.g. a fire). In this connection, assure that the minimum information necessary to assist the operators in such shutdown actions, the minimum protection system actions required (e.g. scram) and the spectrum of alternative paths available to the operators to supply cooling water and.remove decay heat dependent on plant conditions are included in your emergency procedures.

"Report to this office, in writing, within 20 days, of the date of thi:s Bulletin, your schedule for review in each of the above areas.

"Upon completion of your review, provide this office with the results of these reviews and the schedule for accomplishment of any revisions to your policies and procedures, and any proposed changes to the facility; and the date by which the changes arc scheduled to be completed. If this latter date is more than 30 days after 'the date of the initial report, provide a monthly =

sumuary report detailing your prog'ress in the review and/or proposed procedure or facility modifications. Reports requested (continued)

0 t

, ~

by'Bulletin 75-04 may be incorporated with the initial response to this Bulletin."

The licensee's initial response 1/ to the above bulletins was submitted within the specified time period. The licensee's response letter presented, their position and proposed action for each of the items of action outlined in the two bulletins.

During this inspection, the inspector .reviewed the actions taken by the licensee and discussed with several licensee representatives the positions taken by the licensee on those items for which no specific action is indicated. The licensee's response to and their actions taken for each of the items of action requested in the subject bulletins are summarized below.

In response to Item 1 of the action requested of licensees in IEB 75-04, the licensee stated that they had reviewed their procedures for controlling construction activities and believed them to be adequate. The inspector found that the procedure which, the licensee has for controlling construction activities is Administrative Procedure 1.7'entitled, "Station Maintenance". The primary construction activities currently underway at the Cooper Station are performed by employees of Burns and Roe, Inc. who are constructing the Augmented, Radwaste Facility which is adjacent to the, existing Radwaste Building.

By letter dated April 18, 1975, NPPD (K. Meyer) advised Burns and Roe (J. Bowles) of their responsibility to work within the procedural requirements of Procedure 1.7. This fact was acknowledged by letter dated April 25, 1975 from E. Kuchera (Burns and Roe) to K. Meyer.

~ s Although Procedure 1.7 is acceptable for controlling construction activities in general, the procedure does not.specifically address

-the installation and testing of seals for electrical cables between compartments of the reactor building.

This fact was discussed with licensee representatives who stated that attention to the installation (or reinstallation) and testing of seals for electrical cables would be assured by the engineering, quality assurance, and operations department reviews of maintenance activities required under Procedure 1.7. They felt that this was an unwritten policy for personnel in the above departments and that specific written guidance was not necessary. The lack of specific guidance in this area was identified as an unresolved item..

In response to Item 2 of IEB 75-04, the licensee indicated that high and low density cellular concre'te had been used to fill penetration openings and urethane foam painted with fire retardant intrumescent paint had been used to fill smaller holes and the ends of conduit.

This fact was generally corroborated by the inspector. Details of the inspection of penetration seals is contained in part b of this section.

(continued) 1/ NPPD letter Jay H. Pilant to E. M. 1Ioward, dated April 23;- 1975.

0

'The licensee's response to Xtem 3 of IEB 75-04 indicated that they had evaluated their procedures for the contxol of ignition sources.

They stated that they do not use an open flame or an ignition source for leak testing and that their procedure entitled. "Hazardous Haterial Control" will reduce the probability of fires in areas containing flammable materials. This procedure was reviewed in detail during this Inspection. The results of this review are discussed under Xtem 3.b to IEB 75-04A. The fact that the licensee does not use an open flame or an ignition source for leak testing is an unwritten policy. The licensee representatives interviewed did not feel that a wxitten policy .or procedure was necessary to prohibit the use of open flames or ignition sources in 1'eak testing. They felt that the supervisors who review maintenance and modification procedures were aware of this policy and would prevent the use of open flames or sources. This item was identified as an unresolved item. 'gnition In responding to Xtem 2 of the action section of IEB 75-04A, the licen-see stated that policies and proceduxes relating to construction, maintenance, and modification work have been reviewed and are con-sidered adequate to assure that safety related activities are properly controlled. The licensee noted that Administrative Procedure 1.7 (Station lfaintenance) and 1.13 (Station Design Changes) provide control of construction/maintenance and modification activities respectively. The inspector reviewed these procedures and found that they were acceptable for the general control of these activities, but no specific guidance was given in either procedure concerning a policy of deferring the above activities (except for emergency maintenance) unitl a shutdown period. The 1falfunction/4'oxk Request (KJR), established by Procedure 1.7 and used for all maintenance activities, does provide for the designation of a maintenance priority, but the priorities which may be selected to not include a "defer until shutdo~m" category. Licensee representatives indicated .

that it is Cooper Station's unwritten policy to defer (when possible) safety related maintenance until a shutdown period. They did not believe that a written policy or procedure to defer these activities was necessary. The absence of a written policy in this area was identified as an unresolved item.

In the licensee's response to Item 3.a of XEB 75-04A, they stated that, "The plant policies and procedures for reviewing the degree of safety significance of affected and nearby cabling and piping during con-struction, modification, or maintenance work are now considered adequate.

By the implementation of bib'R's and/or minor design change procedures for all required work, safe practices can be assured."

The procedures referred to in this response are Administrative Proce dures 1.7 and 1.13. As noted in the above evaluations, these proce-dures provide acceptable guidance for the review and control of maintenance/construction and modification activities, but there exists no specific written guidance for the supervisory or other individuals (continued)

who review these activities to assure that the review includes the degree of s'afety significance of affected and nearby cabling and piping. The licensee representatives'nterviewed did not believe that written guidance was necessary to assure this type of review.

They were of the belief that all of the reviewers of maintenance and modification activities were cognizant of the potential hazards to cabling and piping during such activities and would consider these potential hazards during their review. The absence of specific written guidance in this area was identified as an unresolved item.

In responding to Item 3.b of IEB 75-04A, the licensee ..tated that "Procedure 1.6.8, Hazardous Material Control, provides for the safe use and storage of all combustible materials at CNS."'he inspector reviewed procedure 1.6;8 and found that it did provide for the control of the following combustible materials:

(1) Gaseous hydrogen (2) - Acetylene (3) Fuel gas (4) I'uel oil (5)'irconium turnings, borings, filings, chips or dust The inspector noted that the above procedure did not include controls for such additional combustible materials as:

(1) Lubricating oils

'(2) Paint (3) Wood and paper. products (4) Rags Licensee representatives stated that these materials should also be controlled under Procedure 1;6.8. They indicated that Procedure 1.6.8 would be modified to provide controls for the above listed items.

This item is identified as an unresolved item until Procedure 1.6.8 is modified.

In the licensee's response to Item 3;c of IEB 75-04A he stated that, "Procedures and policies concerning the use and control of equipment that might be an ignition source have been reviewed and are considered adequate."

The procedures which control cutting (torch) and welding operations are Administrative Procedures 1.7.3 (Cutting and Welding Permits) and 1.17 (Administrative Procedure for.'Special Process Control). The (continued)

F inspector reviewed these procedures and found them acceptable for the control of cutting and welding operations. As noted in the previous evaluations, the licensee has no written policy or procedure

'to control the use of open flames or other ignition sources for leak testing.

Xn responding to Item 3.d of IEB 75-04A, the licensee indicated that personnel knowledgeable of plant arrangement and operations would be assigned'to monitor unattended areas adjacent to work only 'when there is a "probability of concern". The licensee's response stated that, "He believe that routine plant patrols adequately cover many of these areas." The inspector found t.hat the above policy is unwritten as is the definition of the term "probability of concern". Licensee representatives interviewed in this area felt that a written policy was not necessary because the requirement for a full time monitor would be identified during the review of maintenance or modification pro-cedures. This item was identified as an unresolved item.

The .licensee's response to Item 3.e of IEB 75-04A stated that, "Pro-cedure 2.2.4 provides for instruction on the use of the installed and portable communication equipment available at the plant. Sufficient equipment., both protable and installed, are available to provide monitoring personnel with prompt communications with the Control Room operating staff as required." The inspector reviewed Procedure 2.2.4 (Communications System) and the communications installation at the facility and found no discrepancies.

In response to Item 3.f of IEB 75-04A, the licensee stated that they had reviewed their fire protection system and consider it adequate to safeguard all areas of the plant. In Amendment No. 15 to the FSAR, the licensee responded to FSAR Question No. 7.4 with a detailed description of the fire detection and protection installations in the areas where safety related cables are installed. The fire detection and protection installations were to include:

(1) A dry pipe and pre-action sprinkler system in the Electrical Cable Spreading Room.

(2) A dry pipe and pre-action sprinkler system in the Reactor Building area above the Hotor Generator Sets.

(3) A wet pipe automatic sprinkler system 'above the Hotor Generator Set Oil Pumps and Hotors.

(4) An automatic C02 system for each of the dieslc generator rooms.

(5) Smoke detectors in the following critical areas.

(a) Computer room ceiling.

(continued)

0

~

~ 4 (b) Auxiliary relay board room ceiling.

(c) D.C. switchgear room ceiling.

(d) Battery room ceiling.

~

(e) Peactor pxotection system MG set room ceiling.

The inspector toured the above areas and verified the installation of the above fire detection and protection equipment. The inspector also noted an ample number of wall mounted C02 hand ex< inguishexs located throughout the above areas.. The inspector also noted that smoke detectors had been installed in the reactor control room. Ho discrepancies were noted in this area.

~ In responding to Item 3.g of IEB 75-04A, the licensee noted that, "Fire fighting procedure 5.4 provides for instruction to personnel

'oncerning the various types of fires and the required action of the plant personnel in response tq a fire. It is recognized that a fire, even. one involving electrical equipment may, if of sufficient intensity, require water as the ultimate suppression medium." Procedure 5.4 consists of a general Eire procedure (5.4.1) and twenty-five (25) special E'ire procedures which provide guidance in fighting Eixes in many different areas throughout the plant. The inspector noted, however, that none of the procedures reviewed addressed the above stated policy that an electrical fire of sufficient intensity may require water as 'the ultimate suppression medium. In fact, a number of the'proceduxes contained a statement to "avoid using water on electrical fires." The inspector discussed with licensee representatives this apparent conflict from their stated position (above IEB response) on the use of water on electrical fixes. The licensee representatives stated that they would review this item further. This item was

-identified as an unresolved item.

In response to Item 4 of IEB 75-04A, the licensee stated that pro-cedure 5.2.1 (Shutdown from Outside Control Room) was being revised to include local operation of core standby cooling systems and a new procedure 5.2.10 was being written to provide for flooding of the reactor core with service water. These procedure changes had not been completed as of the date of this inspection. Thisitem remains open.

b. Fire Barriers The primary objectives of this inspection were to'.

(1) Examine the construction specifications of the facility to determine what requirements had been imposed'or.:

(a) Location and installation of fire barriers and compartment

( boundary seals for safety related cables.

(continued}

0 s V'

<<15-(b) Application and the extent of application of fire

.. retardant coating for safety related cables.

(2) Examine maintenance and modification procedures to determine whether the requirements of (1), (a) and (b) above are invoked on a continuing basis.

(3) Visually examine the facility to determine the extent of con-formance to the requirements identified above.

Construction S ecifications on Fire Barriers In Amendment No. 15 to the FSAR the licensee responded to FSAR Question No. 7.4 with the criteria for cable routing in containment, penetration areas, cable spreading rooms, control rooms and other congested or hostile areas. The licensee's response stated that for floor and wall openings in Pire Hazard Zones, "runs of NSSSS and ESS cables are sealed with fire resistant material." The construction specifications which satisfied this commitment are contained in page G-03 of Burns and Roe, Inc.. Specification E.70-3 entitled, "Instru-ments and Control System Installation" and on Sheet 2 of Burns and Roe, Inc.. Drawing No. 3136. Xt was noted that the original spec-ifications called for the use of ceramic fiber, such as Babcock and 7lilcox "YNOVOOL" (or approved equal), packed into the conduit or cable tray penetrations. This specification was subsequently changed to provide the following fire stop installation:

(1) High density or low density cellular concrete to fill floor

.and wall penetration openings around conduit and cable tray runs. The high density concrete was specified for use where radiation resistance and strength was. necessary'.

(2) Small holes and ends of conduit were to be filled with urethane foam. The exposed surfaces of the foam were to be painted with PPG f/42-7 fire retardant intrumescent paint.

The construction specifications did not call for an application of fire retardant coating on safety related cables. The inspector reviewed, however, the qualification test report for the electrical cables used at the Cooper Nuclear Station. The qualification tests were conducted by the Franklin Institute Research Laboratories and the results reported in Report ifF-C 2927, dated October 1970. The following tests were included in the qualification test program:

Heat Resistance Test Irradiation and Post Accident Environmental Test Cable Tray Pire Propagation Test Dielectric Test All of the cables tested were found to be acceptable.

(continued)

0 Maintenance and Modification Procedures Modification and maintenance procedures were reviewed as part of the followup on the licensee's response to IE Bulletins 75-04 and 75-04A.

The results of this review are detailed in Section l.a of this report. r Visual Examination of Fire Barriers The inspector toured the facility to visually examine and verify the installation of fire barriers in accordance with the construction specifications. The'reas which were covered by this tour included:

(1) The Reactor Building (at elevation levels 903'-6", 931'-6",

958'-3" and 976'-0")

(2) Auxiliary.Relay Room (elevation 903'-6")

(3) Reactor Protection System H-G Set Rooms 1A and 1B (elevation

'. 903'-6")

(4) Battery Rooms lA and 1B (elevation 903'-6")

(5) DC Switchgear Rooms lA and 1B (elevation 903'-6")

(6) Cable Spreading Room (elevation 918'-0")

(7) Cable Penetration Room (elevation 918'-0")

(8) Reactor Control Room (elevation 932'-6")

(9) Computer Room (elevation 932'-6")

(10) Reactor Drywell (elevation 903'-6" and 9l<2'-6")

The inspector found that, with the exception of the Reactor Building, all floor and wall penetrations had been sealed with the low density cellular concrete in accordance with the revised construction specifications. The inspector found that in several of the cable tray

.penetrations between the Cable Spreading Room and the Cable'Penetration Room and the penetrations between the Cable Penetration Room and the Reactor Building small strips (approximately one inch thicl'nd three inches vide) of a urethane foam material remained across the width of the cable tray. The inspector tested the foam material and verified that it was combustible, but the foam had not been painted with a fire retardant paint. The strips of foam .had beei> used to seal the gaps between the cables and the concrete for'ms used while the seals were poured. The. foam strips had not been removed when the forms were disassembled. The foam strips are imbedded in the concrete seals to a depth of loss than one inch.

(continued)

~ ~y.

In discu'ssing the foam strips with licensee representatives, the

'inspector noted that'the exposed surfaces of the foam strips which are not painted with ire retardant paint is contrary to the FSAR commitment which states that'runs of NSSS and ESS cables are sealed with fire resistant material" and to the revised construction specifi.cations for fire, bazriers which required that all exposed surfaces and urethane foam be painted with PPG !I42-7 fire retardant paint. This item is identified as an item of noncompliance with the requirements of Cziterion V, Appendix B, 10 CFR 50, which states in part that "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accord-ance with these instructions, procedures or drawings." A licensee representative stated that the foam strips would be zemoved. He said that the foam strips which are most accessible will be removed as soon as possible, but those strips which are not readily accessible will be removed during the next scheduled outage of significant duration.

During hi.s tour of the Reactor Building, the inspector found that fire barriers had not been installed for several of the cable runs b'etween floor levels of the. building. The inspector pointed out this discrepancy to licensee and Burns and Roe, Inc. representatives and noted that Section C.2.d of the licensee's answer to FSAR Question No. 7.4 states that, "Floor and h'all 0 enin,s runs of NSSSS and ESS cables are sealed with fire resistant material". The inspector also noted that Burns and Roe, Inc. construction specification E.70-3 states (on page 6-S3), "hhen all conduits have been installed, this contractor shall close up the openings throughout the entire plant."

The inspector stated that the failure to provide fire barriers for all floor openings in the Reactor Building is an apparent deviation from the above FSAR commitment. The licensee and contractor repre-sentatives said that they did not agree with the inspector concerning the identification of these items as a deviation from the FSAR commitment. They noted that those barriers which had been installed in the Reactor Building floor openings were i.n the immediate area of the Recirculating Pump ."fotor Generator (N-G) Set or the lube oil pumps and heat exchangers which service the H-G Sets. The licensee and contractor representatives said that these barriers serve to prevent H-G Set oil spills from running down the'able runs and are not fire stops. They noted that there are numerous pipe chases throughout the Reactor Bui.lding along with the open equipment hatch and elevator shaft which 'would not prevent a fire from propagating between floors. They said that since the other openings would not prohibit the propagation of a fire, fire stops in cable openings would serve no real purpose. On the basis of the above position, the licensee representatives said that they 'did not plan to install addi-tional fire stops in the Reactor Building. The inspector said that he would identi.fy this item as an unresolved item and .refer it to his management for resolution.

(con tinued)

0

c. Cable Se aration In the licensee's response to FSAR Question No. 7.4, specific criteria for the separation of safety related cables was outlined to minimize the potenti'al for fire damage to cables of redundant systems/

components. During his tour of the facility to verify the installation of fire barriers (Section l.b), the inspector also observed the extent of compliance with the cable sepaxation commitments made in the FSAR.

H The inspector found that in general, the licensee's commitments had been met for:

(1) Horizontal separation of cable trays.

(2) Vertical separation of cable trays.

(3) Vertical separation of conduits.

(4) Separations within control panels and instrument racks.

The inspector found six (6) discrepancies in the area of cable separation. The discrepancies are:

(1) On the northeast end of the Reactor Building a Division I (C-82) and a Division II (C-99) cable tray run vertically from the 931'-6" elevation to the 903'-6" elevation witn a horizontal separation of approximately eight (8) inches. The horizontal separation criteria of the above FSAR commitment has not been met for this cable run by the fact that the inside cover of the

.Division I tray is not solid metal.

(2) On the northeast corner of the Reactor Building, near the ceiling of the elevation 903'-6", a Division II cable tray crosses over a Division I cable tray with a vertical separation of less than eighteen (18) inches. The solid metal cover on the bottom of the Divisiop II cable trays was apparently moved during installation exposing a gap of about one inch in width.

(3) On the east end of the Cable Spreading Room (elevation 918'-0")

a terminal box (designation unlcnown) contains Division I and Division XI cables which are properly separated within the box.

The cables coming out of the box, however, are run in cable trays which parallel each other with a horizontal separation of less than six. (6) inches for a length of about two (2) feet. A fire barrier has not been installed between the cable trays in accord-ance with the FSAR separation criteria; (continued)

0 (4) . On the northvest corner of the Cable Spreading Room a Division I cable tray crosses over a Division II cable tray and the-metal cover over the Division II t:ray does not extend to five (5) feet on each side of the cross-over area as required

. by the FSAR commitment:.

I (5) In the Auxiliary Relay Room the Division II cable from the Division II relay cabinet are laid in.a cable tray which runs west and then north and exits through the northwest area of the. ceiling. The cable tray is installed in such a manner that it passes within a three (3) feet horizontal separation of the Division I cable tray which collects the cables from the Division I relay cabinet. No fire barrier has been installed between the two cable trays as required by the FSAR commitment.

(6) Tvo cable trays ring the Reactor Drywell with most of the runs being in the upper position of elevation 903'-6". The cable trays are designated C85 (Division I) and C84 (Division II) and are run with C85 above C84 vith a separat:ion of about one foot.

In the horizontal runs, a solid metal tray has been installed on

~ the top of C84, but: no solid metal tray had been installed on the bottom of'85, as required'y the FSAR separation require-ments. In t: he verEical runs of. the above cable trays the separation is still about one foot:, but: no fire barrier had been insta3.led between t: he cable t:rays which is contxary to the FSAR separation requirements.

The inspect:or told licensee and contract:or representatives that the above discrepancies vere contrary to the licensee's commitment in the FSAR. The inspector point:ed out the fixst five discrepancies to several licensee and Burns and Roe, Inc. representatives vho acknowl-edged that the discrepancies were contrary to the FSAR commitment.

The discrepancies in the'dryvell vere pointed out t:o the licensee representative vho accompanied the inspector into the dryvell. The inspector did not det:ermine, if construction specifications exist to satisfy the FSAR cable separation requirements. The above discrepancies imply that either an adequate specification had <<ot been prepared or that the specification had not been followed. In either case the above discrepancies constitute an item of noncompliance vith Criterion V, Appendix 8, 10 CFR 50, which is quoted in part: in Section l.b.

2. 0 eration at Reduced Power On April 26, 1975 the NRC Office of Nuclear Reactor Regulation issued an Order for the modification of the Cooper Nuclear Station License (No. DPR-46) to limit the maximum core power level and the maximum core flov rate to 50% of design power and design flov rate. The order. was issued on the basis of possible vibration of instrument tubes vhich is suspected by the anoma3.ous readings from a transversing incore probe (TIP).

(continued)

0 The inspector reviewed the operating records of the facility and verified that core power and core, flow were reduced to 'less than 50% on April 26. Core power. and flow have not'exceeded 50% since April .26. The licensee has informed all operating personnel of the power and flow limitations.

The licensee has begun a program of obtaining weekly TIP readings from all TXP positions. This program will enable him to monitor the core and detect any recurrent vibration indications. The inspector reviewed the TIP traces taken on Hay 2, 1975 at 48.6% power and 45.4% flow. No discrepancies .were noted.

.3. Status of Power Ascension Test Pro ram During this inspection, the status of the power ascension test progiam at the 100% plateau was xeviewed in detail. The completed tests (listed below) which had not been previously reviewed by the inspector, were, reviewed to verify that:

a. . The test had been conducted at the power level and core flow conditions required by the PSAR.

b. The procedure used had been properly approved.

c. Indicated "hold" points in the procedure had been signed-off.

d. The results of the test conformed to the indicated acceptance criteria.

e, 'he test results had been reviewed by the Cooper staff and by the Staxtup Test Committee.

Deviations from the indicated acceptance criteria had been resolved in the review process.

The inspector also reviewed Staxtup Report - Supplement No. XI, dated April 29, 1975, 'to verify that the test results reported were consistent with the startup test records. No discrepancies were found.

The following tests have been completed through the final review of the Startup Test Committee and have been accurately reported in the Startup Report:

I Test No ~ Test Title STX-9 Mater Level Heasurement STX-13 Process Computer STX-18 Core Power Distribution STI-19 *Core Performance STI-20 Steam Production (continued)

E

Test No.. Test'Title STX-22 Prcssure Regulator Set Point Change STX-23 +Feedwatcr System STX-27 *Turbine Trip STX-29 <Flow Contx'ol STX-30 +Recirculation System STX-34 <Vibration Heasurements STX-35 Recirculation System Flow Calibration STX-72 Drywell Atmosphere Cooling System STI-73 Cooling 4'atcr Systems

,>'<The FSAR required that portions of these tests be run at flow and power conditions which the licensee believed to be unnecessary or undesirable.

The tests were not conducted under these conditions. The licensee has reviewed these changes to the test program and reported same in Section XII of Startup Report - Supplement II.

'he above reviews were conducted during the part of the inspection held on Hay 5-7, 1975. .The inspector noted that Test STI-16 (Selected Process Temperatures) had been completed and reviewed by'he Startup Test Committee, but the test results had not been reported in Startup Report - Supplement II. A licensee representative said that the results of this test would be reported as a revision to Startup Report Supplement IX. The inspector also found that Test STX-24 (Bypass Valves) had not been conducted with natural circulation flow on the 100% load line (Condition 4A) as required by the FSAR program. The licensee representative said that they did not plan to run this test under condition 4A and would justify this test program change in the above revision to Startup Repox't - Supplement XI.

R>en the inspector returned to complete the inspection on May 16, he was informed by a licensee representative that the revision to Startup Report Supplement IX had been issued on Hay 14, 1975 and was entitled "Startup Test Program, Attachment A to Supplement XI". The inspector reviewed this document and found that the results of Test STX-16 had been accurately reported and that the test program change to eliminate condition 4A from Test STX-24 had been justified. The inspector found no discrepancies with this document.

The licensee has conducted all of the tests required by the FSAR test program or has justified program- changes in his Startup Reports. All of the test results have been reviewed by the Startup Test Committee (STC)

. and have been accurately reported in the Startup Reports. Deviations fron> the indicated acceptance criteria have been reviewed and resolved by the STC and have been reported in the Startup Reports. A licensee representative said that they believe the requirements of thc Startup Test Px'ogram have been completed and that the licensee will begin ine'rting the drywell (a., required by TS) after the startup which follows the current outage period. The inspector said that he concurs with the licensee's position on the completion of the Startup Test Program and the requirement to begin drywell inerting when reactor operation resume.

(continued)

<<22<<

Followu on IE Bulletin 75-03 C On Harch 14, 1975, the NRC Office of Inspection and Enforcement (IH) issued IE Bulletin (IEB) No. 75-03 entitled "INCORRECT LOWER DISC SPRING AND CLEARANCE DI"KNSION 'IN SERIES 8300 AND 8302 ASCO SOLENOID VALVES". The bulletin advised licensees of recent abnormal occurrences at two power reactors in which safety related solenoid air-pilot valves manufactured by Automatic Switch Company (ASCO) failed to operate properly. The bulletin further described the types of ASCO valves which have failed and the apparent cause for the failures. .Licensees were advised to contact the ASCO valve service department in case of uncertainty.

The bulletin outlined the following action to be taken by all power reactor licensees with operating license or construction permit:

l.'Determine if ASCO valves of the types .described above are in use or palnned for use in safety related systems..

2. "Report to this office in writing, within 30 days for facilities with operating license, and within 60 days for facilities with construction permit, the results of your findings with regard to

~ Item l.

3. "If solenoid valves of the ty'pes described are in use ox planned for use in safety related systems, include in your written reply the actions you have taken, or plan to take, to prevent failures of the type described above. Your written reply should also include the date when such actions were, or will be, completed."

The licensee's reply 2/ to IEB 75-03 indicated that they did not have any of the specified series of ASCO solenoid valves in their safety related systems. They did note, however, that four of the ASCO Series 8302-C form U solenoid valves were installed to control fan dampers in the drywell ventilation system and several of the series 8302-C from RU v'alves are in the Augmented Radwaste Building Systems. They further noted 'nstalled

. that they had been in contact with the manufacturer (ASCO) and planned to follow ASCO's recommendations on the actions taken.

a During this inspection, the inspector reviewed the corrective actions taken by the licensee relative to the above ASCO valves, The licensee had contacted the ASCO valve service department and had received additional information 3/ on the previous failures of these valves and the actions to take to prevent further failures.

The ASCO letter also included a detailed list of, the specific catelog numbers for all of the solenoid valves ubject to the type of failure noted in the bulletin. The letter also enclosed a maintenance instruction sheet (ASCO 1&~41 Sheet U-5503) which outlines the procedure to check and adjust the solenoid valves.

(continued) li 11 2/

3/

NPPD ASCO latter, Jay H.

(L. ll. Cason)

Pliant to letter to H.

NPPD lforria Hoaard, dated hprdl dated April 9, 1975.

14, 1975.

<<23 The licensee had completed the inspection of the seven (four in drywell ventilation system, and three in radwaste systems) solenoid valves of the types listed in the ASCO letter. This inspection verified that the lower valve disc clearance was in the range of 0.008 to 0.016 inches as required by the ASCO instructions. Two of the valves in the radwaste system have resilient seats. The licensee had ordered the conversion kits that will convert the valves to provide metal-to-metal seating surfaces.

The licensee anticipated receiving the conversion kits and modifying the valves before Hay 15, 1975. Since these valves are not safety related, no additional followup will be made on the above conversions. This item is closed.

5. Abnormal Occurrence (AO) Re ort Follow-u Abnormal, Occurrences 75-10 through 75-12 were reviewed during this inspection and the findings are summarized in Table X. The inspection effort was directed at verification that:

a. The details of 'the event were clearly reported in the 10-day letter;

b. the cause was identified;

c. the corrective action indicated in the 10-day report had been taken;

d. the event and, the indicated'corrective action was reviewed and

'valuated in accordance with the technical specifications,',

the event did not violate a safety limit, limiting safety system setting or limiting condition for operation.

No discrepancies were noted and the above abnormal occuriences axe consid-ered closed.

6. .Trainin Activities The licensee's training records were reviewed to verify that training and retraining of licensee personnel have been accomplished in accordance with NRC requirements and licensee commitments. The training areas reviewed and the inspector's findings are discussed below.

a, 0 erator and Senior 0 erator Re uglification Pro ram Dux'ing the inspection of October 30 through November. 1, 1974, the inspector. reviewed the actions that the licensee had taken to implement the Operator and Senior Operator Requalification Program which had been approved by the AEC Directorate of Licensing on January 17, 1974. The inspector found that the requalification program had not been fully implemented, and this item was identified as Unresolved Xtem 7414-1.

(continued)

During the inspection of February 10-12, 1975, the inspector again reviewed the licensee's activities under the requalification program.

The inspector found that some progress had been made toward full implementation of the requalification program but that the following items remained unresolved:

(1) Scheduling of the annual requalification exam.

(2) Performance evaluation of all licensed operators.

(3) Semiannual review of the emergency operating procedures.

(4) Long,-range schedule and plan for the overall training program.

During this inspection, the inspector again reviewed the training activities under the requalification program. The licensee had administered the annual comprehensive exam to all but one licensed operator during the month of April. The one licensed operator who did not take the exam is a supervisor outside of. the Operations Department who ~vill probably not seek iequalification but allow his license to expire. The licensee was in the process of grading the exams at the time of tlxis inspection. A licensee representative discussed the tentative long-range schedule and plan for next year's training. He noted that this may be changed when the exams have been graded. The inspector reviewed the records of the performance evaluations of the licensed operators and the records of the review of abnormal and emergency operating procedures. No discrepancies were found and Unresolved Item 7414-1 is closed.

ualit Assurance ( A) Trainin Quality Assurance Instruction QAX-6 entitled "PERSONNEL QUALXFICATXONS AND TRAINING FOR QA ASSIGlfrKNTS" establishes the requirements for the training and retraining of all licensee personnel assigned to perform QA activities for the Cooper Nuclear Station. QAX-6 requires that, "Cooper Nuclear Station supervisory personnel, responsible for operat-ing or maintaining systems and equipment requiring Quality As'suranre, .

shall receive formal instructions in Quali'ty Assurance, including basic principles, 10CFR50 Appendix 8, the contents of the NPPD policy document on QA fo'r Operation, and the contents of specific Quality Assurance documents prepared to implement the QA Program for Operation."

QAI-6 also establishes the following requirements for the scheduling of the above training and the retraining of the above personnel:

"Scheduling of per. onnel into the QA training sessions shall be coordinated so as to minimize conflicts with other work activities.

However, all designated supervisors shall complete the first half of the program before plant start-up. The second half shall be completed within six (6) months.

(continued)

"Refresher QA training sessions will be incorporated into operator retraining programs and will be completed within the required two-year cycle."

During this inspection, the'nspector reviewed the QA training records of- the licensee. The initial QA training was conducted on December 11 and 13, 1972 for the first half of the program and April 10 and ll, 1973 for the second half. The training records did not, however, contain any records of refresher training nor were there any records of QA training for supervisory personnel who began employment after April 1972. The licensee's Training Coordinator stated that he was unaware of any retraining in the area of QA. The inspector was subsequently informed (telephone call. on Hay 13, 1975) by a licensee representative that QA refresher training had been given in 1974 by the QA Supervisor. The inspector advised the licensee representative denoted that this item would be identified as an unresolved item pending the inspector's review of the training records for 1974.

Xn reviewing the QA training activities and QAI-6, the inspector that Section 3.1, 3.2 and 3.3 of QAX-6 establish the qualifications and training requirements for the i~fanager,'icensing and Quality Assur-ance; Quality Assurance Engineer; and Quality Assurance Specialist, respectively. Each of these Sections refers to a different Attachment (B through Dq respectively) which is to contain the minimum qualifica-tions for each of the above positions. The Attachments B through D, however, contain no qualification information. Each qualification category (Education, General Experience, QA Experience, etc.) contains only the word "(Later)". The inspector asked a repxesentative of the licensee's QA Department if the qualifications have been established.

He said that they have been drafted and are in the process of being reviewed by management. The inspector identified this item as an unresolved item.

c~ Securit Trainin The inspector reviewed the licensee's training activities relative to facility security procedures and access control. The initial training sessions were held on November 7, 8 and 9, 1973 and supplemental, infoxmation was given on December 17, 1973 which included information

7. Batter Poom and

'r on the AEC (now NRC) approved Security Plan. The licensee plans to schedule refresher training in the near future. No discrepancies i

were found n thxs Vital ea.

Switchgear Ventilation awhile reviewing the licensee's commitments on the installation of fire barriers for electrical cables, the inspector noted another potential t fixe problem which had been addressed in the FSAR. By FSAR Question No.

10.16 the licensee was requested to evaluate the potential problem in the battery room ventilation due to an archway which provided a potential for c (continued)

hydrogen accumulation and the fact that the battery room exhaust ventilation ducting and exhaust fan were to be located in the control room. The licensee's response to the above I:SAR question indicated that the above areas of concern had been corrected by:

a. Modifying the duct work to extend to each archway in the battery room.

b. Installing fire dampers (which close on high temperature) in the exhaust ducting for each battery room and in the exhaust ducts in each critical switchgear room.

c. 1nstalling a standby fan which will automatically start on the failure of the operating fan.

d. Replacing the battery room exhaust ducting in the cable spreading room and control room with explosion proof piping.

e. Enstalling'he battery room exhaust fans in the corridor outside of the control room with the exhaust directed to the atmosphere through the roof.

The inspector examined the battery room,and switchgear room (1A, 1B, 1I: and 1G) ventilation installations. The modifications to the ventilation system had been made in accordance with the above commit-ments by the licensee. The fire dampers are of the fused-link type and had been installed to provide separation between the battery rooms and between the switchgear rooms. No discrepancies were found in this area.

'TASLE 1 AMOMQJ 'OCCVRRENCE'FOLLON-UP AO

,Number ~Sub'eet 'NCN'No. TS'Vlol. 'Comments 75-10 ADS Timer s/p dft 520 Yes Closed 75-11 SBGT Line Plow Reduction 523 Yes Closed 75-12 RHR Riser dp switch s/p dft . 524 No Clo ed Le end of Acron s ADS Automatic Depressurization System AO Abnormal Occurrence NCR - Nonconformance Report TS Viol - Technical Specification Violation s/p dft Set point drift SBGT - Standby Gas Treatment System

~ RHR'- Residual lieat Removal System

'U ~ S ~ NUCLEAR REGULATORY COa MISS ION OFFXCE OF INSPECTION AND ENFORCEMENT REGION XIX Report: of Operations Inspection 1

XE Xn pecti'on Report No. 050-315/75-07 Licensee: American Electric Power Service Corporation Xndiana and i~fichigan Power Company 2 Broadway New York, New York . 10004 Donald C. Cook Nuclear Plant, Unit 1 License No. DPR-.58

. Bridgman, Hichigan Category: B Type of Xicensee: PVR,- Westinghouse Type of Inspect:ion: Special, Announced Dat:es of. Inspection: April 24, .and Hay 2, 1975 Daf.es of Previous Xnspection: !farch 5, 10, 13, 19, 27, April 8, 9, ll, 1975 (RIP)

Principal Xnspector: Baker

~ '0 M

Accompanying Inspector: None Ot:her Accompanying Per onnel: None Reviewed By: M. ~ Jordan Senior Inspect:or React:or Operations Branch ( atc)

S'E'iKLRY OF FINDINGS Enforcement Action: None Licensee Action o~n revfouslv Xdantffied Fnforeaaent Matter Not inspected.

Unusual occurrences None.

Other Si nificant FindinGs A. 'urrent Findin s Licensee has submitted replies to IE Bulletins 75-04 and 75-04A.

Reviews indicated actions in the licensee s repl.es are in progress.

Certain cable tray penetration fixe barri.ers and air eals were observed to be out of de ign specification. No immedi.ate safety concerns were identified.

t B. Unresolved Items Repairs/modification to fire barriers and air seals to bring them into specification. (Paragraph 5, Report Details) liana ement Interview The following matter were discussed with Hr. Jurgensen, Plant ."fanager on April 24, 1975 and subsequent phone conversations:

A. The licens'ee stated that based upon the inspectors obsexvation a complete detailed inspection of the areas required to be sealed would be made. (Paragraph 5, Report Details)

B. The License tated that rework by construction will be controlled.

The admin txative frame work is in place and functioning. The particular problem with the seals will be brought to construction attention.

C. Deficient seals wi.ll be repaired when a repair procedure is developed and approved. Seals which are deficient because of flammable backing materi.al axe being corrected by the removal of the material, (Paragr'phs 4 and 5, Report Details)

r ' ~

~

The licensee stated that though some seals~ are out of specification they still will serve as a fire barrier and air seal. Also, even though seals may be missing in areas the ability to maintain a COg atmosphere on these areas has ';'..en demonstrated.

t The licensee stated that no "quick fix" was going to be done. The licensee vill assure that the specifications are proper, proper materials will be used and that reviewed and approved procedures vill be used so that the fix vill not'degrade the seal installations.

~ ~

REPORT DETAILS

l. Persons contacted

(

R. Jurgenson, Plant lfanager R, Keieh, QA'Supervisor P. Dorschel, QC Xnspector J. Randolph, Utility Operator.

'The inspection was a special inspection to review the facilities installation ofire barriers and air seals.

3. S ocifications A review of the facilities specification (DCCFP101QCiv) for cable tray penetration fire barrier and air seal revealed 'the following:

a. Sealant Flexible Silicone Ruboer Foam (Silicone Class Dimet:hyl Polsiloxane, U. L. Listed 94 VH-0) test:ed in accordance wieh ASTH E119 (Fire tost:s of building conseruction materials).- Haeorial was tested and witnessed by insurance company on Harch 26, 1975. Te"t was for five hours and t:o temperatures o'f 2075oF with no ignition.

b, Application At boundaries of room/areas listed in ehe specif'ication all wall and floor opening aro sealed t:o the thicltness of tho wall or. 12 inches + 1. Xf cables occupy greater than 50% of opening t:hen 6 inches + 1 is applied.

c. Repairs or modification ~fethods not detailed in specificat:ion.

4. Haintenance and Modification Procedures Reference t:o the DCCFP101QCN specification is noe used or. called for. in the facilitios modificaeion or maintenance procoduxes. The Licensee has no procedures for seal repaix.

r

5. Xnstallation The inspector toured the areas required by specification DCCFP101QCN to be sealed to observe the licensee's adherence to the specification.

The f'ollowing types of deficiencies were noeed in most areas:

, a. Opening not sealed.

Flammable backing maeerial not removed after seal installa tion as required by the specification.t

0

c. Holes in seals created when cables were remoyed.

d. Seals partially removed due to cable pulling or removal.

e. Holes createdby cable removal sealed with flammable material (duct seal)

The licensee's later inspection revealed that about 20% of the 2100 openings requiring sealing were deficient with some aspect of the specifi-cation.

6.'es >onse to XE 13ulletins 75-O~i and 04A The licensee re ponded to 75-04 on April 23, 1975. Included in this response i.s a schedule for review of the various items of 75-0~ih.

UNITED STATES NUCLEAR REGULATORY COi tISSION 01'FXCE OF IHSPECTXOH AND EHFORCE~fENT REGION IIX Report of Operations Inspection IE Xn.,pection Report No. 050-010/75-09 XE Inspect:ion Report No. 050-237/75-14

'IE Inspection Report No. 050-249/75-12 Licensee: . Commonwealth Edison Company P. 0. Box 767 Chicago, Illinois 60690 Dresden Nuclear Power Stat:ion License No. DPR-2 Unit:s 1, 2, and 3 License, Ho. DPR-19 Hol.risq Xllinois License No. DPR-25 Category: C Type of Licensee: BMPi GE Type of Inspection: Special, Announced Dates of Xnspection: April 28 and Hay 12, 1975 Dat:es Principal Xnspector:

1 of Previous Xnspection

April 21-24, 1975 (Operations)

(.(

T. L. Hag>ster (Date)

Accompanying Inspectors: None Other Accompanying Personnel: None gy ~S Reviewed By:

Senior Inspector (Date)

Nuclear. Support Operations Branch

'I ~

~ P

SUEfhl<Y OP FINDINGS Enforc ment Action: None.

Licensee Action On Previous). Tdentified Enforcement Items: None required; Unusual Occurrences: None.

Other Si nificant Findin s A. Currenl~Findin e

1. Unresolved Items The inspector questioned the cable separation in 'areas of the RPS and ESS Systems. This matter is considered to he unresolved pending further investigation. (Paragraph 5, Report Details)

Status of Previousl Re orted Vnre olved Items: Not inspected.

~Mene,ement Interview The following subjects. were discussed at the conclusion of the inspection on Hay l2, l975, with Hessrs. Roberts, Butterfield, )lausman, and Jurecki.

A. The inspector summarized the findings of his visual examination of penetrations. The inspector. stated that:

1. Pcnetrations had been identified which had not been sealed, had not been resealed, or had not been sealed/resealed in conformance with specifications.

2. Combustible material was identified both in penetrations and cable trays.

3. Hany fire stops were deteriorating because of material shrinkage.

(Paragraph ~i, Report Details)

B. The inspector questioned whether cable separation was adequate in areas of the RPS and ESS Systems. Thc inspector stated that this would be considered an unresolved item pending further investigation.

(Paragraph 5, Report Details)

C. The licensee discussed parts of the reply to IE Bulletin No.75-04A

,with the inspector. The Bulletin reply is in preparation.

0 The inspector di'scussed the licensee's modification control procedures.

Th" licensee ackno~:ledged that there was presently no procedure for maintaining fire stops on a .continuing basis. (Paragraph 3, Report Details)

Rl'ORT DETAILS

1. Per onnel Contacted A. Roberts, Assistant: Plant Superintendent D. Butterfield, Administrative Assistant J. Jurecki, Staff Assistant to'aintenance Engineer J. Hausman, General Engineer I

2. Const:ruction Snecif ications

a. The inspector reviewed Sargent and Lundy Standards.

following summary is prov xded.

t I

(1) Cable Pan Fire Sto and

'he Air Seal Throu h Hall (STD-EA-175) opening and void between cables is filled with Thermal Insulating tiool. A 1/4 inch layer. of Flamemastic is applied over the Thermal Insulating tdool to form the seal (2) Fire Sto in Cable Riser (STD-EA-176)

A support for the Thermal Insulating 4'ool is inst:alled at the bot:tom of the fire stop. The Thermal Insulating t,'ool and Flamemastic is applied as in 2.a.1. above.

(3) Cont:rol Board Cable Ent.rance Se l (STD-EA-179)

Similar to 2.92 above except the bottom support is specified as'ebony board.

b. The inspector reviewed Sargent: and Lundy Drawing 12E2079 Electrical Inst:allation-Reactor Building, which stated:

h Aft.er cables are in place, stuf f Turbine Building end with Duc-Seal and Oakum, then GE Silicon fill irom Reactor Rubber Type RV-108.

Building side with c, The licensee stated that it had determined through discussions with General Electric that GE Silicon Rubber Type RV-108 is moderately flammable.

d. The inspector reviewed Owens-Corning Fiberglass Customer Acceptance Standard IN-144.13 for Thermal Insulating Wool

~ (TIP) Type II.

~t

<<4-

) EP

(1) The product i designed for uso on all heated Industrial Applications at t'omporaturos up to 1000 1'.

(2) The product meet the following standards and, specifications:

(a) 1'ederal .Specification 11H-1558B -(Amondmont 2)

(b) 1orm 8, Type I,'lass 7 and Class 8; (c) Povm C, Class 10; (d) Form D, Type IV, Class 14; (e) Military Specif ication NIL-I-28188 (requires waiver o f LOX)

(f) U. S. At:omic 'Energy Specificat:ions and Guides Develop-ment:

(g) RDT Standard M 12-1T (h) U. S. AEC Regu3.ation Guide 1.36 The inspector reviewed a Fact:ory Mutual Research Corporation Evaluation of Flamemastic 71A".'ho following conclu'sions were reached.

(1) The Plamomastic when applied in accordance with the manufacturers specifications did not cause excessive cable heating for t: he maximum cable current permitted by

't.he Hat:ional Electric Code.

(2) The Flamemastic coating prevented the spread of fire when exposed to a moderate intensity ignition source.

The inspector reviewed a Franklin Institute Research Laboratories Rcport of Plamomastic. The following summary is provided:

Samples of electrical cables were coated with Flamomastic.

Part of the samples were exposed to 2 x 10 rads of gamma irradiation. All of the samples were then given a flame test.

In all cases, t: he Flamemastic prevented propagation of the f3.arne away from the ignition source.

3. Haintonance and Modification Procedures The licensee stated that there are no specific modification procedures

'to ensure that fire stops and compartment boundary sea3.s are maintained on.a continuing basis.

Visual Examina t ion The inspector toured the facility with Hes rs. flausman and Jurecki to determine the extent of conformance with the specifications in

.Paragraph 2, Specific areas examined were the Control Room, Auxiliary Electric Room, Computer Room, Turbine Building, Reactor Building, and Die 'el Cencrator Rooms.

The following areas of interest were identified.

a. A large number of penetrations were not sealed. Examples are:

'(1) Unsealed conduit sleeves in control boards.

(2) llorizontal cable tray wall penetrations in Auxiliary

~ Electric Room,. Computer Room, and Turbine Building.

A large cable bundle penetration in the wall between the Auxiliary Electric Room and the Computer Room.

(4) Unsealed openings in the Auxiliary Electric Room wall for conduit runs.

(5) Vertical risers without fire stops in the Turbine Building.

b. ~

Several penetrations were identified'which had cables added and were not resealed.

c ~ A large number of penetrations were not sealed/resealed in conformance with specifications.

(1) There were 4 basis types of seals in control board floor panels:

(a)

's Thermal Insulating kiool and Flamemastic in conformance with specifications),.

(This seal (b) Thermal Xnsulating Wool and an unidentified tan grouting compound.

(c) Thermal Xnsulating 4'ool and an unidentified asbestos fiber and plaster like material mixture.

(d) Combinations of the above.

(e) Unit 1 control board floor panels were solid concrete.

(2) Control board f3.oor panels had been rosealed wi th Duc-Seal and Silicon Rubber {RTV).

(3) Sleeve penetrations acros the secondary containment wall wore generally 100 percent RTV.

Two ponetrations across the secondary containment wall wore stuffed with'rags on the Turbine Building side. The React:or Building side of t:hese penetrations was not accessible.

(5) ))orizontal cable tray penotrations in the Turbine Building were covered with wood or masonite boards.

Bot:h the Flamemastic and Asbestos Fiber plaster like mixture had shrunken considerab3.y causing deteri.oration of the fire stopso

e. Combustibles were noted both in trays and ponetrations, (1) Combustib3.e mat:erials in penetrations include RTV and Duc-Seal, both of-which may be moderately flammable. Rags were found in 2 penotrations. Hood or masonite boards a large number of horizontal cable tray penotrations 'overed in the Turbine Building.

(2) Paper, rags, and wood were found laying in cable t:rays at various locat:ions in t: he p3.ant.

5. Senaration The inspector considers the following matt:ers to be unresolved pending further investigation.

Cables from separate divisions of the reactor protection system are tied together in common bundles within the control boards, e.g.,'anel 903-10.

b. Cables from different divisions of the engineered Safeguards Syst:ems come together in panels in the Auxiliary Electric Room; o.g., panels 902-33, 902-38, and 902-47.

6. Control Boards The in pector noted during the visual examination that many control boards wore open on top and in back. An open ladder type cable

I ~ 1 ~ v tray rari directly over open Uni.t 2 and 3 panels. The licensee stated that the panels were supplied without tops and backs,

/. Bulletin Status The licensee submitted the reply to lE Bulletin No. 75-Oli on April 25, 1975. The licensee is preparing a reply to XE bulletin No.75-04A.

UHXTED STATES NUCLEAR REGULATORY COHHZSSZON OZ:PZciy OP ZNSZECTZON AND ENPORCi'.HENT .

gO REGXON XXX Report of Operations Xnspection XE Xnspection Report No. 050-155/75-06 Licensee: Con umers Power Company 212 4'est Hichigan Avenue

,Zackson, Hichigan 49201

)3ig Rock Point: Nuclear. Plant: License No. DPR-6 Charlevoix, Hichigan Category: C Type oi Licensee: BUR GE 4

Type of Xnspection: Special, Announced Dat:es of Inspection: April 30, and Hay 1, 1975 Dat:es Principal Inspector:

~fq~.g of Previous Inspection: Harch .5-7 and 24-26, 1975 X. N.~Gackiw (Operations)

(Date)

Accompanying Inspect:ors: Hone Other Accompanying Personnel.: Nope C 'o:,

RevSeved By: H. C. Dance Senior Inspector (Dat )

Nuclear Support Operations Branch

0 f'

r SUNfARY 01'INDINGS Hnforccmcnt Action: None.

4 f Licensee Act:ion on Pr'cvious3. Identified Enforcement Hatters: Not inspected.

Unusual Occurrences: None.

h. Cux'rent 1'indin~s: None.

33. Unresolved Items: None.

C. Status of Previousl Re ort:ed Unresolved Items: None.

Hang ement Interview ht t:hc conclusion of this inspection on Hay 3., 1975, a management interview vas conduct:ed wit:h Mes rs. llart:man, (Plant Superintendent: )', DeHoor, (Technical

'ngineer); and Kuemin, (Engineer). The following it:ems vere discussed:

Xn regard t:o facility construct:ion specifications, the inspector acknowl-edged the licensee's earli.er. statements that: no such'documents vere availabl.e at t: he site. (Paragraph 2, Report Det:ails)

B, The inspector. st:ated that the licensee's Administrat:ive Control Pro-cedures for. facility change control have no provis"'on for. Quality Assurance rcviev of facility changes prior to start: of worl:.

Thc licensee acl:no<<ledged t:his and stated that the corporate office is present:ly revising all Administrative Procedures. (Paragraph 3, Rcport Details)

C. The inspector summari.zed the areas that wore examined and stated th t two areas of concern vere noted. The 3.icensce st:atcd that t:hese areas vi,l3. be reviewed for. corrective action. (Paragxaph 4, Report Details)

D. = The inspect:or. stated t:hat the following pot:ential fire hazard conditions w'ere noted:

1. , Exposed cable trays.

2. Splices in cable trays.

3, No fire stops bett ecn compartment boundaries.

The licensee acknowledge thi" <<ith no comment. (I'aragraphs li, li.c and l<.d, Rcpor.t Details)

~ I

~ ~

REPORT DETAILS l, Persons Cont:acted C. llarLman, Plant: Superintendent D. 1fclfoor, Technical Engineer J. ):uemin, .Engineer

2. Construction S ecifications No const:ruct:ion specifications were available for t: he inspect:ox t:o revi.ew; The licensee representative sLat:cd that the corporate office and the axchi.tect: engineer wer(. cont:acted and it appears that no con-st:xuction specifications in this area of concern e>:ist for the p3.ant.

The inspector request:ed that he be contacted if any pccificat:ions are located.

As-built: drawings were reviewed and indicated that no seal nor penetrat:ion information were specifi.ed on t:hese dra1ings.

3. Haint:enance and Hodification Procedures The inspectox confirmed that Admini trativc Cont:rnl Procedure A7.0 for maintenance activities, spe(.itic~ adequate revie(: ".or the activity Lo bc performed. This procedure also requires that

~ .

safety relat:ed maintenance activiti.e. be reviewed by t: he Qualit:y Assu1.ance Engineer, The inspect:or noted however, that Administrative Control Procedure for faci.lit:y change activities does not: provide f'r Quality Assurance.

review prior to st:art of the worl. Thc licensee responded that to his know3.edge the corporate office di.d not include this requirement: in the curlent revisions t:0 the Administrative Contro3. ProceduresI Thc inspector inquired as to what guides and st:andards will be used for. tut:ure maint:enance and modif'ication activities. The inspect:or also asked if t: he licensee plans to review the usc of fire stops in penctrations. To both of t:hese inquiries the licensee responded tl!at he did not know what'ctions would be. taken by thc corporate office.

4, Visua3. E>tamination The following areas of t: he plant were e>'amincd t:o det:ermine the condition of t: he licensee's cables, cable trays and penctrations:

~j

~.

a ~ Contro3. Room - all poMer and coiit:rol cables penct:rate the floor bcliind tlic cont:rol panels and aze not 'ea].ed. The pe>>ctrations are about 6 x 12 indies. Ho fire ret:ardant rrratcrial is used on eit)icr side of t:lic penetration. Cables izom t:lic control room go t:o t:lie compressor room below.

~Com roaaor Room aablaa from tbo control room ron into horizontal t:rays tliat: are vertically st:ackcd about: 2 feet: from eacli other. Cable t:ray in thi room have no solid tops nor boLt:oms.

Also, no fire retardant: material is used on any of the cab3.cs in t:iris room.

Xn tliis room are located t:)ie plant air. compressors, air receiver tanks, st:ation batteries and a number of st:ation motor control centers. The mot:or. control centers serve tlie fo].loving equipmcnt:

reactor shut 'dorm pumps; station battery charger; coro spray pumps', emergency diesel generator; reactor. protection HG scL's; etc ~

About 9 cable t:rays penetrat:c the compressor room .wall and go t:o the cable penetration room. No sealant material is used in these penet:rations.

c>> Cab3,c Penetrat:ion Room cable t:rays in this room are stacked above <.ac)i ot)icr with separations of about: 2 feet and these Lrays Ilav<'lo 'oliu Lop& vi: UvLLvlns A IIV!liber vI. Lat)ed BIId

~

cziinpcd splices i)erc obsczved in these trays. The jackei material for these t:aped plices is pul.led back exposing what appears t:o be t:hc pEPVC material used to insulaLe the in<lividual

.conductors. Ot:hcr splices observed i"ere covered irith clear plastic covers and werc part of the fact:ory assembled penet:ration seals.

d, Cont:ainmcnt - in the penetration .,eal area taped and crimped splices ii'ere observed in a number. of cable trays. Cable trays at t: he seal area are open trays (no solid top nor bottom) and are stacked above eacli other. trit)i separations of about 2 fcct:

between trays.

Xn other. areas of t: he containmcnt, a3most all cable trays t:hat:

t run under metal grating are covered wit)i solid metal covers, Micze trays are stacl<ed vertically under, the metal grating on3.y t: he top tray is covered. The in pcctor noted Lhat cable tray TP i)hie)i runs under thc 599'" elevaL'ion graLing does not have a cover. T)ie liccn:cc st:atcd l.liat. he Mill loo)< <<t:

tliis matter..

0 n storage r~~Ão. 4lil thc inspector. observed t:hat co b t'ble

!>a>ar>al wcs >!cins~~rcd nc;:" ! a Lhc 3 vcrcical ca>!la crays >n

'e th s room. AAt: t:l.e time ime oz-->

ox chc cv.'. t. >:t <<~v5.cw, the licensee stat:ed t:hat: a maintenance order had been initiated "..-clean up t:his room The following two items of concern werc ident:ified by the liccn:",.=

prior to t:his inspection:

(1) Two wooden cable support:s in t: he control rod drive room.

(2) A rubber cover in the penet:ration between t-.he accumulator and the. control rod drive rooms.

The licensee stated that: these it:ems axe gnder review.

l~ollowing a cable tray fire at the Peach Bottom plant in 1965 the licensee conduct:ed an elect:xic cable, penetration an

Surve Rc ort:"

.Xndepcndent conductors of power cables are insulat:ed with butyl rubber. The outer jacket: is of butyl xubbe"., neopx-.a=

PVC, H

b. Nearly all control cable has 20 rail polyethylene (PE) insulat:ion on each conductor, covered by a 10 mil thick layer of polyviriyl-chloride (PVC). The outer cable jacket is of PUC.

C~ Area under t:hc contxol room has some automatic sprinkler fire prot:ection and the area near the sphere penet:ration has none.

Each conductor through the sphere penetration is spliced about:

10 feet from each sicle of the penetration. The splices fall adjacent: t:o each othex in t:he cable t:rays.

C~ Alt >ough no hist:ory of splice failure exists, it: is recognized t:hat t:hc e are trouble points in any cable run.

Xn t: he sphcxcarea where many stacked trays xun under met:al grating, a cover over these should be considered.

g. Xn some locations, removal barriers in vertical trays would reduce chimney type spread of fire.

between'oosts

h. A large'art of'he through one penetration.

480V power for the sphere i supplied Parallel valves For thc emergency condenser inlet are .controlled

'by ci cuits through thc same sphere penetration. The same is true of the emergency conden..er outlet valves. Also, liquid para13.el control valves use one penetration. 'oison "Con"rol Cab3.e and Switci<board llire Re ort"

a. PEl?VC control cable, Super Coronol Plamenol Gl: and group of 15 single PEPVC conductors without PVC jackets failed flame resi.,ting tests.

b. BRP PEPVC doe" not have petroleum wax inside cables (Peach Bottom plant had this wax which is very flammable)

c. BRP field inspection showed no fire hazard due to similar Peach Bottom cable conditions.

de There are areas where trays are exposed to fire hazards due to welding above and other hazards such as spilling liquids.

e. Xnside the sphere near. the nitrogen poison headers and just outside the sphere there are m ny splices wi< h taped points within 10 inches of a second plastic. covered splice.

f. PEPVC was not used for the 20 foot 3ength of cable in the factory assemblies used for penetration seals.

Xt is recommended that metal covers be provided over open trays 3.ocated under metal walk grating around reactor, along turbine generator and near nitrogen poison headers. These covers are required for. t:op tray on3.y when trays are .stacked vertical.

"Con" rol Cal>la and S>>lrebboard L'lre pla~maabill.r Tnaa Re orr"

a. The PHPVC insulation on conductors themselves burns quite readily; however, the PVC jacket will not support combustion.

0'NXTED STATES NUCLEAR REGULATORY COa'f.'fISSION OFFXCE OF INSPECTION AND ENFORCF2fENT REGION IXI .

Report of Operations Inspection XE Inspection Report No. 050-331/75-05 Licensee: Iowa Electric Light and Power Company P. O. Box 351 Cedar Rapids, 'Xowa 52405 Duane Arnold Energy Center License No. DPR-49 Palo, Xowa Category: C Type of Licensee: BMR 538 Mt' T~e of Xnspection'. Special, Announced Dates of Xnspection: May. 8 and 9, 1975 Dates of Previous Xnspection: 18 21, 27 and

~

January 28, 1975 (REP)

'f~,1g/g~

/T. ~.L. /Harpster

• Principal Inspector:, ..7 7 1+y I L (Date)

I Accompanying Xnspectors: None.

Other Accompanying Personnel: None Reviewed By: H. C. Dance C. 27 73 Senior Inspector (Date)

Nuclear Support Operations Branch 4'o II I

~ ~

~ ~

SR~4X OF FINDlNGS Enforcement Action: None.

Licensee Action On Previousl Zdentified Enforcement Items: None required.

Unusual Occurrence  : None.

Other Si nificant Findin s A. Current Findin s: None.

B. Status of Previousl Reported Unresolved'tems: Not inspected.

~lfana eeent Interview The following subjects were discussed at the conclusion of the inspection on Hay 9, 1975, with kfessrs. Gebert, Gucciardo, and Vinquist.

A. The inspector summarized the findings of his visual examination of penetrations. The inspector stated. that:

1. Several penetrations which had not been sealed were identified.

2. Penetrations were identified which had not been resealed.

3. Penetrations were identified which had not been resealed in conformance with specifications.

4. 'ombustible foam was. found in several penetrations.

5. The plant generally conformed to the bulk of the specifications.

(Paragraph 4, Report Details)

P B. The inspector discussed the cable installation control procedure with the licensee. The licensee stated that the scheduled cable installa-tion checklist (Form E-700) is currently being revised to provide assurance that the penetration is resealed. (Paragraph 3, Report Details)

C, The licensee discussed parts of the reply to IE Bulletin No.75-04A with the inspector. The Bulletin reply is in preparation.

~ ~

S 0

REPORT DETAILS

). Personnel Contacted J. Gebert, Maintenance Superintendent T. Gucciardo, Electrical Engineer J. Vinquist, Electrical Maintenance Supexvi or

2. Construction S ecifications The inspector reviewed Bechtel Power Corporation's electrical engineering data letter No. 10 revised, fixe stops for cable penetrations in floors and walls. <The following summary is I

provided:

(1) Floor Penetrations (a) Fire Sto s for Cables Throu h Floor Sleeves'arinite board is used as a form beneath the floor. The void area around .the cable is filled with Thermal Insulat-ing klool. Flamemastic is applied to the cables inside the sleeve and built-up to 1/~> inch on top and bottom to form both a ventilation seal and fire stop. If the sleeve is in the open a second piece of marinite is installed on top the sleeve. 1'lamemastic Hastic is applied in a 1/8 inch layer on the penetration bottom to protect the hold-ing screws in the Harinite.

(b) Fixe Sto for Cable Tra s Throu h Floor 0 enin s The installation is simil'ar to 2.a.l.a above with some differences. For normal building slabs the opening is closed to within about 1 foot of the tray before the fire stop is installed. For 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated slabs the opening is closed to within about 1 inch. For fire rated slab closures, the cables inside the penetration are coated with Flamemastic. Then the opening is closed and the Harinite form and Flamemastic seal are applied to

~

the bottom of the penetration.

(c) Fixe Sto for Cable Tra s Runnin Verticall Mithout Floor Fire Sto s Vertical cable tray runs have fire stops installed a minimum of every 20 feet. These are similar to 2.a,l.b above..

Y W

(2) Mall 9enetrations (a) Fire Sto for Cables Throu h Mall Sleeves

=

This is similar to 2.a.l.a above, except that Marinite is installed on one side only. Xf the sleeve is offset to prevent streaming, Harinite and Flamemastic is applied to both sides of the wall at the opening.

(b) Fire Sto for Cable Tra s Throu h Wall 0 cnin s This is similar to 2.a.l..b above.

b. The inspector reviewed "Johns-~Lfanville" literature for Harinite.

The following summary is provided:

(1) Harinite carries the following Underwriters Laboratories i:ire hazard classification:

Flame Spread 0 Fuel Contributed Negligible Smoke Developed 0 c ~ The inspector reviewed Bechtel Specification 788'~-E-503, conduit and tray notes and details. The following summary is provided:

(1) Cable trays used for instrumentation shall be steel solid bottom. Xnstrumentation trays containing low level signals shall be covered.

(2) Covers shall be provided on each top tray run below floor gratings and in open areas where cable damage is likely.

(3) The minimum vertical distance between trays installed in tiers shall be 16 inches.

(lt) hll tray penetrations through floors, walls, and ceilings into areas which are otherwise isolated shall be provided with fire stops. Vertical runs of cable trays shall be provided with at least one fire stop every 20 feet.

~

(5) Xn manholes, all cables 5 kv and above shall be fireproofed from the point of entrance to the point. of exit with asbestos tape or other approved fireproofing and arc resisting material.

~

~

S

d. The inspector review'ed General Electri.c Design Specification 22A3128, electric equipment separation for safeguards systems.

The following summary is provided:

(1) Rcactoi Protection S stem Hiring for the reactor protection system outside of the main protection system cabinet shall be run in rigid conduits used for no other wiring.

(2) Fire Hazard Zones (a) Where routing of cables through areas where there is potential for accumulation of combustible liquids is unavoidable, only one division of RPS, NSSSS or ESS cables is allowed.

(b) In rooms where the only source of fixe is electrical in nature, cable trays must have a minimum 3 foot horizontal separation or be separated by a fire xesistant barrier.

(c) For redundant: portions for ESS and ESSSS, the minimum vertical separation is 5 feet. The lower tray must

. have a solid metal cover and the upper tray a solid metal bottom.

(d) The minimum vertical separation for tray cross overs i.s 18 inches. The lower tray must have a metal bottom extending 5 feet from the intersection. *

(e) Any openings. in. floors, for vertical runs of RPS, NSSSS, or ESS cables must be sealed with fire resistant material.

(3) Control Room Panels (a) Panels less than 3 feet apart containing circuits of different divisions must bc separated by a steel barxier.

(b) Floor to panel fire barriers must separate adjacent panels with closed ends.

0

~ = ~

(c) Pgnetration of separation barriers within panels is permitted if the penetration is- sealed such.

that an electrical fire could not reasonably propagate'rom'ne side to 'the other

<<C.' e. The inspector reviewed the following cable specifications:

(1) Bechtel S ecification 7884-E-18 5 kv Power Cable F

This cable is certified fire resistant in accordance with a test performed by the Kerite Company on October 21, 1970.

(2) Bechtel S ecification 7884-E-19 600 V Power and Control Cable (a) This cable is required to pass a horizontal and vertical I

flame resisting test.

F (b) This cable must pass an additional flame resisting test in accordance with lPCEA Standard 5-19-81, 6.19.6.

(3) Bechtel S ecifications 7884-E-23 A and B S ecial Wire and Cable I

This cable is required to pass a horizontal'nd vertical flame resisting test.

f. The inspector reviewed Bechtel Drawing 788-H-95, Sleeves and Seals D tails, P netrations and Blockouts

3. 'aintenance and Modification Procedures

a. The inspector reviewed Bechtel Specification 7884-E-512, Cable and Hire Xnstallation which states:

The installation of conduits and raceways shall be in accordance with 7884-E-503. (Paragraph 2.c, Report Details)

(2) The installation of fire barriers shall be governed by "Engineering Data Letter No. 10, Pire Stops for Cable Penetrations in Floors and Walls". (Paragraph 2.a, Report Details) inspector reviewed the following documents:

Cable and raceway installation control, form No. 1040.8 (2) Scheduled raceway installation, repair procedure No. RP-RAC/IE-l.

F

p (3) Scheduled cable installation, repair procedure No.

RP-CAS/lE-1. \

c~ The inspector stated that the above procedures did not provide assurance that a penetration would be xesealed if a new cable were pulled. The licensee stated that the scheduled cable

. installation checklist (Form E-700) was currently being revised to make this provision.

Visual Examina tion I

The inspector toured the facility with Mr. Gucciardo to determine the

'extent of conformance'with the specifications in Paragraph 2. Specific areas examined were the Control Room, Cable Spreading Room, 1A3 and lA4 Switchgear Rooms, Reactor Building, Turbine Building, and Diesel Generator Rooms. The inspector found the plant to generally conformed to the bulk of the specifications.

However, the following areas of concern were identified.

P (a) Penetrations not sealed. Examples are:

(1) Opening in Marinite boar/ in Control Room (XU5X) with

~

. no Flamemastic.

(2) Six inch sleeve 2C257 in Cable Spreading Room.

(3) Four inch conduit 2P877 in lA4 Switchgeax Room.

(4) Opening in wall between 1A3 and lA4 Switchgear Rooms.

(b). Penetrations not resealed. Examples are:

(1) Generally all panels in Control Room which have had cables added have not been resealed.

(2) Six inch sleeve 2C242 in Cable Spreading Room.

(3) Cables in Control Room have been removed from seal tight flexible conduit and the conduit not resealed.

(c) Penetrations resealed, but not conformance with specifications.

Examples are:

(1) Flamemastic replaced with Duc-Seal in Contxol Room.

I h

~ ~ II

(. Hinit'Foam replaced with Duc-Seal in Cable Spreading Room penetration 2C253.

r Six inch sleeve P-805 in Cable Spreading Room stuffed with 0

foam.

(4) Concrete replaced with Duc-Seal in Cable Spreading Room penetration P-804.

(d) Combustible foam in penetrations. Examples are:

(1) peneLrations which have never had the foam construction damn removed.

(2) Pc>>ctrations which have been resealed and stuffed with foam.

The inspector noted that the several penetrations in the control panel were filled greater than the 40 percent required by specifications

5. Bulletin Status The licensee is preparing a reply to XE Bulletins No. 75-04 and No.75-04A.

~ (p7%

U. S. RJCLEAR REGULATORY COKifXSSXON OPPXCE .OP XHSPECTXON AND ENPORCLfENT REGXON XXX Report of Operat:ions Xnspection XE Xnspcction Report No. 050-255/75-09 Licensee: Consumers Power Company 212 'Hest Hichigan Avenue Jackson, I'fichigan I<9201 Palisades Nuclear Genprating Plant Licen e No. DPR-20 Covert:, Hichigan Category; C Type of Licensee: P>m (CE)

Type of Xnspect:ion: Special Announced Bat:es of Xnspection: April 28, Ifay 5-7, 1975 Dat:es of Previous Xnspect:ion: February 12, 27, Harch 6, 14, 20, 21, 25, 26, April ll, 13, and 16, 1975 (EXP)

Principal Xnspect:or:  ;~K. }~ Baker ~~ /6 iS'

~(Da .e)

Accompanying Xnspec tor". None Ot:her Accompanying Personnel: None Reviewed By: 1,'. L.f/Jordan Senior Xnspector Date)

Projects Unit 2 React:or Operations Branch

~ ~

I SUMfARY OF FXNDXNGS Enforcement Action None.

r Licensee'ction on Px'eviousl Ident:ified Enforcement Matters Not. inspect:ed.

Unusual Occurrences Hone.

Other Si:,nifi.cant I indin's A. Cux'rent: Findings I'ixe st:ops and ventilat:ion seals for. cable trays were observed that did not: appear to be in conformance with design specificat:ions. Licensee i.s prepaxing fina3. replies t:o IE Bulletins 75-04 and 75-0~~A. A portion of the act:ions required by the XE Bu3.let:ins 'is in progress.

13. Unresolved Xt:ems Repairs/modification t:o fi.re stops and ventilation seals. (Paragraph 5)

Mana cment Xnt:erview

~ The following it:ems were discussed with Mr.. Lewis, Plant: Superintendent on May 7, 1975:

The licensee stat:ed t:hat: an overall review of fire protection was in progres . Besides design it includes t:raining and fire fighting equip-ment, (Paragxaph 6)

The need for. a thorough comprehensive inspect:ion of t: he fire stops was discus ed. The licensee stated that such an inspection would be performed.

C. The licensee stated that any repairs t:o seals would be made using approved procedures and with mat:erial that was qualit:y assured.

(Paragraph,~i)

D. The licensee st:at:ed that: a long t.erm soluti.on to prevent rnodific,.tions and other work from degrading the fire stops was being developed.

(Paragraph 4)

~ ~

E

'REPORT DETAILS l, ~

Person.. Contacted J. -Letris, Plant Supexint:endent:

G. Sladc, Operat:ions Superintendent K. Berry, Technical Superint:endent

11. 1:eiser, General Engineer G. 11ein, 1faintcnance Superintendent:

2, 'Xns ect:ion Sco e I

A special inspection of fire barriers.and air. seals was performed.

3. '

iecifica t:ion A review of tlte facilities'peciiicat:ion fox fir'e'barriers and was made. The only specification covering t:hose was E-42, Rev. l.

air'eals This specification deals with cable t:rays. Xt,does require t:hat venti-

'lation seals be inst:alled for. the cont:rol room. The,specifi.cat:ion.

in general requires iire t:ops t.o be installed in cable tray. entering various rooms. The fire stop is made of Harinite-36 (asbestos fiber board) ~< inch t:hicl:. Voids in the cable trays and board are t:o be stuficd wit:h an inorganic t:hexmal insulating wool covered and sealed wit:h < inch of Flamemastic 71A.

4. 'aintenance and Hodification Procedures Facility modification and maintenance pxocedures do not address fire st:ops. No facilit:y procedures exist. for repair or installation of iixe st:ops, The specification. E-I~2 had been revi.sed to require its application to the cooling tower and new rad~ aste installati.on, but a review of the inst:allation indicated fire st:ops had not: been inst:alled where cables were brought into t: he Control Room.

5. Xnstallat:ion The inspect:or toured, various areas requi.red by specification E-42 t:o have fire stops. The following t:ypes of deficiencies were noted ~

in most areas inspect:ed:

ae 1 ire stops not installed.

b. 11oles or. removed Flamemastic created by cable removal/installation.

c ~ Fire st:ops and ventilation seals not in tailed in complete compli-ance with speciiication E-~>2.

The licensee records indicated that in December, 1974, tests s'bowed the abi.li.ty to maintain positive prcssure in the Control Room with the pre ent installation of fire stops and ventilation seals. When the inspector brought the opening in the Control Room to the licensee's attention the openings were temporarily plugged by stuffing the openings with inorganic thermal insulating wool.

6. 7H')3ulletins 75-04 and 75-04A ihe licensee responded to these bulletins by requesting more time to prepare an answer. The licensee has various groups wor):ing on the reviews required by these bul"etins.

The inspector discussed various aspects of the fire fighting g> xng, training and equipment with the li.censee. These discus ions indicated the licensee was reviewing the adequacy of training (breatliing equipment, use of water on electrical fires, etc.), access to vzriou areas and equipment under adverse conditions, and available emergency equipment.

U ~ S. NUCLEAR REGULATORY COICfISSION OFFICE OF INSPECTION AND ENFORCEMENT REGXON XXX Report of Operations Inspection IE Inspection Report No. 050-263(75-08 Licensee: Northern States Power Company 414 Nicollet Mall Minneapolis, Minnesota 5540l Honticello Nuclear Generating Plant License No. DPR-22 Monticello, Ifinnesota Category: C Type of Licensee: BWR (GH) 545 yff~e Type of Xnspection: Special Announced Dates of Inspection: April 23 and 24, l975

.Dates of Previous Inspection: April 2-4, 1975 (Radxologzcal and Environmental Protection Branch)

?c'(r'r~

Principal Inspector: lfaura 'ri.-/.=

(Date)

Accompanying Inspectors: None Other Accompanying Personnel: None C".

Reviewed By: H. Dance Senior Reactor Inspector )

(Date)

Reactor Operations Branch I

<<,l

II

'e ~

~

SUKfARY OF FI%)XNGS ~ \ ~

e> e h Enfozcemcne Action J ~ ~

None.

Licensee Action nn Previousl Identified Enforcement lfaeters Noe inspected.

Unusual Occurrences None.

'Other Si nificant Findinp~s A. Cuxrent Findings None:

B. Status of Previousl Re orecd Unresolved Items e

Not inspected.

~liana emana Inaavviav A man'gement interview was conducted with Hessrs, Larson, Plant ".tanager; Clarity, Superintendent Plane Engineering and Radiation Protection; Anderson, Superint:endcnt Operations and ifaintenance; and members of the licensee's staff at the conclusion of thc'inspection on April 24, 1975.

A. The inspect:or seated that none of the penet:rations appear to have the approximate 2" thickness of Flamemastic stated by a Bcchtel Corpoxat:ion lett:cr dated Narch 25, 1975. In fact sor,",e penet:rations only have Flamcmastic coating only a few mils thick. In view that: the licensee no longer uses Flamemastic, but Pyroczcee, a Carboline product for which a minimum thickness of ~<" is recorrmended, the inspect:or zcqucseed that t: he licensee review the Bechtcl's xeco-..mendation, reach a conclusion as to the required thickness, and implement a program to upgrade the present ehexmal barrier for all electrical peneerations.

The licensee agreed to proceed with such a pxogzam. (Paragraph 3, Report Details)

B. 'he inspector noted that, using core spray pumps No. 11 and 12 as czampr'es ie appears that the separation criteria outlined in the FSAR foz cables routed through the cable spreading room i.s being met. However, duc to

, the lack of cable identification in thc room considerably more effort would be required to confirm ehc condition. (Paragraph 6, Report Details)

~1 I

C. The inspector stated that a review of the self contained breathing equipment 'at the site, in light of'he problems experienced at another facility, revealed that, the licensee should consider:

\

1. 'Mhe'ther an adequate supply of air to refill used containers exists and where to obtain refills after normal working hours, specially during weekends.

2.

Training personnel, specially the members of the emergency or fire teams in the use of the Scott Rescue Pak.

~

The licensee stated the capabilities of the <<fonticello, Anoka, and St.

Cloud Fire Departments in supplying breathing air refills to the site will be determined. Also a training program in the use of the Scott Rescue Pak will be carried out. (Paragraph 7, Report Details)

D.-" The inspector requested and the licensee -agreed to generate guidelines to be used by the station on )cow to fight all types of fires and in particular when to use water on electrical fires. (Paragraph 8.b, Report Details) r

< ~

h

~ I

~

3 tt

~ (.

' ~

~ g

REPORT DETAILS Persons Contacted I

~"

C. Larson, Plant Hanager H.- Clarity, Superintendent, Plant Engineering and Radiation Protection H. Anderson, Superintendent, Operations and ?daintenance D. Antony, Plant Engineer, Operations EI. Nimmo, Haintenance Supervisor H. E?ammer, Instrument Engineer .

R. Perry, Engineer

2. Construction S ecifications I The specifications available at the site consisted of Bechtel'wg H-636, Revision 0, issued for construction on February 1.3, 1970 and recent correspondence between the licensee and Becntel, Corporation. For .all typical penetrations shown in Drawing H-636 Revision 0, the sealing material specified was polyurethane covered on both sides with Flamemastic 71A of unspecified thickness. The polyurethane used was made by 3ustafoam Products, Inc., and has a trade"name Insta Foam Froth- Pak.

According to a recent letter (March 25, 1975) from Bechtel Corporation the Flamemastic thickness was approximately 2 inches. The licensee has recently switched i:rom Flamemastic to Pyrocrete 102, a Carboline product,, as thermal barrier. Carboline recommends a minimum thickness of 1/4 inch.

) C Xn addition to the construction drawings the FSAR Section 8, describes the routing and physical barriers used to separate and protect redundant channels or systems.-

3. Visual Examination The inspector verified that:

All cable penetrations have been sealed as required.

~ I The control room end of the penetrations have been r'einspected by the licensee and where required a new coating of pyrocrete ha been applied, The thickness appears to exceed 1/4 inch.

Ce Xn the cable spreading room most penetrations are covered with I'lamemastic, but a few show areas where the urethane's visible.

Where applied the Flamemastic thickness appears to range from a thin coating up to approximately 1/2 inch.

0 d; -

In the .reactor..building..most of the penetrations of cables going to the cable spreading room had very thin Flamemastic 'coa'ting" in '

the order of a few mils. . Specifically penetrations P-117 thru

'I P-120 had little dr no thermal barrier covering the polyurethane sealing material.

e. The same typical defici'encies noted before existed in the t'urbine building,penetrations, L

f. In the battery room it was noted that a7.1 cables are enclosed in conduit and the penetrations are covered by. conduit termin-ating in metal junction boxes. j

g. Spare penetrations arc filled with po7.yuxethane and cover'ed with Flamemas tic.

Smoke detectors are installed in the cable spreading room and annunciate in the control room. The det:ectozs axe supp7.ied with non-interruptible 120 V AC power.'

Cardox system does not exist at the site.

4. Haintenance and Hodification Procedure's The licensee does not have procedures which pecifically cover how a penetration is to be made, sealed or repaired. The licensee stated rocedurcs for a particular job would be developed as needed and 'n ~

accordance with their Adminzstrative Contxol Directives Ho. 3 Revision 1, Design Change Xnstallation Procedure; and No. 3ACD 4.3 Revision 1, Design Change Preoperational/Operational Testing. The licensee did state that the Task Force will be considering the prepar-ation of a specific procedure to cover the sealing and/or repair of cable penetrations. The inspector verified that the licensee has modified his list of critical equipment {Ali'I 3.6. 1 Revision 2) to include cable penetrations in order to require a second level'f review by plant management prior to the performance of any work on the penetrations. I

5. Res onse to XE Bulletins 75-04 and 75-04A The licensee had prepared a draft response to XE Bulletin 75-04 and had submitted it to his HO. lie was not awaxe whether. the response had been mailed to XE, and if any changes had been made to the draft.

Regarding Bulletin 75-04A the licensee was forming a Task Force to look into the Browns Ferry fire and the requirements of the Bulletins.

The members of the Task Force had not been named as of the time of our inspection, therefore,. the licensee's effort in the areas covered by XEB 75-04A were yet to commence.

0 0

j II'

~ ~ I 6.'e iaration Criteria The inspector attempted to physically determine whether the separation criteria outlined in the FSAR Section S,had been applied. Core spray pumps No. 11 and 12 control cables were u'tilized as examples.

Through the use of cable tray numbers, cable routing. lists; etc..

the pat>

(Date)

Accoplpanying Xnspect:ol I None Other Accompanying Personnel: Hone Reviewed By: L. E. ordan Senior Inspect:or tDat )

Reactor Operations Branch

1 SUN1ARY OF FINDINGS Enforcement Action: None Licensee Action on Previousl Xdentified Enforcemcnt hfatters None outstanding.

Unu ual Occurrences Hone inspected.

Other Si .nificant Findin s A. Current Findin s The unit is currently operating essentially full power in a base load mode.

B. Unresolved Xtems Hone C. Status of reviouslv Re orted Unresolved Items Honq.

liana emcnt Xntexview The lfanagement Interview was conducted on April 25, 1975, with tlessrs.

Louma, Plant Supexintcndent, and 7 ange, Assistant to the Superintendent, Haintenance ~

The items discussed included the following:

A, Construction specification for electrical penetration. (Paragraphs 'a 3d)

B. Results of Regulatory in pection of electrical penetration. (Para-graph 3d)

C. Current practi:ces at plant. (Paragraph ~i)

D. Compliance with the final safety. analysis report. (Paragraph 5)

E. ,Plant Pire Protection System (Paragraph 5 c)

P. X,icensee's Response to XE Bulletins 75-'O~i,75-04A. '(Paragraph 6)

I REPORT DETAILS

l. P Persons Contacted Misconsin Public Service Corporation (tfPS)

C. Louma, Plant Superintendent R. Lange, Assistant Plant: SuperinLendent, Haintenance J. Ruege, Quality'Assurance Sup'er'vi'sor.

R. Itirst, Haintenance Supervisor

2. General I t

I Special Inspect:ions were conducted on April 23, and 25, 1975 t:o determine the plant status in reg'ard to the provision of acceptable fire st:ops and ilame ret:ardanL seals P

f'r electrical penetrat:ions.

The major inspection effort was of the elect:rical penet:rations in the following areas:

Cont:rol Room Relay Room (cable spreading room)

Auxiliary Equipment and Ventilation Room (above cont:rol room)

Diesel Generator Rooms Portions of t: he Turbine Building Portions of Lhe Auxiliary Building The inspection included a review of a represent:at:ive sampling of the complet:ed plant work request and modification request iorms, plus discussions wit:h t: he plant elect:rical Supervisor, the Quality Assurance Supervisor, and the Assist:ant to the Hanager, Haintenance.

Also included in this inspection was a sampling comparison of License commitments in the Final Safety Analysis Report (PSAR) against:

t.he act.ual condxLxons not~ existing at t: he plant.

3. Penetration Seal Haterials The followinp materials and specifications were utilized in pro-viding the fire-stops, sealing and fire retardant: protection for the various electrical penetrations and trays at: t:his plant; These iire-st:ops are one inch thicl: sheets of "Harinite Board" manufact:ured by the Johns-Hanville Company. The basic materials are cement: and asbestos,.

0

b. ~ Pire-Retardant Materials 1, 1'lamemastic 71A manufactured by t:ho Dyna-Therm Corpora-tion. This is a water base -material which is non-flammable 'at 'all times.

2. R,T.V.124 and Sll manufactured by General Electric Company. Thi" material is documented by U.L. Tost Sub)oct 94 to be type SE-.O or H self-extinguishing rating, c ~ Sealant Materials The sealant: materials which are packed in around the electri-cal cables in t: he electrical penetrations axe all of. t:he inorganic fiber insulat:ion type of materials

1. Thermal insulating wool {glass) Johns-Manville.

2. Cerafibex - Johns-Manville.

3. Kaowool {glass) Babcock & Milcox Company.

Plamemastor Dyna-Therm Coxporat:ion.

These materials are specified as non-flammable and identified in purchase order spocificat:ion on order E;664.

Thus, in summary, none of t: he materials used in sealing and iire retardant coating of these electrical penetrat:ions are at: any time flammable.

d. Penetration Sealant and Flame Retardant S ocifications.

Det:ailed penetrat:ion sealing, fire ret:axdant application, and fire-st:op specifications are provided for eight different typos of penetrations. These spocificat:ions are provided by Pioneer Service and Engineering Company on drawing Ko. 237127A-F2639P, Revision P, 11-1-73. These pocificat ons were reviewed by the inspector prior to t: he physical examination of the various electrical penetrat:ions in tho plant:. Several minor deficiencies were observed as follows:

(1) One non- afety related cable in a multi-cable penetration from the relay room to tho cont:rol room was <<ot coated with a flame-retardant material. Xt appeared that this cable had been installed after t: he penot:ration was origi>>

nally sealed. The cable was firmly packed i<< fiber glass

wool.to provide a'eal, however, no flame retardant had been applied dixectly on this single cable. All other cables were coated with flame retardant material.

(2) Three 2" conduits originating in the relay room and terminating in the control room were not sealed, that

's, a draft could bc felt: at the Control room end of these conduits.

(3) Two 2" spire conduit openings between the Relay room and the Auxiliary buildings were not sealed.

(4) At several electrica1 penetrations fire stops, the flame-mastic 71A fire retardant material was observed to be cracked, apparently due to shrinkage upon drying. This cracking up to <" in width, did not provide a pressure/smoke seal around the fire-stop.

The licensee is currently examining all safety related electrical penetrations for conformance to the specifications identified above. The licensee has stated the intent to correct any deficiencies found, including the four identified above, as expeditiously as time and plant conditions allow.

The. four deficiencies are not considered as immediate'y serious by the inspector since they pose no fire propogation threat, but zathez a smoke control pzoblem. This plant utilires a multi-mode ventilat'on systein"/ which is designed to assure that smoke from any other portion of the plant can be prevented from entering the contxol room or. can be swept out if it originates in the control room. As a backup measure the in-spector observed that there are two self-supporting air

~

breathing masks available in the control room. Also this plant is designed with the capability for a shut-down from out ide of the control room. This capability was demonstrated as a part of the plant start-up and power ascension testing.2/

Duxing this inspection the inspector re-reviewed this capa-bility. Xnspections at the control cabinet vexified that 3 contxol center, multi communications systems, and procedures /

are current and ready for use.

Current Practices

a. Discussions with the Electrical Supervisor and the Plant Emergency Conto3 Room air conditioning system operation E-ACC-25.

Power ascension test no start-up test Ho. 6.3, procedure H-0-06, on ofay 3, 1974.

Emergency procedure H-0-06 control zoom inaccessibility.

0 f

Quality As uxance Supervisor, plus a review of 'plant'work request and modification records indicate that none of the safety related electrical peneerat:ioris 'have born disturbed since final conseruction. Thus, there has been no need for special pxocodures for ro-sealing an electri.cal penetration.

General maintenance procedure Gi'F No. 202, cable pull, carries a note to remind personnel'f t:ho need t:o xoeurn ehe ponetrationeto "Ori'ginal st'acus" after ea'ch cable-pull activity.

However, this procedure does noe reference tho con t:ruction speci.fications referenced in it:om 1-D above. Tho licensee will consider listing this reference in futuro revision of G))P 202, na The licensee does not believe that individual penetraeion seal testing to insure tnat a t:otal pressure seal exists is necessary for penetrations other than containment boundary pcnetrat:i.ons.

This position is based on dosigned independe>>cc-between t: he various plant ventilat:ion control systems to permit sweepin of smoke from e)>e various portions of the plane wit:houe t: he smoke being int:roduced into the control room. The separat:o cont:rol room vent:ilat:ion system is designed with the capability to purge any smoke originating in the control room directly t:o .

atmosphere, or to opexat:e in a t:otal recirculat:ion, totally filtered mode. Thus, the licensee doe noe int:end to perform individual penetration seal t:est:s. They do intend to adhere eo t: he penet:ration specificat:ions of item 3-d above in providing a flamo st:op, flame retardant fire barrier type penetration with reasonably tight smoke limiting seal. The inspector's review of PSA)'. and t: he ponetrat:ion specification indicates t:hat neither specifics t:hat a measurable pressure seal exist:,

but rather that a "Pire )3arrier" exise. No open flame is u ed in the t:eseing of seals or penetrations in'the Plane.

5. Com lienee nits final Safetv'Analrsc~s Re ert Other it:ems inspect:ed and compared against: the commitment of ehe PSAR include the following: (sampling basis only)

The Hain Auxiliary, Reserve Auxiliary and Tertiary Auxiliary Transformers are located outdoors and are phy ically separated from one another by firewalls. Each transformer cell, formed by the firewalls, has an automatic water spray syst: em to extinguish and prevent: eho spread of fires.

b., Ampere ratings for t: he power conduct:oxs used are based on tl>e National Elect:xical Code, 1968 Edition (USAS Cl 1968)90o

rating, with a dcrating factor of 80% applied across thc board to comply with section 318-6 of the National Electrical Code. The power conductors are three conductor, galvanized armored and installed in a single layer in ladder typo cable trays, which. are clamped to insure that ample ventilation spacing is maintained throughout the run.

All cables, exclusive of lighting circuits, have fire and radiation resistant jackets designed to withstand the radiation, temperature and humidiL'y conditions of the containmenL atmos-phere following a loss-of-coolant accident.

Cable sep ration is provided between redundant systems so that no single failure or incident can render both redundant sysLcms inoperable or rcmove them from service.

Redundant circuitry for reactor pzotection and engineered safety systems are separated into six color coded Class lE c'able groups.

Hach group is run in a separate tray, ladder, trough ox conduit.

These tzays are identified on electrical drawings for engineered safety features and arc marked and color-coded on'he actual haxdware, All trays foz the engineered safety feature equipment are Class 1 structures.

Cable trays used for zedundant reactor protection systems, engineered safeguards systems and Class 1H electrical systems have an identifying code number stencilled on them in colored paint after they are installed. The number is applied when-ever there is a chango in identity or. when pa sing through floor ox wall openings. This number is applied prior to the pulling of any cables, and the color established the syst: em to which it is assigned'or the non-Class lH systems thx'oughout thc remainder of the plant, trays installed in stacks are spaced vertically with of 12" bottom-to-bottom in all areas. Ilowever, Class a'inimum 1E trays have a minimum of 15" bottom-to-bottom between trays of the same train. Class lE trays contain'ing instrument, control or power cables have a minimum horizontal separation between redundant circuits of 36". Redundant circuits are not permitted in the same tray or conduit. Tf closex spacing

.than 36" cannot be avoided, an approved barrier. is placed between the circuits. Cable trays are xouted to avoid a fire hazard area< such as oil storage rooms> oil tanks> et'

0 0

whenever possible. When t:his cannot bc done, thc 'cabl'e t:ray system is protected by fire resistingibarricrs. Where practical, these barriers are t:ray covers. Hi>enevcr possible a Mall or floor has been introduced. bet~recn t:x'ays carrying'

~

redundant safeguard circuits;. Fire barriers are provi<led '

Mi>ere mut:ually-redundant: txays cross., ,

k \

chere thc 'Airing for redundant engineered safet:y features is Mithin a single panel or panel section, this "riring is s'eparated, one group from the other by a six-inch (6")

air space or a fireproof barrier. The barriers are sheet:

met:al or. flexibl'e me'tallic'oriduit." Spec'i'al "fib'r'rgla'ss hous'ngs have been installed axound some safeguards relays inside safeguards cabinets in t:he control zoom.

Plant; Fire Protection S stem The inspector. verified t:hat: applicable poxtions of t: he FSAR section 9.6.1., fire protect:ion syst: em, are current:ly funct:ional:

j (1) Cont:rol- Room Prot. ection (a) Observed three portable CO and one ansul e>:tinguishers in t: he cont:rol room.

(b) Observed four poxt:able CO 2 and four portable ansul extinguishezs. immediately avail,.ble to the control rooms (c) Observed one large ansul unit: immediately availablc t:o the control room.

(d) Observed trio deluge spxay nozzle and 'fixe hoses immediately available to the contzol room; (e) Observed special fire annunciat:or panel for t:"reive separate sections of the control room with separate annunciation for each of 12 smoke detect:ors.

(f) Observed zone stat:us light: panel for fire annunciation ior zest of plant; ~<7,annunciators including e3.cctrical pentrations and cable runs.

(2) Rela Room Protect:ion (a) Observed one portable CO . extinguisher in relay room.

(b) Observed one C02 hose reel and deluge in relay room.

(c) Observed two smoke detectors @it;h 3.ocal pyrotronic" annuciator units, (Also annuciate in control room)

1 0

~ ~ ~ (3) DS.esel Generator Poom (a? Obse'rved sm ke and t".em'erature detector units (b) Ob.,erved CO deluge spray nozzles. Each diesel y( 6

~,

ieeiisee's-generator room is provided with an automatic deluge f ron a 300 psig CO- system; Res on.".e sols biille6kns 75-'0<i s

0<i-A CO 2

The licensee issued a response to theo " bulletins on April 23, 1975.

The licensee has requested that responses to questions 3 and 4 oZ this bulletin be extended to Hay l2, 1975.

The licensee is actively pursing the answers to these questions.

~ ilI,

-10<<

UNXTED STATES NUCLEAR RECULATORY CO."CfXSSXON OFFXCE OF XNSPECTXON AND ENFORCE.fENT REGION XXI Report of Operations Inspection IE Xnspection Report No. 050-254/75-09 XE Xnspection Report No. 050-265/75-09 Licensee: Commonwealth Edison Company P. 0. Box 767 Chicago, Illinois 60690 Quad-Cities Nuclear Power Station License No. DPR-29 Units 1 and 2 License No. DPR-30 Cordova, Xllinois Category: C

. Type of Licensee; GE Bf&

I Type of Inspection: Special, Announced Dates of inspection: April 28, 30, and Ifay 1, 1975 Dates of. Previous Inspection: April 7-9 and l7-18, 1975 - Unit 1 (Operations)

,April 22 and 23, 1975 Unit 2--

(Construction)

Principal Inspector:

~. <-I~,W 1.5

. Jr

/Date)

'Accompanying Inspectors: None Other Accompanying Personnel: None Revie@ed By: }I. C. Dance Senior Inspector C ':~ (Date)

Nuclear Support Operations Branch i ~

4

) D bn

SUt."mRV OP FINDINCS Enforcement Action: None.,

Licensee Action On Previousl Identified Enforcement Items'None required.

Unusual Occurrences: None.

I Othex Si nificant Findin s I

A. Curxent Findin s Unresolved Items Review of construction procedures has been incomplete.

(Paragraph 3.b, Report Details)

~ b. The basis for tying together safeguaxds cables was not readily explainable. (Paragraph 4.e, Report Details)

'l B. Status of Previousl Re orted Unresolved Items: Hone inspected.

Hang ement Interview The following subjects were discussed at the conclusion of the inspection

'on Hay 1; 1975, with ~fessrs. Stole, }1ausman, Kalivianakis, and members of Hx'. Kalivianakis's staff.

The inspector summari"ed the findings of his visual examination of penetrations. The inspector 'stated that a large number of the penetrations did not conform to specifications. The licensee acknowledged that this problem existed. (Paragraphs 2 and 4, Report Details)

C B. The inspector discussed the modification control procedures with the licensee, and in particular the fact that not all procedures for safety related modifications are reviewed by the oper"tions group prior to implementation. The inspector stated that this would be considered an unresolved item pending fux'ther investigation.

(Paragraph 3, Report Details)

C. The inspector 'questioned as to whether cables fx'om Divisions 1 and 2 safeguards systems should be tied together inside of panels.

The licensee stated that the separation criteria existing at the time Quad-Cities was constructed had been met. The inspector stated that this would be considered an unresolved item pending further investigation. (Paragraph 4, Report Details)

D. The licensee discussed the reply to IE Bulletin No. 75-O~iA with the inspector. The licensee stated that the station had several personnel including the station fire marshall, on the volunteer staff of the local fire department. As a result of this involvement, much attention had been given to fire fighting, training and equipment.

REPORT DETAILS

1. Personriel Contacted N. Kalivianakis, Plant Superintendent K, Grasser, Haintenance Engineer R. Querio, Technical Staff Supervisor

}f. St.olt, Station Nuclear. Design Engineer J, Hausman, General Engineer

2. Construction S ecifications The inspector reviewed Sargent and Lundy Standards. The following summary is provided.

(1) Cable Pan Fire 'Sto and Air Seal Throu h Wall (STD-FA-175)

The opening and void between cables is filled with Thermal Insulating Wool. A 1/4 inch layer of Flamemastic is applied over the Thermal Insulating Wool to form the seal.

(2) Fire Sto in Cable Riser (STD-EA-176)

The support for the Thermal Insulating Wool is installed at the bottom of the fire stop. The Thermal Insulating'Wool and flamemastic is applied as in 2.a.l. above.

(3) Control Board Cable Entrance Seal (STD-EA-179)

Similar to 2. 92 above except the bottom support is specified as ebony board.

b.'nspector reviewed Sargent & Lundy drawing 4E1079, Electrical Installation-Reactor Building, which stated:

(1) After cables are in place, stuff turbine building end with Duc-Seal and Oakum, then fill inch from reactor building thick seal of GE side with foamed cement and 1 Silicon Rubber type RV-108.

(2) All conduits that are a continuous run through .a secondary containment wall shall be sealed by inserting an "EYS" fitting, or approved equal in the run.

0 C~ The licensee stated that it had determined through discussions with General Electric that GE Silicon Rubber type RV-108 is moderately flammable.

'I d~ The inspector reviewed Owens-.Corning Fiberglass customer acceptance standard IN-1~i~~.13 for Thermal, Insulating Wool (TXll) Type IX:

(1) The product is designed for use on all heated 0

Xndustrial Applications at temperatures up to 1000 F.

(2) The product meets the following standards and specifications:

(a) Federal Specification HH-1-558B (Amendment 2)

(b) Form B, Type I, Class 7 and Class 8; (c) lorm C, Class 10; (d) Form D, Type IV, Class llew; (e) Hilitary Specification NIL-I-2818B (requires waiver of LOX)

(f) U. S. Atomic Energy Specifications and Guides Development (g) RDT Standard >f 12-1T (h) U. S. AEC Regulation Guide 1.36 The inspector reviewed a Factory ifutual Research Corporation Evaluation of "Flamemastic 71A". The following conclusions were reached:

(1) The Flamemastic when applied in accordance with the manufacturers specifications did not cause excessive cable heating for the maximum cable current permitted by the National Electric Code.

(2) The Flamemastic coating prevented the spread of fire when exposed to a moderate intensity ingition source.

f. The inspector reviewed a Franklin Institute Research Laboratories The following summary is provided:

Report of Flamemastic.

Samples of electrical cables were coated with Flamemastic.

Part of the samples were exposed to 2 x 10 rads of gamma irradiation. All of the samples were then given a flame test..

Xn all cases, the Flamemastic prevented propagation of the flame away from the ignition source.

The inspector reviewed a letter from the Nuclear Energy Property Xnsurance Association (NEPXA) to Brand Xndustrial Services which stated:

We have completed our review of your drawings FS-1 thru FS-4, as well as the sample of the foamed-in-place cellular concrete proposed to be used as fixe stops for the cable pans and conduit for the pass-through fire walls and concrete floors at the captioned locations. We wish to advise this material is

.acceptable to this Association as 17Cire stops at the above two locations for their propo ed use.

The inspector reviewed a second letter fxom NEPIA to Brand Xndustrial Services which stated:

Based on our office and field evaluation, foamed-in-place cellular concrete fire stops for cable pans and conduit for pass-through fire walls and floors as depicted in your drawings 1"S-l, 2, 3 and 4 (dated November 2~i, 1969) and covered in your BXSCO Specification 202-72 (August 1, 1972), "Specification of .

Nuclear Power. Stations" wil//be acceptable to this Association where we have jurisdiction.

3. Haintenance and Viodification Procedures a~ The licensee stated that there are no specific modification procedures to ensure that Sire stops and compartment boundary seals are maintained on a continuing basis.

b. The inspector determined through discussions with the licensee that safety related modifications can be implemented without the procedure being reviewed by the operations group. This can happen when the modification is sent from offsite to either the constguction or substation construction group. The inspector considers this matter to be an unresolved item pending further investigation.

1/ Ltr NEPIA to Brand Industrial Services, dtd 12/4/69.

2/ Ltr NEPXA to Brand Industrial Services, dtd 2/12/73.

~ l Visual Examina ti'on The inspector toured the facility with Hessrs. Stolt, 1Iausman, and other representatives of the licensee to determine the extent of conformance with the specifications in Paragraph 2. Specific areas examined were the Cable Spreading Room, Control Room, Auxiliary L'lectric Room, Reactor Building, Turbine Building, Piping Tunnel, and Die-"el Generator Room.

The inspector noted that plant personnel were in the process of filling penetrations with Thermal Insulating Mool. The Licensee stated that they were waiting for Flamemastic to arrive to cover the wool.

The inspector identified. 5 general areas of interest:

Unsealed Penetrations (I) Xn the Cable Spreading Room, most cable tray penetrations through the wall into The turbine Building are not sealed around the tray.

(2) Unsealed conduit sleeves in the Cable Spreading Room and the Control Room.

(3) An opening for. piping on a Cable Spreading Room wall.

b. Seals Mhich Do Not Conform to S ecifications (I) Pill Turbine Building end with Duc-Seal and Oakum. Then fill Reactor Building side with foamed cement and RTV.,

(2) All conduits that are a continuous run through secondary containment walls are sealed with "EY'S" fittings.

Cellular Concrete The inspector noted that the cellular concrete was cracking and crumbling in many locations.

d. Combustible Haterials at Various Locations (I) The inspector noted some combustible material in penetrations.

(2) Examples are:

(a) Mood form wired in place.

0 0

'I

hA I.' I ~ I~

(b) Mood in cable riser fire stop.

I (c) Foam Dam in secondary containment penetration.

I (1) Thc"inspector'oted that in the.'Auxiliary 'Electric. Room, cables.from divisions l and 2 of safeguards systems were tied in common bundles inside of the panels.

(2) Example are panels 902-32, 902-33, 902-40, 902-41, 902-

'6, and 902-50.

1 l

(5) The inspector considers this matter to be an unresolved item pending further investigation.

I 5.. Bulletin Status The licensee submitted the reply to the XE Bulletin No. 75-04 on April 25, 1975. The licensee is preparing a reply to IE Bulletin Ho.75-04A.

,'U S. NUCLEAR REGULATORY COiffXSSXON G

~ OFFXCE OF INSPECTION AND ENFORCEMENT

,i REGION XIX Report of Operations Inspection IE Inspection Report Np. 050-295/75-04 XE Inspection Report No. 050-304/75-03 Licensee: Commonwealth, Edison Company P.O. Box 767 Chicago, Illinois 60690 Zion Nuclear Power Station, Units 1 & 2 Licenses No. DPR-39 Zion, Illinois and No. DPR-48 Category: C Type of Licensee: PMR 1050 K~e (W)

Type of Xnspection: Special,. Announced Dates of Inspection: April 24 and 28, 1975 Date of Previous Inspection. March 27, )975 (REP)

/

/. ~. $ (c~w.g4~

Principal Inspector: T. L. Harpst'eraJ (Date)

Accompanying Inspector: None Other Accompanying Personnel: None C

Reviewed By: H. C. Dance, Senior Inspector Support Operations Branch

'uclear (Date)

SUKfARY OP PINDINGS Enforcement Action None Licensee Action on Previousl Identified Enforcement Items None required Unusual Occurrences None .

Other".Si nificant Pindings A. Current Findin s None B. Status of Previousl Re orted Unresolved Items Not inspected Mana ement Interview The following. subjects were discussed at the conclusion of the inspection on April 24, 1975, with Hessrs. Wagner, Stolt and Zunjic, and with ifr.

Stolt at Commonwealth Edison General Offices on April 28, 1975.

A. The inspector reviewed the findings of his visual examination of

~ penetrations. (Paragraph 4)

B. The licensee discussed the reply to IE Bulletin 75-04 with the inspector.

C.. The. inspector discussed-the penetration specifications with the licensee. (Paragraph 2)

~ O Personnel Contacted REPORT DETAILS G. -Wagner, Assistant Plant Supeiintendent R. Budowle, Quality Control Engineer D. Davidson, Engineering Assistant

~ H. Stolt, Station ibuclear Design Engineer S. Zunjic, General Engineer

2. Construction S ecifications

'The inspector reviewed Sargent and Lundy standards:

a>> Cellular concrete cable pan fire stop and air seal through wall (STD-EA-177).-

b Cellular concrete fire stop in cable riser (STD-EA-178).

These specifications state:

After cables have been installed, a fixe. stop shall be constructed as shown. The location of the fire stops will be as indicated on the Construction Drawings.

~ ~

b'. Temporary forms shall be installed to contain the cellular concrete. These shall be removed carefully after the fire stop is complete.

c. The cellular concrete shall contain no aggregate. It shall of a Portland Cement matrix around air voids which 'onsist are generated by a preformed foaming agent.

8. The dry density of the cellular concrete sh'all be from 25 pounds to 45 pounds per cubic foot, depending on requirements.

e. The mixing and application of the cellular concrete shall be as directed by Brand Industrial Services, Inc., 2350 West Fulton St., Chicago, Illinois 60612 or approved equal.

The inspector noted that the specification drawings indicate that the penetrations are to be completely filled with cellular concrete, although no dimensions are specified.

'V

3 The inspector reviewed Brand Industrial Services drawings:

a.. Fire stop for cable pan through wall (FS-I).

II

b. Cable riser fire'stop at floor (FS-2) ~

Ce Fire stop for .pipe and conduit sleeve through wall (FS-3).

Fire stop for pipe and conduit sleeve through floor (FS-4).

The inspe'ctor noted that the drawings indicate that the penetrations are to be completely filled with cellular concrete, although 'no dimensions are specified.

The inspector reviewed a letter from the Nuclear Energy Property Insurance Association (NEPIA) to Brand Industrial Services which stated:

Me have completed our review of. your drawings FS-1 thru FS-4, as well as the sample of the foamed-in-place cellular concrete proposed to be used as fire stops for the cable pans and conduit for the pass-through fire walls and concrete floors at the captioned locations. We wish to advise this material is acceptable to this Association as fire stops ~t the above two locations for their 1?

proposed use.

The inspector reviewed a second letter from NEPIA to Brand Industrial Services which stated:

Based on our office and field evaluation, foamed-in-place cellular concrete fire stops for cable pans and conduit for pass-'through fire walls and floors as depicted in your

~

drawings FS-1, 2, 3 and 4 (dated November 24, 1969) and covered in your BISCO Spec. 202-72 (August 1, 1972),

"Specification for Nuclear power Stations" will/>' acceptable to this Association where we have jurisdiction.-

I The licensee stated that no fire retardant coating was used on safety rela ted cables because cellular, concrete .i,s non-flammable.

)/ Ltr. NEPIA to Brand Industrial Services, 12/4/69.

2/ Ltr. NEPIA to .Brand Industrial Services, 2/12/73.

O. 4

3. Maintenance and Modification Procedures .

The licensee stated that there are no specific modification procedures to ensure. that fire stops and compartment boundary seals are maintained on a continuing basis. The licensee stated that all work is accomplished through the Station Work Request program and thus is sub)ect to the Operations Quality Assurance Program.

4~ Visual Examination The inspector toured the facility with Mr. Stolt and other representatives of the licensee to determine the extent of conformance

.with the specifications in paragraph 2. Specific areas examined were

'the Unit 1 Cable Penetration Room, Units 1 and 2 Cable Spreading Rooms, the Unit 2 Aux.'lectric Room, and the Control Room.

The inspector identified three general areas of concern:

a. Combustible materials at various locations:

~

(1) Wood blocks supporting a cable tray.

(2) Wood in conduit sleeves and cable trays.

(3) Foam in conduit sleeves and cable trays.

(4) Unidentified ropclike material used to seal some conduit sleeves. 'I

b. Unsealed Penetrations:

(1) Some penetraHons had not been sealed at construction, e g., D-24 A through D-24 F.

(2) . Several conduit sleeves into control panels which were installed for spares but were never capped or sealed.

(3) Penetrations which have been opened to pull new cables and have not been resealed.

Co Cellular Concrete:

(1) While observing a penetration which had been opened

.to pull a new cable and not-resealed, the inspector noted that the penetration was not solid with concrete as the specification indicated, but instead was only filled to a depth of about an inch.

5

0 (2) The inspector noted that <he concrete was cracking and crumbling in many locations.

5. Bulletin Status The licensee submitted the reply to IE Bulletin 75-04 on April 25, 1975. The licensee is preparing a reply to IE Bulletin 75-04A.

UNITED STATES NUCLEAR REGULATORY COiPfISSION OFFICE OF INSPECTION AND ENFORCEHENT REGION III Report of Operations Inspection IE Inspection Report No. 050-282/75-06 IE Inspection Report No. 050-306/75-04 Licensee: Northern States Power Company 414 Nicollet Hall Hinneapolis, Hinnesota 55401 Prairie Island Nuclear Generating Plant License No. DPR-42 Units.1 and 2 License No. DPR-60 Red Hing, Hinnesota Category: C Type of Licensee: (H) PIE 560 H'4'e Type oi'nspection: Special, Announced Dates of Inspection: Hay 12 and 13, 1975 Dates of Previous Inspection: April 29 Hay 2, 1975 (Operations) Unit 1 April 7-11 and 16,.1974 (Operations) Unit 2 Principal Inspector: C. Ik. Brown (Date) ~

Accompanying Inspectors: None Other Accompanying Personnel: None gg. d,Mi:.

Reyieved By: ll. C. Dance Senior Inspector c)~,.

Nuclear Support Operations. Branch

I '

SR MARY OF F IN D INGS Enforcement Action: "None.

License Action on Previousl Identified Enforcement Items: None required.

Unusual Occurrence  : None.

Other Si nificant Findin s A. Current Findin s: None.

3. Status of Previousl Re orted Unresolved Items: Not inspected.

Mana ement Interview A management interview was conducted with Messrs. Goering, Superintendent Plant Engineering; Hunstad, Staff Engineering;.and Albreckt, Electrical Engineer; at the conclusion of the inspection on Hay 13, 1975. The'ollowing items ware discussed.

A. The inspector's findings during the visual examination of the Penetrations. (Paragraph 3, Report Details)

B. The llrcnsee's response to IE Bulletins No. 75-0'~ and No.75-04A and the status of the task force. (Paragraph 5, Report Details)

C. The licensee's use of construction specifications for seal repair.

(Paragraph ~i, Report Details)

D. The fire fighting training equipment and the evaluation of their hose nozzles meeting the fogging necessary for fighting energized electrical cable fires. (Paragraph 7; Report Details)

REPORT DETAILS

1. Persons Contacted

'.E. A. Sasges, NSP QA Engineer Albre'cht, Electrical Engineer D. Brown, Engineer G. T. Goering, Superintendent Plant Engineering

-2. Construction S ecifications Pioneer Service and Engineering Drawing NF-39202 through 13',

32712A-E360A, 237127A-H362, and.Technical Specifications TS-262 werc availyl~le and reference) in L. K. Comstock procedures 000-03-008 and 000-03-009- . 'he '009 procedure covers con-struction of the Category I ventilation,'team exclusion, and fire barrier seals around electrical cabling penetrations. The licensee considers the steam exclusion seals as fire barriers both are similar. construction.

The cable trays either have RTV poured over the random layered cabling,and the remaining volume packed wi'th fiberg'lass "board" or in th'e case of power cables, only the fiberglass "board is used.

The fiberglass "board" and cabling is then sealed with Flamemastic

~

71A in two 1/8" coatings on both sides of the penetration. The seal vcpification 's the quarterly ventilation test to verj.fy that the auxiliary building does go to a negative pressure. No devices are used to check individual seals.

The above Comstock procedures are to be used for repair of a disturbed seal.

The construction drawings and applicable procedures follow the separation and barrier criteria in Section 8 of the FSAR. The color coding of the cables was performed as the cable was removed from the reel and all power cable is armored with semi-flexible aluminum sheathing. All cable in the plants is specified as Type I and meet the "Philadelphia Flame Test".

3. Visual Examination The following areas were inspected where applicable to the fire barriers:-

Control Room Relay and Cable Pulling Room (Relay Room) 1/ "Electrical Conduit Seals" in the biological shield.

2/ Sealing Electric Openings.

Turbine Building ~

Auxiliary Building Di.sel Generator Rooms Bus Rooms (Switchgear for Busses 15 and 16, 25 and 26)

In these areas the steam exc'lusion and fire barrier 'seals (approxi-mately 40% examined) were found to be as specified except as follows:

a. Two, cab~ tray penetrations were not sealed with Flamemastic on the Relay Room side.

b. In approximately 20% of vertical penetrations the Flamemastic has not bonded to the concrete on some part of the penetration periphery and the fiberglass could be seen. The lack of bonding was also noted on some of the cabling in this type of penetration. The above was noted only on 'the top seal of these penetrations.

Ce In the vertical penetrations that have 3 or more layers of cables the internal cables did not appear to be completely sealed with 1'lamemastic in the fire barriers. This did not appear to be a problem in steam exclusion and Category I ventilation seals as RTV is poured into these seals. The

'icensee agreed to review this area and correct as necessary.

This item was not fully covered 'in the procedure .and the fire barriers are as specified.

The "Permagum" (duct seal) which is flariunable was used as dams for pouring RTV (Unit 1) or Chico (Unit 2) into conduit for sealing and is probably still in place. This annulus area was not inspected.

Permagum was used to seal stub tubes in the penetration seals that have wires running througli the tubes and the majority are not coated with Flamemastic. Permangum is the only flammable material used in the seals as RTV apparently only burns on surface and the char protects the remaining seal.

4. Maintenance and Modification Procedures The licensee has initiated a procedure that routes to the Electric Engineer any work request that requires cable pulling through an existing seal or barrier. He reviews the work request and adds the applicable original construction sealing procedure to be used for repairing the s'eal. No modifications have been'ade in the 4 week period that this procedure has been in effect. The licensee is continuing the review of previous modifications and it appears that the new cabling has pulled through the stub tubes that are part of the seal. The tubes are either capped if not in use or fiberglass is packed around the wires and the ends of the stub tube is sealed with "permagum". The "permagum", in some cases, was sprayed with

flamcmastic the majority of stub tubes in use have temporary cabling pulled through them and the licensee is evaluating covering the "permagum" with Flamemastic.

5. Res onse to IE Bulletins No. 75-04 and No. 04A The licensee's response to IE Bulletin No. 75-04 has been received.

The licensee stated that .ignition sources as used 'in paragraph 3 of the response presently refers to welding and grinding, but is also

'to include other sources i'f any are used in the future. Northern .

States Power Company has formed a task force of personnel 'from both the licensee's nuclear sites. -The initial meeting was held May 5, to set up the guidelines and the next meeting was scheduled for May 1'4.

Monthly progress reports are to be sent to IE until June 30, the scheduled date for completion of the response to the bulletins.

6. Se aration Criteria The requirements and specifications of the construction prints, the electrical wiring procedures 'and the FSAR, Section 8, appear to have been met as to the- separation and barriers. The physical tracing of individual wires in a cable tray could not be performed b{ ~~end he firsl pefi

< ctrl tlon as the cables lcf, the control <<oom or the termination point. The construe'tion QA personnel have completed a 100% inspection of the barrier requirements using the prints and color coding with no deficiencies noted. The cable pull cards had previously been verified.

7 ~ Fire Fi htin E ui ment The fire fighting equipment available at the site consists of hose sta'tions with fog or adjustable nozzles, portable C02, purple K fire extinguishers in the plant and 2'ater extinguishers outside the control room doors. The relay'and cable pulling room has an automatic Cardox system with manual start pull box The diesel generator rooms have automatic water sprays. The fire detection system consists of ion smoke detectors and bimetallic temperature elements which alarm in the control room. The self contained

.breathing cquipmcnt was purchased for the purpose of ai,rborne activity protection, 'but could be used for fire fighting. The equipment now on site is four single bottle Scott air packs with four spare botties and four large 'cylinders that can recharge approximately 20 bottles. Each of the charged bottles provides approximately 30 minutes of working time. The person knowledgeable of how the cylinders are recharged was not'vailable at the time of

the inspect9.<n. One Scott Rescue Pack with one spare .oxygen bottle, each worth approximately 30 minutes, was available at the site. The Red Wing-Fire Department will respond to a fire at the site and they have held fire fighting, classes for the site personnel.

A training memo was issued by the Training Supervisor on Hay 6, 1975, outlining the training to be held in reference -to the Brown's Ferry fire. The memo also refers to the National Bureau of Fire Underwriters Special Interest Bulletin No. 91 that lists safe distances vs. voltage for use of water fog on eneMgized electrical wiring fires.

UNITED STATES .NUCLEAR,REGULATORY COiM~ XSSXON

~3 OFFXCE OF INSPECTION AND ENFORCEHL'VX REGXON XII Report of-Opexations Inspection XE Inspectioh Report No. 050-409/75-04 Licensee: Dairyland'Powex Cooperative

'26l5'ast Avenue South LaCrosse, Wisconsin 54601

'aCrosse Boiling Water Reactor License No. DPR-45 Genoa, Wisconsin Category: C Type of'Licensee:

Type of Inspection: Special

~ 3 Dates of Inspection:

Dates of .Previous Inspection:

April '23-24, March 1975 5 7, 1975 (REF)

~'p,":

Principal Inspector: X. N~ Jackiw V (D te)

Accompanying, Inspectors: None Othe'- Accompanying Personnel: None Reviewed By: H. C. Dance C p~ S 7)g Senior

, Inspector ( ate)

Nuclear Support

~

, Opexations Branch 1

~ )

~

SUMMARY

OF FINDINGS Enforcement Action: None.

Licensee Action on Previousl ,Identified Enforcement Matters: Not inspected.

I I

Unusual Occurrences: None.

.A. Current Find'ines: None.

B. Unresolved Items: None.

C. Status of Previousl Re ortcd Unresolved Items: None.

~

Mana ement Interview At the conclusion'f this inspection on April 24, 1975, a management interview was conducted with Hr. Shimshak, Plant Superintendent and other members of the staff. The following items were discussed:

A. The inspecto summarized the items covered during this. special inspection and stated that the facility appears to be in compliance with their construction specifications. (Paragraph 2, Report Details)

B. The inspector stated that existing maintenance and modification procedures do not provide for an independent veri'fication of job completion as requ"'red in the licensee's "equality Assurance Program" manual Section XI.

The licensee replied that the independent verification effort wiil be implemented when the quality assurance procedures are written by November 1, 1975. (Paragraph 3, Report Details)

C. The inspector stated that during his "visual examination of the cables and cable trays in the plant no immediate areas of concern were noted.

(Paragraph 4, Report Details)

D. Regarding the status of t'e action taken in IE Bulletins 75-04 and 75-04A, the licensee stated that a response to these bulletin's has been drafted and will be mailed to Region III. (Paragraph 5, Report Details)

REPORT DETAILS

l. Persons Contacted H. Towsley, Quali.ty Assurance Supervisor

'H. Norwicki, Instrument and Electric Supervisor R; Shimshak, Plant Superintendent

2. Construction Specifications V

Alii.s-Chalmers and Sargent & Lundy construction specifications were xcvi.ewed to d termine what req'uirements exist for fire barriers and boundary seals. No specifications exist for 'these two areas. However, A'-C specification 41-4'91 "Specs for Electrical Design Features" requixes that reactor building cable pans have solid bottoms and sides. The inspector confirmed that cable pans in the reactor building are so constructed. .Also, reference drawings in S&L STD-EB-134 indicate that the minimum distance between horizontally stacked trays be 10 inches.

3. Maintenance and Modification Procedures

,The following .procedures relating to 'maintenance and facility change controls were reviewed to detexmine whether requirements are impos d in connection with modifi.cations and repairs to cables and.penetration boundries.

a. "Design Control and Review" ACP-04.1

b. "Facility Ch"nge Requests" ACP-04.2

c. "Maintenance Requests" ACP-17.3 These procedures provide sufficient review for maintenance and mod-ification activit'ies. Also, procedure ACP-0.4.1 states that the Plant Engine-ring Staff is responsible for establishment of a suitable test program as necessary to accomplish d sign reviews.

Revi.ew df procedures ACP-04.2 and ACP-'17.3 showed that no provi.sions exists to include independent verification of job completion if and when required. The licensee stated that the "Quality Assurance Program" manual procedures are continuously being upgraded and independent verification requirements will be included as required.

Xn regard to the second emergency diesel genera'tor installation, the inspector asked what controls would be followed prior to and during this installation. The licensee replied. that procedures would be written for this installation activity.

Visual .Examination

'he inspector toured the following areas to determine the licensee's conformance with installation and construction specifications

&o Control Room cables penetrate the floor and are sealed through metal plates by compression fittings. It appears that this 'type penetration is adequate to serve as a -fire stop.

b. Electrical E uioment Room in this area cable penetrations exist be'tween the control room (metal plates), the mezzanine floor of the Turbine building and cablepenetration room (outside the northwest quadrant of the containment shell);

I Cable pans in this room have solid bottoms and sides and are sprayed with a fire-proof material .(Flamemastic 71A). In all sections where cables run from one cable pan to another Flamemastic 71A is used. Also, Flamemast'ic 71A is sprayed 3 feet.,on both sides of wall penetrations. Vertical cable runs in this room are enclosed in solid cable raceways. The xoom also contains the station batteries.

Co Turbine Buildin (~Lfezzanine Floor) -'lamemastic 71A is used "about every 10 feet in the horizontal pans and at each cable pan junction. Cables penetrating the mezzanine floor and going to the grade floor below are fully enclosed.

'd ~ Diesel Generator Room power cables are totally enclosed in conduit and run into the concrete floor.

e. Cable Penetration Room in this'oom cables from the primary containment penetration seals run vertically into horizontal pans and at this point and along the horizontal run are sprayed with Flamemastic 71A. This cable penetration room is presently being used for storage of items such as electrical extention cords, welding rods, tools, etc.

Containment cable pans in this area are fully enclosed except where the cables enter and leave the pans at which point they are. sprayed with Flamemastic 71A. Cables for the emergency core spray system, water level instrumentation and the emergency shutdown condenser are copper-sheathed, mineral insulated, fire-proof cables and run to the equipment itself.

4

In the areas examined the inspector noted that all wall penetrations are filled with fiberglass material and Flamemastic is "sprayed on both sides of the penetration.'he 'licensee stated that Flamemastic 71A was first applied in'eptember 1972 for fire insurance purposes.

Except for the Diesel Generator compartment, all areas examined have one or more fire extinguishers, also all these areas employ fire/smoke detection sensors that alarm in the control room. The licensee stated that he will consider placing a fire extinguisher outside the door of the Diesel Generator, room.

5. Bulletin Status Replies,to Bulletins 75-.04 and 75-.04A had been drafted and would be sent to Region XII.

'3 U. S. HUCLEPR REGULATORY CO.~~iISSION OFFICE OF IHSPECTEOH A:V3 .ENFORCE. HT REGIOif III Report of Operations Inspection IE 'Inspection Report Ho. 050-331/75-11 Licensee: Iowa Electric Light and Power Co"pany Security Building P. O. Box 351 Cedar Rapids, Iowa 52405 Duane.Arnold Energy Center License Ho. DPR-49 Palo, Iowa Cat gory: C t

Type of Licensee: BUR GE 536 ~."ae Type of Inspection: Special, Announced Dates of Inspections: August 20 and 21,'975 Principai Inspector.: T. L. Harpster t I. ('. g( (Dat'e)

Accompanying Inspector: None

,Other Accompanying. Personnel: Hone Reviewed By: M. S. Little ~

rT Senior Inspector ,D= -e)

Nuclear Support Operations I

Br nch

(

M

SPIRY OF FINDINGS Ins ection Sumter Inspection on August'0 and 21 (75-11): Followup inspection of actions taken with respect to IE Bulletins 75-04 and 75-04A Enforcement Items Hone.

Licensee Action on Prey'ousl Identified Enforcement Ite,,s Hot ins . cted.

Other Significant Items A. .Systems and Components hone.

3. Facility Items (Plans and Procedures)

Hone.

C. Managerial Items None.

D. Noncompliance Identified and Corrected by Licensee

.Hone.

E. Deviations None.

F. Status of Previously Reported Unresolved Items None.

Mana ement Interview The following subjects were discussed at the conclusion of the inspection on August 21, 1975, with Hr. G. Hunt and oth'er members of your staff.

The licensee stated that no action had been taken as yet with respect to the deficient penetrations ioentified during the initial firestop, inspection. ,QE Inspection Report No. 050-331/75-05)

The 1'icensce stated that .a 100% inspection of electrical penctrations, which are required to be sealed in accordance with Sectio'n ~f.3.5 of the DZXC FSAR and the construction specifications which i..plement

.this commitment, will begin on August 25, 1975. The esti..ated date for completion is"October 15, 1975., The license stated that any combustible . aterial found in electrical pen'etrations will be removed. Repair priority will be given to the control room, cable spreading room, etc., in accordance with the safety significance of each area.

The inspector asked to be notified of any ch nge in this sched le and urged that this work be completed as expeditiously. as possible.

(Report Details, Paragraph 2)

The inspector stated that the revised "Scheduled Cable Installation" procedure and addendum had been reviewed, and appeared to ensure that -cable.penetrations would be sealed in accordance with licensee requirements. (Report Details, Paragr ph 3) e

REPORT DETAILS

l. Personnel Contacted G. Hunt, Chief Engineer J. Gebert, ."fgintenance Engineer T. Gucciardo, Flectrical -Engineer

2. Penetration Repair Status arith the exception of minor de'ficiencies and combustible foam in

'everal electrical penetrations, the plant was found to general3y conform to the bulk of specifications during the i.."tial firestop inspection. (IE Inspection Rcport Ho. 050-331/75-05)

The plant has been in an extended outage as a result cf fuel channel vibration problems. No actions have been taken as y t with respect to the deficiencies and foam. The licensee stat=c that an inspection of electrical penetr tions will ocgin on August 25, '1975, and that any combust'ble foam w" ll be removed and deficient penetrations sealed in accordance with licensee requirements.

3. 'Re air Procedure The "inspector reviewed the following procedure and addendum:

Repair Procedure RP-CAB/IE-1, Scheduled Cable Installation", and Addendum E-700, "Scheduled Cable Installation Checkl:st".

The procedure had been revised to ensure that penetrations ~;ere sealed in accordance with licensee reouirements aftc" cable installation. Tne procedure included references to the appro-

,priate specification's. (IE Inspection Report iso. 050-331/75-"5}

4. 'Fire 'Fi htin Trainin The licensee stated that in response to IE Bulletin 75-04A, training of plant personnel had been ir.;plemented under" the station fire protection plan. The training 'is conducted on a monthly basis., and consists of both lectures .and practical experience.

P UNITEC STATSS 1

~

NUCLEAR RLGULfiTORY COMYilSSION IIFGION Il 230 PCACI'TIIEE STAEET, N: Vl. SVITE 8I8

'3 ATLANTAIGEOIIGIA 30303

~

IE Inspection Report -No. 50-321/75-6 LiceI>see: Georgia Power Company 270 Peachy'ee Street, N. 'l4.

Atlanta-, Georgia 30303 Facility Name: Edwin I. Hatch Plant, Unit No. 1 License No.: DPR-57 Docke" No.: 50-321 Category: B2 Location: Bazley, Georgia Type, of. License: BUR, 2436 Kit Type of Inspection: Special, Announced Dates of Inspection: Hay 6-8, 1975 Dates of Previous Inspection: ~

April 8-11,

~

1975 Principal Inspector:

~

D. G.

~ ~ Hinckley, Reactor Inspector Facilities Operations Branch Accompanying Inspectors: None Principal Inspector: .. E. Lc c.<~g~~

D. G. Hinckley, Reactor Inspector Date Facilities Operations Branch

~-~I ~r ~~A g5 Reviewed by:

F. J. Long, Chief Date Facilities Operations Branch

<pLUTl pauli

">s-Io<e

t IE Rpt. No. 50-321/75-6 I.

SUGARY OF FINDINGS Enforcement Items None XI, Licensee Action on Previousl Identified Enforcement Matters Not inspected XXI. New Unresolved Items None IV. Status of Previousl Re orted Unresolved Items Not inspected V. Si ificant Findin s A. Cont'rol and procedures lacking for breaching and repair of fire stops. (Details I, paragraph 3)

B. Emergency procedures do not address alternate methods for

~ .

accomplishing a plant shutdown and cooldown.upon loss of normal and alternate preferred shutdown and cooldown systems. (Details I, paragraph '5)

VI. Mana ement Interview On April 10, 1975, a management interview was conducted by Mr. D. G. Hinckley with Mr. D. P. Shannon and selected members of his staff. The scope of the inspection and findings were discussed. {Details I)

4 IE Rpt. No. 50-.321/75-6

~ 3 DETAILS I Prepared by:

D. G. Hinckley, Rea t:or Inspector w~/~z ~

Date Facilities Operatiork Branch "

Dates of Inspection: May 6-8, 1975

?

.Reviewed b~y: .W  ! .Zc> ps F. J. Long, C ief Da e Facilities d Operations Branch

1. Individuals Contacted D. P. Shannon Plane Superintendent M.. Manry Assistant Plant Superintendent D. '.'-~Savage Operating QA Engineer H. P . 4'alker Technical Supervisor C. E. Bellflower - Senior Field QA Representative

2. Sco e of Ins ection The inspection vas performed to 'determine the requirements relating to compartment boundary seals and fire stops for electrical penetra-tions, imposed by facility construction specifications, foz the Edwin I. Hatch Nuclear Plant and to determine the extent to which the facility currently conforms to these requirements.

Particular inspection effort vas giien to the follovirig major areas:

(1) design information (2) plant modifications (3) conformance to identified requirements (4) zesponse to IE Bulletins 75-04 and 75-04A

3. Desi Information a.'onstruction S ecifications Georgia Pover Company drawing A-13029, "Electrical Seals", establishes a guide of basic specifications and details for general fixe stops and seals for cable penetrations in floors and walls of the Hatch Nuclear Plant. This guide does not address the secondary containment fire stops and pressure seals consisting of modular units, identified as Multi-Cable Transit (MCT), manufactured by Nelson Electric Division

~ .

of Sola Basic Industries. The frames for these modular units are detailed on construction dravings. The specifications for" the general fire stops and seals and a brief description of the MCT modular units are discussed below.

IE Rpt. No. 50-321/75-6 l-2 Floor Penetrations Cable trays entering the floor of the cable spreading room are sealed to provide a fire barrier and insure a ventilation seal. Specifications require that one-half inch Harinite-36 was to be used as a form beneath 'the floor, cut to fit around cables and cable tray. Mineral insulating wool was, to be used where necessary to Sill large voids around the cable. Flamemastic 71A sprayable was to be applied to the cables in the penetration as well as a minimum of twelve inches below the penetration'.

Flamemastic 71A mastic was to be applied over the holding screws and between the Harinite'panel fo'rm. Flamemastic 71A sprayable was then to be built up to approximately 1/4 inch on the bottom of the Harinite form around the cable's and cable tray, at their ~

entry through the form, to insure a fire stop and ventilation seal.

The top opening of the penetration was to be covered with a steel plate or a piece of 1/2 inch Harinite-36 board to prevent debris from gathering into the penetration.

within the reactor building (secondary containment) most floor penetrations between levels consist of 'either embedded walker

'duct'r embedded conduit. Mineral wool was to be installed in the bottom side of the penetration to was fill voids. Flamemastic to be built up to approximately 1/4 inch on the bottom '1A side of the penetration to provide a fire stop. Hineral insulating wool was to be used to to fill large voids on the top side of the from collecting in the penetration.

penetration prevent debris (2) Mall Penetrations Mhenever cable trays penetrate a compartment wall a fire stop is provided. The construction of the fire stop is much the sama as described for floor penetrations. The exceptions being that Harinite was required only on one side of the wall, and Flamemastic 71A was to be applied to the cables for a minimum of 12 inches on either side of the wall and inside the wall opening, if possible.

(3) Cable Tra Pire Stops Fire stops were to be placed in all cable trays at approximately 75 foot intervals. Construction was to consist of a one-half inch Harinite-36 panel placed around cables and cable tray and secured to a support strut. Mineral insulating wool was to be used where necessary to fill large voids around the cable. The cables in the cable tray were to be sprayed with Flamemastic 71A, twelve inches on either side of the fire stop. Flamemastic 71A, mastic was to be applied to a minimum 1/8 inch thickness over the holding screws and applied to fill the crack between the two pieces of Harinite, cut to fit around cables and cable tray.

0 IE Rpt. No, 50-321/75-6 I-3 Flamemastic was then to be built up to approximately 1/4 inch on both sides of the .Harinite panel l

In vertic'al cable trays, a cover was to be installed on top anc,bottom (if not a solid bottom tray) of the tray. This cov:.g was to be placed on the upper side of the fire barrier and was to extend at least five feet beyond the barrier.

(4) Seconda Containment Pressure Seals and Fire Sto s Conduit sleeves exist between the control building and reactor building. These conduits are sealed to allow the reactor building to be maintained at a negative pressure. The seals are similar installed for the diesel building wall seals described later to'hose in this report. The difference being that conduit sleeves are extended through the wall between junction boxes, and circuits feeding into the boxes are totally enclosed in conduit on both sides. of the wall.

Wherever cables from cable trays penetrate the secondary contain-ment from the cable spreading room or control building, the penetration is made through a Nelson Electric Hulti-Cable

'Transit {HCT) module which provides both a seal and a fire stop.

The TECRON (tradename) module fits snuggly around each cable.

These modules expand when heated, choking off fire and smoke.

This expansion supposedly compensates for the loss of cable insulation, burned away by a fire, thus maintaining the fire-tight integrity of the penetration.

.(5) Control Room Floor Pressure S'eals Cable penetrations between the cable spreading room and control room panels were to be sealed with a flame retardant BISCO flexible silicon'e foam. Penetrations under the panels consist of recessed aluminum plates with multiple holes used to accomodate chase nipples, terminated conduit or flexible conduit extended through a hole.

Spare holes in the aluminum plate were to be blocked and sealed with duct tape or extended into the panels with short lengths of aluminum conduit sealed on the spreading room side of the pene-tration with a penny and bushing arrangement, prior to placement of the sealing material.

The area under the control room panels was to be filled with BISCO flexible silicone foam, by Brand Industrial Services, to at least the embedded strut in the recess.

XE Rpt. No. 50-321/75-6 T-4 (6) Diesel Buildin Hall Pressure Seals The penetrations between the diesel rooms and switchgear rooms are to be sealed. Each penetration sleeve was to be sealed by injecting RTV sealant into the spaces between the cables of the bun'die. The injection was to start within the penetration as far as practical and was to extend to some two inches out of the. penetration. Mineral wool was to be packed into the penetra-tion around each cable bundle to within about 1/4 inch of the penetration opening. RTV sealant was then to be applied onto in, and around each penetration to cover the entire assembly with sealant not less than 1/8 inch in thickness.

b. Material S ecifications and Qualifications (1) Plamemastic 71A (Technical Bulletin 01079)

Dyna-Therm Plamemastic coatings are compounded of thermoplastic

~

resinous binders, flame retardant chemicals and inorganic incom-bustible fibers. The manufacturer claims no burn-through .of 1/16 inch coatings after 1S minutes exposure to a propane torch, 'at a distance of 2 inches, with a flame temperature of 2050"F.

(2) Marinite-36 Panel Johns-Manville Marinite was originally developed to isolate and prevent the spread of shipboard fires. The manufacturer claims Marinite panels are composed of incombustible asbestos fibers, diatomaceous silica and a hydrothermally-'produced inorganic binder. Marinite carri,es the UL label with the following fire hazard classification {based on 100 for untreated Red Oak):

Flame Spread 0 Fuel Contributed Negligible Smoke Developed 0 Marinite is approved by the Board of Standards and Appe'als of the City of New York, meeting the requirements of C26-88.0 Administrative Building Code as an incombustible material.

(3) RTV-124 RTV-124 is a flame retardent adhesive sealant manufactured by General Electric. RTV carries the UL label and classifies as self-extinguishingGroup 0 (SE-0) .

0 IE Rpt. No. 50-321/75-6 (4) Mineral li'ool In .ulation t

Mineral wool insulation is a non-combustible asbestos material supplied by the .Rock Wool Manufacturing Company.

(5) BISCO SF 20 Silicone Foam (BISCO Spec. 8207)

BISCO flexib"le silicone foam is formulated with Dow Corning Corporation Components per Brand Industrial Services (BISCO)

Specification f/207. The silicone foam has a Dimethyl Polysiloxane base with a UL fire resistance listing of 94 UE-0. The foamed-.in-plac'e silicone has a temperature range of -76 F to 550 F.

BISCO SF 20 silicone foam was tested, as a seal material at the D.C. Cook Nuclear Plant on October 12,'974. Foamed-in-place silicone as a flexible flam retardant and ventilation seal for conduit penetrations through walls and floors was tested at the Pilgrim Nuclear Power Station on November 12, 1974. A test was performed by the Factory Mutual Research Corporation, on March 26, 1975, to investigate the fire endurance capabilities BISCO silicone foam when subjected to fire exposure.

'f The test was conducted in accordance. with the Standard Fire Test of Building Construction and Materials ASTM E119-73.

G

~ (6)

~

TECRO'N TECRON (tradename) 1 is the module material used in the Multi-Cable Transit (MCT) penetrations to provide the sealing and firestop capabilities as claimed by Nelson Electric. The manufacturer claims that cable penetrations have been tested to withstand temperatures of 1715 F without allowing passage of fire, smoke or gas, A Georgia Power Company representative stated that Nelson Electric MCT seals have been fire tested by both Nelson Electric and several other independent companies. At least one'f these tests was conducted in accordance with ASTM Designation E 119-61.

c. Assembl Qualificaticns An assembly or simulated assembly qualification test for installed fire stops was not performed by Georgia Power. Comp'any. The Nelson Electric MCT penetration has b'een extensively tested by the manufacturer and claimed to be an effective fire stop. Nelson Electric Bulletin 200-BF-'002 indicates that MCT test reports'are available for review.

R IE Rpt. Ho. 50-321/75-6 I-6 3 d. Installation Georgia Power and Procurement Com p an roccdure A-13029 "Electrical Seals" p rovid for installation of general fire stops and seals. The BISCO es'uidance silicone foam seals between ehe cable spreading room and control roon were installed by Brand Induserial Services, Inc. and apparently controlled by their installation pxocedure. The Nelson Electric NCT

~

frames were detailed on construction drawings and installed during buH:ding conseruction.

i Materials that are cormnergially available were purchased by specification and/or tradename from local suppliers. No certifications were provided.

I A GPC representaeive indicated that fire stops were inspected for conformance to requirements on initial installation. This inspection was to have been made by their QC department. At the time of the inspection; QC documentation of, these inspections was not available.

stops were not reverified during turnover of the facility to

'ire op'erations. Periodic or random inspecti.ons of fire stops are not presently being made.

1 4. Plant Modifications Rerouting or routing of new cables for modifications is presently determined by Bechtel Engineering.

it If a plant modification is involved, is to be reviewed by the Plant Review Board. Presently, it appears that there are not any procedures giving guidance on how t;o breach an existing fire stop or seal. Ho specific requirement or procedure exists for xepair and inspection or" any'ire stop or seal breached for plant nodifications. This was discussed with site management, and they committed to review the problem.

5. Conformance to Identified Re uiremenes'ire stops and seals were i.nspected i.n the Cable Spreading Room, Reactor Building, Contxol Building, Control Room and Diesel-Generator Building.

The purpose of the inspection was to determine, by visual observation,.

to what extent design and construction criteria had been followed.

The visual inspection consisted of trying to determine the actual construction details and materials used by the outward appearance of the fire stops and seals. No attempt was made to disassemble any fire

'stop or seal to verify actual construction details or materials that were not obviously evident.

'. Ply l ~ ~ ~

l IE Rpt. No. 50-321/75-6 I-7 O Two instance's were identified where fire stops had been breached repairs had not- been made.* These were located in one of the Reactor and Protection Systems (RPS) motor-generator set compartments. This item was brought to the attention of site management.

During th'e inspection, general 'observations were made, particularly in the cable spreading room and control room, concerning cable routing..

as 'specified by the FSAR.

6. Licensee Res onse to IE Bulletins 75-04'nd 75-04A GPC has responded to IE Bulletins 75-04 and 75-04A. A general review of the response'as been made. Additional followup as required will be performed during the next regular-inspection. Review of emergency procedures, by the inspector, indicated that procedures were lacking in covering alternate methods for performing a plant shutdown and cooldown in case of loss of normal and preferred alternative shutdown and cool-down system . Site management-'committed to review the adequacy of emergency procedures in this area.

i.iiVITED STATES NUCLEAR REGULATORY COMMISSION REGIOIhI II 220 PEACHTREE STREET, N. W. SUITE 818 ATLANTA,GEORGIA 20202 ~

IE Inspection Report No. 50-324/75-'06 Licensee: Carolina Power and Light Company 336 Fayetteville Street Raleigh, North Carolina 27602 Facility Name: Brunswick 2 Docket No.: 50-324 License No.: DPR-62 Category: B2 Location: Southport; North Carolina Type of License: 2436 Mwt, B!K, G-E Type of Inspection: Special, Announced Dates of Inspection: 1fay 5-9, 1975 Dates of Previous Inspection: April 22-25, 1975 Principal Inspector: F. S. Cantrell, Reactor Inspector Facilities Section Facilities Test and Startup Branch Accompanying Inspectors: None y

Principal inspector: . C...M F. S. Cantrell, Reac pr'nspector Facilities Section Facilitges Test and Startup Branch Reviewed By: )

F. J. Long, Chief

-C~

Facilities Operations Bra ch

0 0

+ ~

IE Rpt; No. 50-324/75-4 SU129LRY OF FINDINGS I. Enforcement Items None II. Licensee Action on Previousl Identified Enforcement Matters Not inspected.

III. New Unresolved Items None IV. Status of Previousl Re orted Unresolved Items Not inspected.

V. Unusual Occurrences None VI. Other Si ificant Findin s Or anizational Chan es Mr. 'J. R. Holder was promoted to a newly created position of Superintendent-Operations, Maintenance and Engineering. He reports to the plant manager.

Deviation From FSAR Commitments During an inspection of firestops, numerous locations were observed which appeared to deviate from. the fire retardant barrier installation commitm nt made in the Brunswick 1 and 2 FSAR, page 'M 8.5-9,(Details, Paragraph 3).

VII. Mana eront Interview I An exit interview was conducted on May 9, 1975 with Messers. Hollowell, Holder and Starkey.

The inspector reviewed the results of the inspection concerning the two Reactor Blowdowns (Details, Paragraph 2), and the status of the

~z fire stops (Details, Paragraph 3).

IE Rpt. No. 50-324/75-6 DETAILS Prepared by: '...C.~

F. S. Cantrell, Reacto inspector Dat Facilities Section Facilities Test and Startup Branch E

Dates of. Inspection: May 5-9, 1975 Reviewed by: /-. + /~

R. C. Lewis, Senior Inspector Date Facilities Section Facilities Test and Startup Branch

1. Persons Contacted 0'.,

a. Carolina Power and Li ht Com an B. Bessac Manager, Bulk Power Supply E. G. Hollowell Plant Manager J. R. Holder Startup Supervision W..C. Rowles Operations Supervisor A. M. McCauley Engineering Supervisor R. Stanley QA Supervisor

b. Brown and Root, Inc. (B&R)

Bill Worming ton Proj ect Electrical Engineer John Propson Engineer

c. General Electric C.. R. Dietz Operations Manager K. Brown J. L. Miller Startup Engineer

2. Reactor Blow Downs A reactor blowdown occurred April 29, 1975, from approximately 10%

power when the B relief valve (RV) lifted for no apparent'ause and failed to reseat. (Abnormal Occuirence Report from CP&L dated May 16,

.1975). A second blowdown occurred May 6, 1975, from about 600 psi while restarting the plant from the April 29, 1975 blowdown. The inspector reviewed CP&L's investigation of first event and portions of the second event, including instrument charts and computer printouts.

The following items appeared to be pertinent to these events:

1 e IE Rpt. No. 50-324/75-6 a~ The first alarm received was high torus level and the second alarm was high temperature in the torus. Each relief valve discharge line

'as a thermocouple in the line to detect relief valve leakage by measuring the temperature, and to provide an alarm when a relief valve .opens. The temperature in each "tail pipe" is recorded sequentially on a multipoint recorder. The high "tail pipe" temperature alarm which comes off the recorder, is normally set 50 F above the maximum temperature being measured, however, the proper setting had not yet been determined in the startup program.

As a result, the alarm was on because of a high ambient temperature

.in another "tail pipe." When the "B" relief valve opened another alarm for high tail pipe temperature was not initiated.

b. Relief valve operations are not monitored by the computer, or other annunciators. At the time of both blowdowns, one main steam bypass valve to the condensor was open. The closing of the steam bypass valve (as a result of the relief valve opening) was recorded on the computer. -This provided the time that the relief valve opened.

Co When it was determined that a relief valve was stuck open and would not reseat during the first blowdown .(about 10 minutes after the RV opened), the reactor was not scrammed immediately as required by Emergency Instructions EI-40. The main steam isolation valves were closed aoout 20 minutes after the relief valve opened. This action scrammed the reactor. A licensee representative stated that this action was taken to minimize the cooldown rate since the reactor contained a new core with very little exposure and very low decay heat removal requirements. During this period, EI-40 requires that the reactor be scrammed as soon as it is recognized that the RV will not close, or if the suppression pool temperature reached 110 0 F.

EI-40 also requires initiating all available RHR heat e..changers in suppression pool cooling mode as soon as possible. An attempt was made to initiate fuel pool cooling with the "A" loop; however, the suction valve would not open. Fuel pool cooling was not estab-lished with "B" loop until 12:40 p.m., 18 minutes after the relief valve opened. The computer showed that the "C" RHR sexvice water pump started at that time. Operation of the RHR pumps was not mon-itored by the computer. During the second blowdown, the operator piomptly scraped the reactor and initiated torus cooling as requir'd by procedure EI-40. (The failure to follow procedures was identified by the licensee as an item of noncompliance with Technical Specifi-cation 6.8, and reported to IE:II as an abnormal occurrence in CP&L letter dated Hay 16, 1975.)

d4 Following the first blowdown the specific cause of the RV sticking open was not determined, however, iron oxide was found in the

0 4

pilot valve and in the second stage of the relief valve. No other abnormalities were detected; therefore it was concluded that the iron oxide had caused the problem. The pilot valve and the second stage of all other RV's, except "A" RV, were disassembled and cleaned. ("A" RV was cleaned during a reactor outage about April 1, 1975). FoIlowing the second blowdown on May 6, 1975, the solenoid valve that supplies air for manual operation was still blowing when "B" valve was initially examined indicating that the solenoid valve was stuck in an intermediate position. Piston in-spection .of the partially disassembled solenoid valve showed that an 0-ring was not seated .on the piston that closes the exhaust air port and connects to the piston that admits air to the relief valve. This same 0-ring was found partially seated in five of the other ten solenoid valves. During a "Bench Test" of the "B"

. solenoid valve, the solenoid valve piston would intermittantly stick in the intermediate position. The necessary replacement parts were obtained and installed under the direction of the

manufacturer representative. The onsite QA group monitored the repair of the relief valves including the solenoid valves using a procedure with hold points developed for this job.

Each solenoid was functionally tested following repair, and each relief valve was scheduled to be functionally tested at 250 psi and flow tested at approximately full pressure (1005 psi) during the subsequent startup.

e. -When the main steam isolation valves were closed, the turbine driven reactor feedwater pumps were tripped off by the loss of steam to drive the pumps; however, the pumps continued to coast down. While

'the high pressure feedwater heaters were being valved out, the operator bumped the control for the high pressure heater bypass valve. The bypass valve opened full, allowing reactor level to increase to the point that the main steam lines flooded. .The con-trols for the heater bypass valve are on the control board between the controls for the high pressure heater isolation valves.

Technical Specifications limit the cooldown rate to 100 per hour.

With the "B" relief valve open, temperature decreased from 517 F to 314 F in 10 minutes. A site vendor representative determined that this rate was less severe than the loss of feedwater pump with main steam isolation valve closure (320 in 3 minutes 40 seconds) that was evaluated as part of the vessel thermal cycle analysis.

Following the first blowdown, a visual >nspection was made of the suppression pool including the welds where the "tail pipe" passes thru the downcomer vent header, and below the water level in the torus using a diver. No damage or defects were identified.

0

3. Ins ection of Fire Sto s

a. Construction Drawin s (1) S ecifications i

The general details of fire stops are specified in the FSAR, Appendix H, Reply to Question 8.5(6)b., and specific details are provided in United Engineers and Constructors Specifica'tion No. 9527-01-48-1.

(2) Location The specific location of fire stops, and the type to be used at that location is specified on separate area instal-lation prints that show penetrations.

'b. ~ Hater'ial .S ecifications Paragraph C.h.3) of Section V of Specification 9527-01-48-1 s'pecifies the cable coating to be used in the fire stops shall be "Flamemastic 71A" as manufactured by Dyna-Therm Corporation of Los Angeles, Californi.a, or equivalent and paragraph C.h.6) of Section V specifies the cellular concrete u'sed in the fire stops .shall be as manufactured and installed by Darbron Corporation of Houston, Texas or equivalent. Flamemastic 71A .

was purchased from Dyna-Therm Corporation, and the cellular concrete was purchased, and installed by Darbron Corporation.

Co Material ualifications

'Test conducted to demonstrate the characteri.sties of flamemastic are discussed in the following reports:

(1) United States Government Memorandum dated April 23, 1970, Ser. 1311-6158F, "Flame Propagation Test of Navy Shipboard Cables coated with Dynatherm Corporation Flamemastic; report on" (in a, fire initiated .with a piece of burlap soaked in transformer oil, the flamemastic treatment "buys time" by maintaining circuit integri.ty)

(2} Florida Power and Light Company Test No. 21-M-7, dated October 18, 1967, "Sprayable Fireproofing." (The flamemastic material completely protected the multiconductor contxol cables during a very hot oil fire for five minutes.)=

N ~

IE Rpt. No. 50-324/75-6 (3) Factory Mutual Research Corporation repoxt dated July 22, 1970, "Flamemastic 71A from Dynatherm Corporation" (Flamemastic does not cause excessive heating of cables and will prevent the spread of fire when exposed to an ignition souxce, and meets Factory Mutual approval requirements)

(4) Fire Research Laboratory, University of Ghent, Belgium Test

~

Report Nos. 835/1 and 835/2, dated April 23, 1970 and April 24, 1970, "Fire Barrier Test for Cable Hall Penetrations" and "Surface Flammability of Materials Test." (These tests showed that "for the two hour test pexiod, the flamemastic flame barrier proved an effective means to contain a fire within a given area" and ". . . protected cables obtained a Class I rating. No ignition of cables.")

(5) Franklin Institute Research Laboratories Final Report F-C3231, dated December 1971, "Flame Test'f Irradiated and Non-'irradiated Protective Coatings for Electric Cables."

(No significant differences wexe noted in the appearance or performance of irradiated on non-irradiated samples.)

No qualifications were provided for the cellular concrete for fire stops.

d. Assembl ualifications The tests in C.(4) (above) established a two hours rating for a flamemastic fire stop (Dyna-Therm letter to UE&C dated January 18, 1971)

e. Installation The UE&C Specification No. 9527-01-48-1 provided the detail specification for installing the fire stops, and special marked up area prints showed the type firestop for each location. No specific procedure was written for the installation. The cellular concrete was installed by the vendor. The flamemastic fire stops are being installed by CP&L's constructor, Brown and Root, Inc.

No special instructions or safety criteria were identified in Specifications 9527-01-48-1. The material used for fire stops was purchased by UE&C as specified in the "Specifications." No certifications were obtained or requested.

f. Ins ection and C Re uirements QA reports of "Inspection for Conformance of. Fire Stops and Seals in Unit 2" were provided for the inspector's review. These

0, IE 'Rpt. No. 50-324/75-6 r

~ ~

reports were, prepared by the constructor gA group were for the installation of cellular concrete in the plant and flamemastic cable coating in the diesel generator building. A licensee representative and the inspector concurred that these reports

. showed that these .penetrations initially were ready for the fire stop installation not that the fire stop had been installed and was acceptable.

The fire stops were not reverified during plant turnover, and there is no schedule for periodic reinspection.

g. Plant Modifications Plant procedures for approval of modifications, including rerouting .

cables that breach a fire stop, require Quality Assurance Supervisor, and Plant Nuclear Safety Committee approval prior to implementing the change.. There are no procedures that spell out how to remove c'ables from fire stops, .or require repair of firestops and reinspec-tion following completion of the work.

h. Installation of Fire Sto s

~ 3 A visual inspection was made of the fire stops in the diesel generator building, the reactor bu'ilding, the control building,'he turbine building and the radwaste building on Hay 5-9, 1975.

The penetration firestops were compared with Specification No. "

9527-01-48-1, and the individual area prints. The location of penetrations on the points were compared with the as build loca-tion. The results are as follows:

Q.) Diesel Generator Buildin Most of the cable coating, (flamemastic) has been applied as specified; however, new cables have been pulled and/or insuf-ficient flamemastic has been applied to five fire stops out of a total of fifty-two fire stops inspected. In addition, eleven penetrations contained holes ox sleeves that were not plugged in accordance with CP&L specifications. Four fire stops were identified with the wrong material, and one penetration was not specified; and contained an open sleeve. Three conduits were identified with the conduit cover removed; (2) Reactor Buildin During the inspection, work was in progress to apply flamemastic to fire stops in the reactor building. The following indicates the status at the time of the inspection:

Vm IE Rpt. No. 50-324/75-6

~ ~ At + 80 elevation", all '.of the-.penetration inspected contained one or more openings that did not meet CP&L specifications. At + 50 elevation, six of nine penetrations inspected contained one or more improperly sealed openings, and/or incomplete flamemastic coating. Of nineteen Sire stops inspected at + 17 and + 20 eleva-tion, seven penetrations contained improperly sealed openings, and'/or incomplete flamemastic coating. (Four penetrations were not accessible for inspection). In the reactor building tray covers were not installed as specified on at least five vertical penetra-.

tions. Three penetrations contained unspecified material (i.e.

ductseal, urathane foam, etc.)

(3) Control Building Of twenty fire stops identified and inspected, eleven contained

'openings that were not sealed or were improperly sealed.

The flamemastic coating had not been applied-to any cables. A sampling inspection of openings in the floor of control room cabinets showed about 10% unsealed. An unspecified foam backing

'aterial was found in one vertical firestop.

(4') Tur'bine Buildin Of fifty-six fire stops inspected, fifty-two contained openings that were not sealed and/or an incomplete coating of flamemastic.

(5) Cable Tunnel Flamemastic had not been applied to the cables in the cable tunnel.

The specifications require a coat'ing of at least ten feet every fifty feet. Eleven of fifteen penetrations were not plugged. One large group of penetrations at the end of the tunnel was not plugged or coated, and w'as not shown on the installation prints provided.

(6) Radwaste Buildin Sixty-four fire stops were inspected'n the radwaste building.

Fourteen of the fire stops inspected contained one or more unsealed openings and/or incomplete flamemastic coating. Several penetrations were identified in the field that did not show on the installation prints. A large number of penetrations shown on the installation prints were not used.

)

UNITED STATES NUCLEAR REGULATORY CO51iVilSSION REGION II

,230 IeKACHTRKK STRKKT, N. W. SUITK 818 ATLANTA,CKORCIA 30303 IE Inspection Report No. 50-261/75-8 Licensee: Carolina Power and Light Company 336 Fayetteville Street Raleigh, North Carolina 27602 Facility Name: H. B; Robinson 2 Docket No.: 50-261 License No.: DPR-23 Cat'egory: C Location: Hartsville, South Carolina Type of Licenses: PWR gf), 700 MPe, 2200 'MNT Type of Inspection: Special, Announced Dates of Inspection: May 5-6, 1975 Dates of Previous Inspection: April 29-30, 1975 Principal Inspector: N. E. Bender, Reactor Inspector Facilities Operations Branch Accompanying Inspectors: Hone Other Accompanying Personnel: None Principal Inspector: r i v~n.~

N. E. Bender, Reactor Inspector Date Facilities Operations Branch

-~h Reviewed by:~J. Ol '.

Long, Chief

+~c Date Facilities Operations Branch

~OTIP'~

~o 1PP6.1916

~e

1 IE Report No. 50-261/75-5 T

SUMMARY

.OF FINDINGS I. Enforcement Items None II. Licensee Action on Previousl Identified Enforcement Matters Not inspected III.. New Unresolved Items None.

IV. Status of Previousl Unresolved Items Not inspected V. Unusual Occurrences None VI. Other Si ificant Findings None VII. Mana ement Interview The findings of the inspection were .discussed with Mr. J. B. McGirt and members of his staff on May 8, 1975.

V

~ 't t't ~ '

IE Rpt. 'No. '50-'261'/75-"8

~ DETAILS I Prepared by:

N. E. Bender, Reactor Inspector Facilities Operations Branch W )S'ate

,Dates of Inspection: May 5-6, .1975

'evieweB by:

F. J. Long, Chief Date Facilities Operations Branch

l. Individuals Contacted

,J. McGirt - Plant Manager K. Young Electrical Engineer W. Traylor Mechanical Engineer

2. The purpose of this special inspection was to determine the requirements and commitments relating to compartment boundary seals for electrical penetrations for this facility, and to determine conformance to those requirements.

"3. Facilit Construction Specifications

? Section 8.2.2, Power Distribution System, of the'H. B. Robinson FSAR contains the paragraph "To prevent spread of flame, fire barriers of glass wool packed around trays on approximately 10 foot spacing in vertical runs has been provided. Fire barriers of similar construction are used in all trays when they penetrate walls."

The licensee's answer to Question VF, in the response to AEC Questions, relating to reactor trip and engineered safety features circuitry, contains the sentence "In instances where physica1 conditions prohibit hori.zontal separation, horizontal fire barriers are provided."

The licensee is unable to locate any documentation to show that the commitments of the FSAR were met during construction. The inspector requested to see the following type documentation and was informed that it.was not available.

a. Construction drawings or specifications'showing the location, type, number, materials and assembly details of the barriers.

b. Material specifications to include procurement specifications and fire resistant characteristics.

c. Material qualifications by Mil-Spec 'or other approved tests.

d. Qualification of an actual or simulated assembly through testing.

~ ~

~ I IE Rpt. No. 50-261/75-8 3

~ e.

f.

Procedure Application of for iait'9.al installation jl fire retardant and material application.

coating on safety related cables in vicinity of fire barriers.

CP&L has contacted the Architect Engineer, Ebasco Services, to obtain documentation on the design and installation of the barriers 'to include the above items.'t is the understanding of the inspector that Ebasco has quoted a price for the work and CP&L is preppring a purchase order.

4. Maintenance -.and Modification Procedures The licensee does not have procedures Xor inspection, maintenance or repair of existing barriers. Numerous cases of barrier breaching are discussed in item 5, below. Procedures do not exist for installation of fire barriers when new wall or floor penetrations are established for cables required by plant modification.

5. Visual Inspection A visual examination of the installed barriers was conducted by the inspector to determine the as-is status. Two basic type wall penetrations were identified. Conduit and tray.

Mas tic ~

>fall or Floor Tray Mastic c.

a 0 d g 0 O

o

'3/4" Asbestos 0 e 0

0 o

Glass wool Cable ~Conduit Board

n. Conduit The licensee and the inspector estimate that approximately 50 percent of the conduits containing safety related cable have been sealed as shown in the sketch, with the remainder unsealed. The requirements for sealing, and the material used is unknown. Host unused conduits were capped but'umerous instances were noted where caps were missing.

0 IE Rpt. No. 50-261/75-8 t

b. ~Tra s Barriers for floor penetrations from the control room down to the cable spreading room have asbestos board on the underside of the floor with a mastic applied on the upper side over glass wool. The following was noted by the inspector.

(1) Much of the mastic has been broken while some is missing.'2)

Barriers were not established when the Axial Power Distribution Monitori'ng System Panel and The Turbine Startup Panel were installed in the control room.

(3) A modif'ication in The Radiation Monitor Panel caused breaching of its barrier and was not repaired.

Except in isolated instances it appears that fire stops were provided for all wall and floor penetrations throughout the plant for safety related cables. In some hard to get at places the mastic was poorly applied. Numerous barriers have been breached through plant modification or -.maintenance and not returned to their original status. The unavailability of documentation showing original specifications and requirements is the licensee's reasons for not repairing breached barriers or installing barriers for new

~ 3 6.

penetrations.

Licensee Actions Requested b IE Bulletins 75-04 and 75-04A Response to these two bulletins was provided in CPSL letter dated April. 24, 1975. -It was stated'hat final response to 75-04A would. be completed by July 31, 1975, with progr'ess reports submitted monthly.

It would be expected that all the construction documentation would have been received from Ebasco and the necessary corrective action taken regarding the deficient barriers by that date.

II w - 4 4b UNITED STATES NUCLEAR REGUL'ATORY COI'IMISSION AEGION Il

'330-FFACIITREE STRECT, N. 'LV. 'UITE 818 ATLANTA,GEORGIA 30303 I

IE Inspection Report Nos. 50-269/75-6, 50-270/75-7 and 50-287/75-7 Licensee: Duke Po0rer Company Power .Building 422 'South Church Street Charlotte, North Carolina 28201 i

Facility Name: Oconee Units 1, 2 and 3 Docket Nos.: 50-269, 50-270. and 50-287 License Nos.:, DPR-38, 47 and 55 Category: C, C and B2 Location: Seneca, South Carolina Type of License: B&b, PHR, 2568, ~i~(t)

Type of Inspection: Special, announced Dates of Inspection: April 30 May 2, 1975 Dates o f Previous Inspection: April 22-25, 19 75 Principal Inspector: <~>>A-T. N. Epps, Reactor Inspector Date Facilities .Operations Branch P

Accompanying Inspectors: None Reviewed by: "-"'. '. 0 ~ 4~~~ ~ /g 5/75 F. J. Long, Chief Date Facilities Operations Branch

Rpt, Nos, 50-269/75-6, 50-270/75-7 and 50-287/75-7 SUif~Y OF FINDINGS I. Enforcement Items None II. Licensee'ction on Previously Identified Enforcement Matters Not inspected.

III. New, Unresolved Items None IV. Status of Previousl Reported Unresolved Items Not inspected.

V. Other Si nificant Findings Oconee-2 reactor coolant flow appears to be close to the calculated core lift valve. This item will be referred to the Office of Reactor Regulation (Licensing) .

VI. Mana ement Interview A management interview was held on May 2, 1975, with Mr. J . E. Smith and members of his stiff. The fire stop inspection and the Unit 2 flow problem were discussed.

Further discussions were held with licensee corporate management, on May 8, 1975, concerning control of flamable materials and smoking in the cable spreading rooms and equipment rooms.

IE Rpt. No. 50-269/75-6 DETAILS I Prepared by: ~-- . ol; T. N. Epps, Reactor Inspector Date Facilities Operations Branch Dates of Inspection: April 30 May 2', 1975 C

by:" ~7

. J F. J. Long,

~'eviewed Chief 'Date Operations Branch

'acilities

l. Individuals Contacted Duke Power Com an (DPC)

J. E. Smith Manager, Oconee Nuclear Station J. W. Hampton Director, Administrative Service's L. E. Schmid Operating Superintendent

0. S'. Bradham Maintenance Superintendent R. M. Koehler Technical Services Superintendent T. S. Barr Technical Services- Engineer H. Hobs Junior Field Engineer, Construction J. W. Davis Field Engineer, Construction This part of the inspection'involved obtaining information on fire stops used at Oconee. The Oconee FSAR, Section .8.2.2.13.g, states that floor sleeves will be filled with a fire retardant material. Section 8.2.2.13.h states that wherever physically pospible, metallically armored and protected cable systems will be used and that with this type construction fire stops as such are not required. The licensee, however, is presently installing and reworking fire stops in the.

following areas: (a) turbine building to auxiliary building, (b) elec-trical equipment room walls, (c) electrical equipment room ceiling to cable room, (3) cable room walls, and (e) cable room ceiling to control room. Information presented herein concerns practices and materials presently. being used by the licensee.

a. Materials The following materials are being. used in fire stops at Oconee:

(1) Flamemastic is a fire resistant material 'sprayed on safety related control cables crossing power cable trays.

This material is commercially available and tested by a method that follows in principle American Standard ASTM E-119.

XE Rpt. No.'0-269/75-6 I-2 (2) Glastic is a UL recognized flame retardant glass mat polyester laminate. The thickness used at Oconee is 1/8 inch. This material was tested according to ASTH D-229 Method I. I (3) Monokote is a plas'ter 'like material used for fire proofing

'nd tested and rated by Underwriters'Laboratories, Xnc.

in accordance with test method ASTH E119. A 2-1/2 inch thickness provides fire proofing for approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Thh licensee uses a minimum of four inches in fire stop applications.

(4) Armaflex - is a rubber like material used in approximately 1 inch thick sheets for sealing against air flow. Xt retards burning and has been tested per ASTH D 1692 and by the licensee with a torch.

The above materials are corr~erically available and are purchased through a local contractor.

b. Installation

~ A licensee representative stated that efforts .were recently initiated to upgrade fire stops at Oconee. This is being conducted in two phases. All open penetrations through walls that are fire barriers are to have fire stops installed. The inspector observed several 6 inch diameter penetrations in the cable spreading room ceilings that opened into the control rooms

~

above that did not have fire stops installed. The licensee stated that installation of fire 'stops would be completed in about three weeks.

The second phase involves reworking old fire stops and adding Monokote to a minimum thickness of 4 inches.

1

~

Several configurations are planned for fire stops at Oconee as follows:

(1) Where cable trays penetra'te walls, either Armaflex or 1/8 inch thick Glastic for air sealing and a minimum of 4 inches of Monokote for fire stops will be used.

(2) Where empty pipe sleeves in floors or walls exist 1/4 inch

, thick steel plates will be tack welded in place to cover these openings.

~ ~ ~

IE Rpt. No. 50-269/75-6 (3) Where pipe sleeves, with cable, piping or instrument lines "

exist Honokote held in place by wire and steel supports will be used. Some will have approximately 2 inch conduit instalged for temporary instrumentation cables and asbestos cloth will be used as packing.

(4) Small cable shafts between the cable spreading rooms

~ ~ and the control rooms will be sealed with 1/8 inch Glastic and Monokote.

A licensee representative stated that no testing has been accomplished on fire stop assemblies.

c. Administrative Items

. It appears that there is no specific requirement'or repair of fire stops and re-inspection of reworked areas at Oconee. A licensee representative stated that such a requirement is being considered.

Licensee representatives stated that there is no requirement against smoking or control of flamable materials in the cable spreading rooms or equipment rooms. Concern was expressed with regard to this policy to Duke Power Company .corporate management by telephone on May 8, 1975.

The licensee response to IE Bulletin 75-04 and 75-04A has been received by Region II. Licensee corporate management stated, on May 8, 1975, that an additional response to bulletin 75-04A would be submitted after additional review of the subject is completed on June 16, 1975.

3. Oconee 2 Reactor Coolant Flow The licensee reported that indications of Unit 2 reactor coolant flow, from a secondary system heat balance were above the core lift valve of 11.9% of design flow but that instrumentation problems were suspected.

On May 4, 1975, the licensee reported that, after further testing of instrumentation used in heat balance determinations, the Unit 2 flow appeared to be 111.5% of design flow. Further testing is being conducted by the licensee to attempt. to verify whether or not core lift is occurringo This matter has been referred to the Office of Nuclear Reactor Regulation (Licensing) for further review.

r re r P UNITED STATES NUCLEAR REGULATORY COi%1MISSION REGIDN II 230 IsEACHTREE STIIEET, N. W. SUITE BIB ATLAI4TA,GEORGIA 30303 RO Inspection Report No. 50-.250/75-7 and 50-251/75-7 Licensee: Florida Power and Light Company 4200 Flagler Street P.,O. Box 013100.

Miami, Florida 333.01

,Facility Name: ,Turkey .Point 3 and 4 Docket No.: 50-250 and 50-251 License No.: DPR-31 and DPR-41 Category: C/C

,Location: Dade County, Florida Type of License:, H H&-760 Mwe, 2200 Mwt Type of Inspection: Special Announced Dates of Inspection: May 12-14, 1975 Dates of Previous Inspection: April 15-18, 1975 Principal Inspector: A. K. Hardin, Reactor Inspector Facilities Operations Branch Accompanying Inspector: Non'e Other Accompanying Personnel: None r

Prlncipel lnspecccr: D. 'p A. K. Hardin, Reactor Inspector Date Facilities Operations Branch Reviewed By: ... ~V F. J. Long, Chief

'~

Facilities Operations Branch.

/ r oiuTfoe e

F76 1916

IE.Rpt. Nos. 50-250/75-7 and 50-251/75-7

SUMMARY

OF FINDINGS I. Enforcement Items None II. Licensee Action on Previousl Identified 'Enforcement Matters Hot within the scope of this inspection.

III. New Unresolved"Items Hone

~ IV. Status of Previousl Re orted Unresolved Items P

Not within the scope of this inspection.

V. Unusual Occurrences None Other Si ificant 'Findin s During an inspection of cable tray .penetrations, 'two locations were observed which appeared to deviate from the fire stop installation commitment made in the~L FSAR, page 8.2-9.

(See Details I, paragraph 3d and 3e).

VII. Mana ement Interview The findings, including the apparent 'deviations from the FPL FSAR, of the special inspection were discussed with FPL management repre-sentatives listed in the Details.

0 y' IE Rpt. Nos. 50-250/75-7 and 50-251/75-7 DETAILS I Prepared By: Q ~ /C>

A. K. Hardin, Reactor Inspector Date Facilities Operations Branch I

S Dates of Inspection: Hay 12-14, 1975 I

I

'I F. J. Long, Chief Facilities Operations Branch All information'n the details applies equally to Turkey Point 3 and 4 except where information is identified with a specific reactor.

1. Individuals Contacted

+H. E; Yaeger Plant Manager

• J. K. Hays Plant Superintendent, Nuclear

• J. E. Tucker ifaintenance Superintendent

• D. W. Jones Quality Control Supervisor H. J. Dager Manager, Power Resources, Nuclear V. T. Chilson Power Resources Specialist W. A. Thue --System Operations Engineer D. Van Tassel Plant Electrical Engineer I

+Present at management exit interview.

2. 'Scope 'of'Special 'Insuection The purpose of this inspection was to review require'ments for compartment boundary fire stops for electrical penetrations and the extent'o which the facility conforms to the requirements.

3. Re uirements 'and Verification of Com liance "The Turkey Point FSAR, Section 8, page 8.2-9 states, cable trays passing through walls or floors are provided with fire stops as shown in Figure 8.2-19'." (See Figures 1 and 2 attached to this report) "A similar fire stop is provided where cables pass through floor slots, such as under control panels. A thermal re-sistant coating (such as Flamemastic 71A) is applied to cables in the cable spreading room, and to cables inside and outside the containment in the penetration area".

~ .

IE Rpt. Nos. 50-250/75-7 I>>2 and 50-251/75-7 A construction installation procedure dated 4/10/70 identified as Job No.'610, Dwg 5610-E-310, states in Section III, "Raceway's passing through walls, ceilings, or floors shall have a fire stop such as shown on Plorida Power and Light drawing A-GO-4 and A-G0-5."

These drawings are the same as shown in the FSAR and are appended as Figures 1 and 2 of this report.

Only the above listed general statements regarding location of fire stops were made availabge to the inspector. The licensee stated that no master list of .fire stop locations existed; An inspection was conducted to determine the application and extent of application. of fire retardant coatings and the location and con-of fire stops. The inspection covered .the following areas. 'truction (a) Fire st'ops for power cables from the unit auxiliary trans-former through the wall of the 4160V switch gear room were examined. Fire stops, as described in Pigures 1 and 2 attached, were in place and were in good condition.

(b) Fire stops for Power control cables from the 4160V 3 switch gear room to the 480 .volt switch gear were examined.

The fire stops were in place. Some .new power cables had been run from the 4160V switch gear to newly installe'd eon-

' densate pumps. These cables were not sprayed with Flame-

'astic. Inside both 4160V and 480V switch gear room, it.

was observed some cable trays-vere completely sprayed with Flamem'astic fire retardent while others were not. The licensee did not have an explanation for the difference.

I (c) The Diesel Generator building was inspected. All cables

~

into and out of the building are run in conduit. No open raceways or trays are used.

(d} Control Rod Drive Rooms were examined. One tray of control cables in the Unit 3 control rod drive room did not have a fire stop (e) Cable trays entering and exiting the auxiliary building were examined. Four large cable trays enter the auxiliary building above the main corridor doors. The cables and trays are sprayed with Plameastic 71A for a distance of about 2 feet inside and outside. the wall.but the trays do not have fire stops. Those cable trays exiting the auxiliary building did not have fire stop> installed.

1 IE Rpt. "Ho's. 50-'250'/75-'7 I-3 and 50-251/75-7 (f) The cable spreading room was examined. All cables and trays Xn the room are sprayed with Flamemastic fire retardant.

All fire stops where raceways enter and leave the room were in good condition. Other ductwork in the cable spreading room such as air conditioning ducts were sprayed with Flame-mastic fire retardant.

4. "Maintenanc'e and Modification Procedures The inspector concluded ifrom observation and -discussions that prior to .the recent severe fire at a nuclear plant that FPL did not have a maintenance and modification procedure which specifically addressed breaching of firestops. The licensee has recently approved a pro-

~ cedure entitled "Fire Stop and Cable 'Tray Fire Proofing". The pro-cedure names the Superintendent-Maintenance as the cognizant manage-ment member to 'authorize breaching a fire stop. The procedure fur-ther defines the construction details of the fire stop design to be usede

5. Site Ie~eectioe The details of examination of the cable'rays fire stops are dis-cussed in item 3, above. In discussions with the licensee, the

'inspector was informed that major program of examining and re-working all 'firestops was und'erway. It is the licensee's intent to build fire stops on all entries and exits without regard to safety or non-safety related equipment,. The licensee further stated that t';ey intend to replace the transite fire stop material with "Marinite" because of its improved resistance to moisture uptake, and to spray cables with fire retardant a distance of 8 feet where practical rather than the two feet shown'n Figures 1 and 2.

6. Material Specifications for Fire Sto s The licensee uses Flamemastic 71A, fiberglass, transite, and Marinite in construction of the firestops. The licensee procures these materials by tradename. The inspector concluded from specifications provided to the licensee by the vendors, and from copies of tests of the materials conducted by FPL and independent testing agencies that the materials of construction are flame. retardant and will not of themselves support combustion.

~ ~ ~ \

IE Rpt. Nos. 50-250/75-7 I-4 Gnd 50-251/75-7

7. Licensee Actions on.EEB's 75-04 and 75-04A The subject bulletins required the licensee t'o evaluate certain fire protection measures and protection from events which might occur as a result of a fire. The licensee responded to these bulletins on April 23, 1975. The licensee concluded..in his response that their

'policies, plans, procedures 'and sys'tems provided the required con-trol and protection. During the inspection, the response was dis-cussed with members of 'FPL,management. /he,inspector stated, that the response did not contain sufficient information to permit a reasonable evaluation by the HRC that the utilities conclusions were justified. The licensee agreed to prepare a supplemental report which would contain a listing of the procedures and other documentation supporting their position. The inspector accepted a supplemental report submittal date of June 27, 1975.

I 3I

~ ~

S ~ ~ S ~

~ ~ ~ ~

~ ~

~ j

~ ~ ~ ~ 0

~ If ~ 5

~ ~

~ ~

~ l

0

~ ~ ~ ~

4 ~ ~ g ~ ~ ~

~ ~

~ ~ ~ ~ 1 ~ t

~ ~

~ ~

~ ~ ~ ~

0 ~

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 230 PEACHTREE STREET, N. W. SUITE SI0 ATLANTA,GEORCIA 30303 IE Inspection Report Nos; 50-280/75-7 and 50-281/75-6 Licensee: Virginia Electric and Power Company P. 0. Box 26666 Richmond, Virginia 23261 Facility Name: Surry Power Station Docket Nos: 50-280 and 50-281 License Nos.: 'PR-32 and DPR-37 Category: C/C Location: Surry, Virginia Type of License: PMR (M) << 822 Mlfe, 2441 halt Type of Inspection: Special, Announced Dates'f Inspection: April 16-18 and May 1, 1975 Principal, Inspector: H. V. Sinkule, Reactor Inspector Facilities Operations Branch Accompanying Inspectors: None Other Accompanying Personnel: None

/

Principal Inspector: '(r. I".. ~ ..

M. V. Sinkule, Reactor Inspector ate Facilities I'

Operations Branch Reviewed by: ~ a F. J. Long, Chief Date Facilities Operations Branch

I ~

~ ~

IE Rpt. Nos. 50-280/75-7 and '50-281/75-6 0 S&kfARY OF FINDINGS

~I I. Enforcement Action None II. Licensee Action on Previously Identified Enforcement Matters Not within the scope of this inspection.

,III. New Unresolved Items None IV. Status .of Previously Reported Unresolved Items Not within the scope of this inspection.

V. Unusual Occurrences None VI. Other Significant Findin, s None VII. Mana ement Interview The inspection findings were discussed with T. L. Baucom, Superintendent, Station Operations, and others of his staff on May 1, 1975, as described in the details section of this report..

9

IE Rpt. Nos. 50-280/75-7 and 50-281/75-6 DETAILS I Prepared by:

M.

i .. /a~ r ~. !cd&

V. inkule, Reactor Inspector Date Facilities Operations Branch

. Dates of Inspec'tion: April 28 to May 1, 1975 Reviewed by: - )I, .L.- w~~~

F. V.'ong, Chief Date Facilities Operations Branch All items pertain equally to Surry 1 and Surry 2 unless otherwise designated.

l. Individuals Contacted C Vir inia Electric and Power Company Station Personnel E. Sweeney, Jr. - Manager, Surry Power Station

• T. L. Baucom Superintendent, Station Operations

• R. E. Nicholls Supervisor, Electrical Maintenance

~D. W, Speidell, Jr. Engineering Supervisor J. Kenny Assistant Operating Supervisor To M. Panak - Store Room Supervisor

~W. C, Earl - Administrative Assistant

• I, P. Kubler << Electrical Foreman M. D. Tower Quality Control Engineer Cor orate Personnel

• R. E. Morton System Electrical Supervisor T. Stephenson Nuclear Applications Engineer Richardson and Wayland Electrical Contractors

• J. O. Olin Electrical Foreman W.. E. Beasley - Electrician E. D. Fitzgerald - Electrician

+Present during management interview.

2. ~Sco e The scope of this inspection was to review the specifications .for the construction of fire stops on electrical cables penetrating compartmental boundaries and to inspect the areas where the stops were located.

L t

A

IE Rpt. Nos. 50-280/75-7 I-2 and 50-281/75-6

3. Sur FSAR and Construction Snecifications Section 8.2 of the Surry FSAR states that cable tray construction shall have approved fire stops in both the horizontal and vertical runs. Facility construction specifications for tray installation do say, that fire stops will be used, however, construction prints do not show the details of the stops utilized. Neither reference specifically addresses the compartment boundary fire stops on .electrical cables.

I The only docu entaticn that shows the fire stops utilized at Surry is a memorandum containing generalized sketches of the stops to use at Surry and a recommended procedure for installing the stops. 'these sketches show the details of two types of pressure seals and/or fire stops as described below:

ao Sleeves containing cables Two notched pennies made of one eighth inch thick "micarta" (or steel) shall be inserted in each sleeve approximately one and one half inches apart. The void between the two pennies will be filled with "Thiokol" potting compound. The vo'id between the outer penny and the "bakelite" bushing will be filled with duct seal (no dimension given). Duct seal will be used to seal around edges of the pennies and c bles and penny edges.

Two, one eighth inch coatings of "Flamemastic 71A Sprayable" will be placed over the outside surface of the sleeve opening. Two, one eighth inch coats. of "Flamemastic 71A Sprayable" will be placed on the inside penny from the other side of the. sleeve. On vertical sleeves only one bottom "penny" needs to be used to contain "Thiokol" potting compound and,fire retardant need only be applied to one side of the stop.

b. Sleeves containing no cables These sleeves shall be sealed using solid threaded metal sleeve inserts. Two,. one eighth inch coats shall be sprayed on the outer surface of the sleeve inserts.

Co Fire stops for cable trays This type of stop is utilized for cable trays penetrating fire walls. Asbestos wool insulation is placed in the penetration around the cables and between two, one quarter inch steel plates, one on each side of the wall, bolted to the wall, loosely fit around the cables, Duct seal is packed in and around the cables approximately for two inches inside each steel plate Two, one eighth inch coats of "Flamemastic 71A Sprayable" shall be applied over the duct seal and efforts made to apply the "Flamemastic" in and around the cables within the tray close to the fire stop. The sketch shows a one eighth inch coating of "Flamemastic 71A" spray coating to be applied to both the top and bottom of the cables approximately six .feet back from the fire stop on one side.

0 l

IE .Rpt. Nos. 50-280/75-7 I-3 and 50-281/75-6

4. Ins ections of Fire Stops An inspection was conducted to verify that fire stops were constructed as described in paragraph 3 above. Since construction prints did not specify where the stops were to be located, the inspector reviewed compartmental walls which contained electrical safety related cables all penetrating the walls and electrical cables pqnetrating areas where safety related cables -wepe located. There are two types of penetrations used at Surry. One type utilizes a c"rbon steel circular sleeve embedded in the concrete with "bakelite" bushings threaded into each end to prevent cutting of the cables. The other type penetration is a rectangular opening in the concrete wall or floor to facilitate penetration of cable trays.

The following variations in the actual construction of fire stops with the design described in paragraph 3 were noted.

a. Rela Room (Sur 1)

(1) There are a number of horizontal sleeve type penetrations from the relay room to the cable vault. These penetrations are packed with duct seal on the relay room side with no fire

, retardant applied. These 'penetrations do have "Flamemastic" on cable vault side. Several new cables have been pulled through one penetration, and the penetiation has been sealed, however, "Flamemastic" has not been applied. The "Flare-mastic" on the cable vault side extends back from the seal approximately fifteen inches.

(2) Examined twenty, 6 inch penetrations from the relay room

'to the cable tunnel. These penetrations are packed with

.duct seal on the relay room side with no fire retardant applied on relay room side. These penetrations do have "Flamemastic" on the cables on the cable tunnel side approxi-mately fifteen inches back from the seal.

b. Emer encv Switchgear Roo@ (Surr 1)

(1) There are a'umber of six inch sleeve penetrations from the energency switchgear room to the cable tunnel. Examined approximately one half of these penetrations and they appear to,be constructed as described in paragraph 3a. Flamemastic"

,has been applied four or five inches back on the cables, "Flamemastic" has been applied from the cable tunnel side approximately 'fifteen inches back on the cables. Two of the penetrations observed appear to have new cables pulled through them. "Flamemastic" has not been reapplied to these cables.

EE Rpt. Nos. 50-280/75-7 l-4 and 50-281/75-6 (2) There are six penetrations on the west wall of emergency switchgear room into duct lines. The cables entering these penetrations are packed with duct seal. No "Flamemastic" has been applied.

(3) There are a number of veitical sleeve type penetrations from the emergency switchgear room to the control room.

These penetrations contain instrument and control cables to the reactor instrument panel and to the reactor console.

These penetrations are packed with duct seal from the bottom and an insulating material, "vermiculite," is applied from the control .room side.. The floor is fifteen inches thick (concrete) with a nine inch trench in the area of the sleeves. This trench is filled with the insulating material described above.

Co Cable Vault (Sur 1)

Sixteen horizontal trays penetrate the cable vault from the cable tunnel. The fire stops in this area appear to be constructed as described in paragraph 3c, however, 'lamemastic" has only been applied on the ca'oles approximately six inches from the wall instead of six feet as described on the construction sketch.

Four of the trays contain newly pulled cables. Duct seal has been packed around the cables, however, "Flamemastic".

has not been applied.

(2) There are a number of horizontal sleeve type penetrations from the cable vault to the safeguards building. The cables are sprayed with "Flamemastic" from the cable vault side.

Duct seal has been applied from the safeguards building side, however, "Flamemastic" has not been applied from the safeguards building side of the wall.

One penetration to the safeguards building contains new

'cables. Duct seal has been applied around the cables, however, a fire retardant has not been applied.

(3) There. is one wall penetration of the type described in

'aragraph 3c from the cable vault to the auxiliary building.

Fire retardant has been applied from the cable vault side, however, it has only been applied about six inches on the cables. "Plamemastic" has not been applied from the auxiliary building side.

IE Rpt. Nos. 50-280/75-7 I-.5 and 50-281/75-6 Several new cables have been pulled through the penetrations described above. Duct seal has been applied, however, fire retardant has not been applied.

(4) There are a number of horizontal sleeve penetrations from the cable vault to the auxiliary building. These cables are coated with "Flamemastic". for about 15 inches from the seal on the cable vault side. They are sealed with duct seal from the auxiliary building side. "Plamem'astic" has been applied .from the auxiliary building side.

d. Cable S readin Room Above Control Room (Surr 1)

Q) There are approximately fifteen vertical cable penetrations of the type described in paragraph 3c from the -cable tunnel to the cable spreading room. "Flamemastic" has been applied to the penetration on the spreading room side and up on cables about 2 inches. The electrical maintenance personnel indicate that below the "Plamemastic" is asbestos wool and duct seal.

One new cable has been installed through one of the penetrations, however, no fire retard'ant has been applied.

(2) Cables through the ceiling penetrations from the cable spreading room to the main switchgear room have duct seal packed around the cables from "the cable spreading room side.

No'ire retardant has been applied. The penetrations enter the high voltage switchgear cubicles in the main switchgear

.room. The high voltage switchgear cubicles were not opened, therefore, the inspector did not observe the tops of the penetrations.

e. Main Switch ear Room (Surr 1 and 2)

The main commhrcial power feeders enter this area from the turbine area. These penetrations are provided with the type of penetration described in paragraph 3c. "Plamemastic" has been applied on the cables approximately one foot from the penetrations.

~

J

f. Emer enc Power Cables (Surr 1 and 2)

(1) There are a number of horizontal sleeve type penetrations from the emergency switchgear room and relay to the cable tunnel. These penetrations have duce seal packed around cables .

0 0

.IE Rpt. Nos. 50-280/75-7 I-6 and 50-281/75-'

/ ~ ~

from the relay, room and emergency switchgear room side. No

. "Flamemastic" had .been applied from emergency switchgear room or relay room side. Cables on the cable tunnel, side are sprayed with "Flamemastic" back about fifteen inches from the seal.

Although,all p'enetrations were not observed fr'om cable tunnel side, at least one of the penetrations had new cable pulled through it and "Flamemastic" had not been reapplied.

(2) .There are a number of horizontal sleeve penetrations from the .east wall emergency .switchgear;room to the equipment room. These penetrations are packed with duct seal on both sides of wall. No "Flamemastic" has been applied.

(3) There is one horizontal cable tray penetration of the type.

described in paragraph 3c from Unit No. 1 emergency switch-gear room to Unit No. 2 emergency switchgear room. The "Flamemastic" has been applied on the cables approximately six inches back from the penetration.

(4) There are a number of vertical sleeve penetrations from the-emergency switchgear room to the control room. These pene-trations are sealed with duct seal fr'om the bottom and an insulating material from the top as described in paragraph 4b(3) for Unit No. 1.

h. Cable Vault (Surr 2)

There are sixteen horizontal tray penetrations from'the cable tunnel and these appear to be constructed as described in

.paragraph 3c of this report. The "Flamemastic" is applied on the cables about six inches from the seal.

(2) The penetrations from the cable vault into the auxiliary building are the same as described for Unit No. I in paragraph 4c(3) and 4c(4). Xt was apparent that several penetrations were being repaired during the inspection.

(3) The penetrations from the cable vault into the safeguards building are the same as described for Unit No. 1 in paragraph 4c(2).

Cable S readin Room (Surr 2)

There are approximately fifteen vertical penetrations from the cable tunnel to the cable spreading room. These penetrati'ons are packed with duct seal from the top. No "Flamemastic" has

XE Rpt. Vos. 50-280/75-7 I-7 and 50-281/75-6

~ Q been applied. Discussions with the that these penetrations are packed electrical foreman indicate with asbestos wool below the

-duct seal. It was difficult to observe these penetrations from the bottom side because of inaccessibility.

(2). There are a number of vertical sleeve penetrations from the cable spreading room to the main switchgear room.

These penetrations are coated with "Flamemastic" back about five inches on the cables. Several new cables have been pulled through two penetrations and the cables packed

with duct seal. "Flamemastic" has not been reapplied on these cables.

(3) Cables through the floor vertica1 sleeve penetrations to the control room are the same as described for Unit No. 1 in paragraph 4d(3).

5. Modifications (Surrv 1 and 2)

A number of modifications have been made involving pulling of new cables through fire walls between the control room, emergency switch-gear room, cable tunnel, cable vault, 'uxiliary building, saf eguards

~- building', and the cable spreading room above the control room.

a.

these modifications are as follow's:

between Units 1 and 2 to provide an I

Addition of cross-tie lines and-associated motor operated valves Some'f additional suction line for each safety injection system.

b. Addition of cross-tie lines and associated motor operated valves between Units 1 and 2 auxiliary feedwater systems to provide an additional steam generator water source.

c. 'ddition of two booster pumps and piping between the underground condensate tank and the suction side of the auxiliary feedwater pumps for each unit to provide an additional ~ater supply to the auxiliary feedwater systems.

Addition of orifices in each 'steam generator blowdown line to provide a signal for closing the .blowdown trip valves on high flow conditions.

e. Relocation of the solenoids which operate the main steam trip valves to an area which is not subject to steam atmosphere.

f. Interlocking of accumulator valves. (Surry 1)

IE Rpt. Dos. 50-280/75-7 I-8 and 50-281/75-6

g. Interlocking of Residual Heat Removal System valves The corrective maintenance procedures for replacement of safety related high voltage power cables and for replacement of safety related low voltage control cables were reviewed for the above modifications and no provisions were incorporated in the procedures for the breaching of compartmental fire stops or repair of the fire stops to insure that integrity of the stops are maintained. For instance, the above described, "

modifications involved pulling approximately 120 new cables. Approximately one half of these cables were pulled through fire stops. Cable pulling

,procedures do not include provisions for quality control inspections to insure that proper materials are used and to insure that repair is made as designated by the procedure. VEPCO representatives stated that the cable pulling procedures will.be revised to include instructions for repairing the fire stops and inspecting them during and subsequent to repair.

6. Fire Stoo Construction (Sur 1 aad 2)

The fire stops were originally installed on the cabIe penetrations by Stone and Mebster Engineering Corporation. Host of the cables involved with modifications were pulled by Richardson and wayland Electrical Contractors. The work was acco..plished by use of a VEPCO approved maintenance procedure and the cable routings were approved by the VEPCO electrical n inten nce supervisor. Althou h cables were pulled by electrical contractors, they were under direct control of VEPCO site management.

a. Fire Stop Naterials Originally the fire stops were constructed of asbestos wool, duct seal, "Thiokol" potting co pound, "micarta" pennies, "vermiculite" insulating material, steel sheets, and "Flamemastic 71A" fireproofing material. The purchase of these materials was handled by the contractor who procured them from electrical suppliers, Purchase orders and material specifications were unavailable except for a technical bulletin which describes the fire retardant characteristics of "Flamemastic 71A" and acceptable methods of applying the "Flamemastic."

(1) "Flamemastic 71A" is produced by Dnya-Therm Corporation 1

and the fire resistance characteristics are described on Dyna-Therm Technical Bulletin 01079, Issue 2. The bulletin specifies no burn-through of one sixteenth of an inch coating after fifteen minute exposure to a propane torch, flame temperature, 2050 F with the distance from Oz the torch of two inches. The chemical composition or the fire retardant characteristics available.'

of the material was not

IE Rpt. Nos. 50-280/75-7 I-9 and 50-281/75-6 (2) "Thiokol" potting compound -No information was available on the chemical composition or fixe retardant characteristics of this material. VEFCO is currently using a comparable material, "PRC" potting compound. The documentation was not available on the chemical composition or fire character-

. istics of this material. This material is being used as a sealant and is type PR-1201-Q produced by Product Research Corporation.

(3) Duct seal Procurement documentation was not available.

A .product known as "Dux seal" ape NSG, produced by Johns Manville Coxporation is currently being used at Surry. The fire retardant characteristics were not available, however, i.t is being used as a sealant.

(4) "Micarta" board was used in the sleeve type penetrations to contain the potting compound. "Micarta" is a hard fiber like material. Documentation on the chemical composition or fire retardant characteristics of this material was not available.

(5) Asbestos wool is an insulating material. Documentation on the chemical composition or fire retardant characteristics of this material was not available.

(6) "Virmiculite" is an insulating material. Documentation on the chemical composition or fire etardant characteristics

~

of this material was not available. Sample of material .

would not burn when a torch-was applied for a short period of time.

7. Licensee Action

a. Licensee representatives stated that plans axe underway to test the types of fire stops used at Surry to insure that they will effectively, stop a fire.

b. Original material and inspection records will be obtained to verify original construction. If these records are not available, tests will be conducted on samples of installed materials to qualify the materials to above described tests.

c. Station cable pulling procedures will be updated to include fire stop repair and inspection.

d. Inspection of the fire stops will be completed and a repair program established to upgrade them to the standards qualified in the above described tests..

IE Rpt. Nos. 50-280/75-7 I-9 and 50-281/75-'6 gO.

4 ~ e. The reviews required by IE Bulletins 75-04 and 75-04A are detailed in paragraph 8 of this report.

8. Status of IE Bulletins 75-04 and 75-04A The initial response to IEB's 75-04 and 75-4A was 'contained in dated April 22, 1975. This letter establishes the schedule VEPCO'etter for 'completion of the reviews specified in the bulletin. The response

-sche'dules the completion of the review of item No.2 of Bulletin 75-04 by ofay 23, 1975, and completion of the remaining reviews on Bulletin 75-04'nd .75-,04A by June 2, 1975.

An engineer has been assigned from the corporate office to coordinate the response. Discussions with this coordinator indicate that

.approximately ten percent of the reviews have been accomplished as of April 30, 1975. The work that has been accomplished is on item

'o.'2 of Bulletin 75-04. No work had yet progressed on the remainder of the items.

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 230 PEACHTRCE STREET, N. W. SUITE SI8 ATLANTA,CEORCIA 30303 IE Inspection Report No. 50-.259/75-11 Licensee:, Tennessee Valley Authority 818 Power Building Chattanooga, Tennessee 37401 Facility Nane: Browns Ferry Unit 1 Docket No.: 50-259 License No.: DPR-33 Category: B2 Location: Decatur, Alabama Type of License: G-E, 1098 a~."ae, BUR Type of Inspection: Announced, Restoration of Fire Damaged Area of Inspection: July 23-25, 1975

'ates July 30-August 1, August 6-8, 1975 1975 August 13-15, 1975 August 20-22, 1975 August 27-29, 1975

~ Dates of Previ.ous Inspection. July 1-3, 1975 July 8-10, 1975 July 15-17, 1975 Principa3. Inspector: B. J. Cochran, Reactor Inspector Facilities Section Facilities Construction Branch Accompanying Inspector: T'. D. Gibbons, Reactor Inspector Engineering Section Facilities Construction Branch Other Accompany'ng Personnel: ione

.Principal inspector:

B. 'J. Cochran, Reactor Inspector 'ate Facilities Section

- Facilities Construction Branch we I /

<oLuTIoy J. C. Bryant, Senior Inspector ~ Date

~c 'acilities Section.

~ Q'i>'=:;-. "- Facilities Construction Branch b

~~~6-s9 I+

IE Rpt. No. 50-259/75-ll A

STORY OF FINDINGS I. Enforcement Items None II. Licensee 'Action on Previously Identified Enforcement >fatters None III. New Unresolved Items None IV.'tatus of Prey'ouslv Re orted Unresolved Items None V. Design Changes None VI. Unusual Occurrences None VII. Other Si nificant Findin s None VIII. Hang ement Interview The inspectors were in continuous communications with the licensee throughout the inspection.

IE Rpt. No. 50-259!75-11 DETAILS I Prepared by:

B. J. Cochran, Reactor inspector Date acilities Section Facilities Construction Branch

~/f, ! rt /( +sr r

J/ /W)

T. D. JGibbons, Reactor Inspector Date Engineering Section Facilities Construction Branch Dates of Inspection: July 23-25, 1975 July 30-August 1, 1975 August 6-8,'1975 August 13-15, 1975 August 20-22, 1975 August 27- 9; 1975 Reviewed by:

J. C. Bryant, Senior inspector Date Facilities Sect'on Facilities Construction Branch

1. Persons Contacted Tennessee Valle Authorit r H. J. Green Plant Superintendent ~

J. F. Groves Assistant Plant Superintendent J..G. Dewease QA Supervisor (DPP)

A. W. Crevasse QA Manager (OPQA)

J. R. Hilding - Site QA Pun".ger (OPQA).

S. P. Vest - Quality Enginr -'.ng Support (OPQA)

D. P. McCloud QA Audit S . visor (OPQA)

B. A. Gant Assistant Con'ction Engineer (DEC)

T. G. Campbell Electrial:. pervisor (DEC)

A. Gooch QA Records Clerk (OPQA)

2. General Status of Restoration Activities

a. The damaged cables, conduit, trays, hangers and supports have been identified, tagged, removed from, the fire area, and placed in storage.

Twelve concrete core samples were removed from the fire area at selected locations in the Unit 1 containment building and analyzed for de erioration due to chlorides released during the fire.

Sections of embedded rebar were also removed for analysis.

XE Rp t. No. 50-259/75-11 I-2

'3 ~

~

The licensee;reported that the analysis results indicated that there was no apparent deterioration in the concrete or rebar as a result of chlorides.

c. Unit 1 torus was inspected for movement during the reactor depressurization. . No movement of the torus was detectable.

d. Crews of electrcians and QC inspectors are assigned to two 12-hour to identify damaged cables in the cable spreading roo . and 'hifts reactor =building.

The licensee will remove all da .aged safety related cables and pull new cables.. Splicing will be done on non-safety related control, signal and power cables.

e. 'QA r'ecords of restoration activities performed prior to the removal of fire da .aged cables, conduit and trays, are being ass'emblcd, cataloged, and processed.

f. The licensee has issued work plans for removal of spalled concrete

'nd repair of da aged concrete and e bedments in accordance with 0 approved procedures.

C.

Porn 12 (pan 75) (Rev) 2 Uo S ~. NUCLEcU, REGULATORY CO~MISSION OFFICE '

OF INSPECTION AND Ebs'FORCWENT I

REGION I I

IE Inspection Report No: /

Licensee. Consolidated Edison Connan of New York License No'DPR 4 I rvin 'P la c e Priority:

New York New York 10003 Category:

Safeguards Group:

Location: Indian'oint 1, Buchanan. New York Type of Licensee".PMR B&$J (615 'AML)

Type of Inspection. Special, Announced

~~" of Inspection'. 4/29 ~ 30 5/1 2/75 Dates of Previous Inspection. 2/27-28/75 Reporting Inspector: gC~ d7 4 -2 2-70 G. Napudh DATE Accompanying Inspectors: None DATE DATE Other Acconpanying Personnel: None DATE Reviewed By:

R. C. Haynes, Senior Reactor Inspector

SRQiARY OF FINDINGS Enforcement Action j

A. Items of Noncom liance None B. Deviations None Licensee Action on Previousl Identified Enforcement Items Not Applicable None Ident- fied Unusual Occurrences None Identified Other Significant Findin s A. Current'indings

l. Acce table Findings

a. Correlation Between the Facility's Requirements and As-Built Status for Fire Stops on Electrical Safer -Related Cables and Penetration Seals A visual examination of the fire barriers and compartment seal installations and fire retardant coating applications was performed by the inspector. There is correlation between the as-built status and the documented requirements.

(Details, Paragraph 3)

b. Invokement of Facility Reouirements for Fire Stons on Electrical Safety-Related Cables and Penetration Seals in Haintenance and Nodification Procedures An examination was made of the maintenance and modification procedures for the installation of fire 'barriers and com-

. partment boundary seals, and the application of'ire.-re-tardant 'oating, for sa fety-related cables.

Present procedures appear to control maintenance and modifications to fire barriers. (Details, Paragraph 4)

B. Status of Previousl Re orted Unresolved Items Hot Inspected Mana ement Interview At the conclusion of the inspection, the inspector held a meeting at the site with the following personnel to discuss the inspection findings:

Consolidated Edison Comoan Mr. M. B. Byster, QA Engineer Mr. P. M. Duggan, Electrical Engineer "Mr. J. M. Makepeace, Technical Operations -Director Mr. S. G. Salay, Station Manager Mr. R. A. Saya, Division Engineer Th'e followi'ng items were discussed and the inspector's findings were acknowledged by the licensee.

A. Pur ose of Ins ection The inspector stated that the purpose of this special, announced inspection was to examine the documented facility requirements for fire stops on safety-related cables and penetration seals, to visually inspect these items for conformance with the requirements, to examine the licensee's provisions for invoking the requirements during maintenance and modification work and to determine the status of the licensee's efforts with respect to the actions listed in IE Bulletins 75-04 and 75-04A.

B. Current Findinns: Acce table Area The inspector stated that his review of the followir.g areas revealed acceptable findings:

1. Correlation Between the Facilit 's Requirements and As-Built Status for Fire Stons on Electrical Safet -Related Cables and Penetration Seals A visual examination was performed of the installation of fire barriers and compartment boundary seals, and the application of fire retardant coating for safety-related cables. There is

correlation between this construction and the facility's documented requirements. (Details, Paragraph 3)

2. Invokement of Facility Requirements for Fire Stops on Electrical Safet -Rel ted Cables and Penetration Seals in ifaintenance and Hodification Procedures An examination was made of the maintenance and modification procedures for the installation of fire barriers and compartment seals, and the application. of fire-retardant coating, for safety-related cables. There is correlation between these procedures and the facility's documented requirements. (Details, Paragraph 4)

C..= Status of Licensee's Efforts re IE Bulletins 75-04 and 75-04A The licensee provided the inspector with a status report on his efforts in complying with the requirements of IE Bulletins Nos.

75.-04 and'5-04A. (Details, Paragraph 5)

DETAILS

1. Persons Conta"ted Consolidated Edison Com an Mr. M. B. Byster, QA Engineer Mr. P. M.,Duggan, Electrical Engineer Mr. J. H. Makcpeace, Technical Operations Director Mr. R. A. Saya, Division,Engineer

2. General

a. Plant Status The 'plant is presently- in an extended shut down status.

b. Pur ose of Tn ection The purpose of this inspection was to examine the documented facilzty requirements for fire stops on safety-related cables and penetration seals, to visually inspect these items for conformance with the requirements, to examine the licensee's provisions for invoking the requirements during maintenance and'odification work and to determine the status of the licens'ee's efforts with respect to the actions listed in XE Bulletips 75-04 and 75-04A.

3.. C'o'rr'elation Between the Facility's Re uirements and As-Built Status for Pire Stops on Electrical Safety-Related Cables and Penetration Sea' Re uirements The in-pector found no applicable requirements for fire barriers and penetration seals in the Final Hazards Summary Report. He requested all site documentation related to the installation of fire barriers and penetration seals. Specifications EI-5045, Revision-3,, 1028, and 1029 were provided the inspector for,.h'is'eview. Fire barriers were not addressed in these sp'ecificati~ns. No construction and installation speci-fications for the cable ducts, were available.

The licensee had identified all penetrations and electrical equipment on prints 138002-1, 138003-1, 138384-3.6, 138732-10, 138733-6, 138734-28/29, 140937-3, 141176-6, and 141536-4 and these were reviewed and utilized by the inspector for his Observations.

Observations (1) Nuclear Service Buildin All cables were contained within heavy gauge metal ducts; where these ducts penetrated walls or floors, there was .a duct-to-concrete seal that appeared to be mortar.

i Cables entering .equipment were channeled through either metal troughs or conduits. All floor-entry conduits and troughs had fiberglass packing at the upper end. Fiber-glass had also been packed into the upper end of troughs that entered cubicles through the top of the cubicle. Ex-tensive use of asbestos wrapping within the cubicles was noted.

(2) Su erheater Buildin~

All duct penetrations had concrete-to-duct mortar seals.

Approximately S0% of the conduit penetrations had concrete-to-conduit mortar seals. Nine of the unsealed conduits passed through two floor sleeves into the control room at the west wall. Thirteen other conduits passed through a fiberglass-packed rectangular penetration in the control tunnel east wall. The other unsealed penetrations con-tained single conduit.

All control-room-equipment penetrations were through the floors of the cubicles.. These penetrations were packed with fiberglas or covered with a marinite board and had Flamemastic applied from both sides.

Elsewhere in the building, cubicle-floor-entry conduits were packed with fiberglass and sufficient evidence was available.to determine 'that troughs entering cubicle tops were fiberglass packed.

Extensive asbestos wrapping of cables and the installation of smoke detectors within virtually all cubicles was noted.

(3) Diesel Generator Room Conduits are used exclusively within this room. The penetrations to the electrical tunnel do not have {nor are required to have) fiberglass packing or sealing.

(4) Electrical Tunnel

~J.l cables are contained within enclosed heavy-gage metal ducts. Vhere these ducts penetrate walls, there is a concrete-to-duct seal. The exception is the cable that enters the Diesel Room, which is enclosed in conduit.

In addition to a water-deluge system, this area is pro-vided with ionization and smoke-detector>> systems.

(5) General Extensive use of asbestos wrapping on cables within cubicles was noted.

The licensee stated that in excess of 80% of the facility's cables were lead-wrapped and all cable insulation was fire-.

retardant.

In the areas examined, the inspector noted that all non-safety-related cables were protected with fire barriers in a fashion similar to that utilized for safety-related cables.

4. Invokement of Facilit Re uirements for Fire Sto s on Electrical Safet -Related Cables and Penetration Sea1s in Haintenance and Hodification Procedures The inspector reviewed Station Administrative Order No. 104-

"Haintenance cwork .Request (KnR) Procedure," and No. 127-"Hodifica-tions to Indian Point Facilities." .They require work instructions and provide control for maintenance and modification activities.

Urethane, originally used to seal the floor pentrations in the Control Room, was removed during the period of time when the unit 82 floor penetrations were being sealed. The licensee stated that the penetrations were resealed to Unit !i2 specifications. This modificat'ion occurred prior to the preparation of the above-referenced procedures., The activity was controlled under a main-tenance work request procedure and documented on lGiR/i5N0485. The li'censee state) construction specifications and prints were utilized as work instructions.

5. Status of Licensee's Efforts re IE Bulletins 75-04 and 75-04A The inspector requested a status report from the licensee regarding IE Bulletins 75-04 and 75-04A. The licensee provided thc inspector with a copy of an April 23, 1975 letter from Milliam J. Cahill, Jr.

(Consolidated Edison Company) to J. P. O'Reilly (U.S.N.R.C.), which indicates that their efforts are expected to be completed by 6/1/75.

XE;I PorQl 12

~

{Jan 75) (Rcv)

Q

~ Uo ST NIJCLEAR REGULATORY CO.'IlfISSXON OFFXCE OF XNSPECTION AND ENFORCEIENT .

REGION I IE Xnspection Report No: Docket No:

Licensee: License No: DPR-61 P.O. Boz 270 Priority.

Hartford Connecticut Category:

Safeguards

'roup:

~ Location.'t" <Il o:. Co Type of Licensee: PWR 575 MV.

Type of Inspection: S ecia1 Announced

>a~ s of Inspection: Ha 6-7, 1975

~

Dates of Previous Inspection. 3 ll 75 - 3 14 75 5 -Zo

~ 0 Reporting Xnspector:

Jacque D rr, Ri.actor Inspector Accompanying Xnspectors:

~ ~

DATE Other Acco...panying Personnel: None I

DATE Revieved By:

~ C .

R. C. Haynes, Senior Reactor Inspector DATE

~C SU!kfARY OF FIBDIii'CS

'nforcement Action A, Item of Noncompliance None B. Deviations None

Licensee's Action on Previousl 'Identified Enforcement Items Not applicable None identified Unusual Occurrences None identified.

'Other Si nificant Findin. s A. Current Findin s

l. 'cce table Areas

a. Correlation Between the Facilit 's Requirements and As-Built Status for Fire Stoos on Electrical Safet -Related Cables and Penetration Seals A visual examination was performed of the installation of fire barriers and compartment boundary seals, and the application of fire-retardant coating, for safety related cables. There is correlation between this construction and the facility's documented requirements. (Details, Paragraph 3.b.)

~3 b, Invokement of Facility Re uirements for Fire Stops on Elec'trical Safet -Related Cab]es and Penetration Seals in l~intenance and Hodification Procedures Flame barriers vere not addressed in maintenance procedures, but more recent modification procedures do specify flame barriers. (Details, Paragraph 4).

2. Unresolved Items None identified B, Status of Previously Re orted Unresolved Items Not inspected

,'>hna ament Interview The inspector held a meeting at the site at the conclusion of the inspection to discuss the inspection findings.

a. Persons Present

~ 3

'Connecticut Yankee Atomic Power V. Hartley, Plant Superintendent J. Ferguson, Staff Engineer Company J. Summa, Associate Engineer, Controls and'nstrumentation

b. Items Discus: d The following items were discussed and the 'inspector's findings were acknowledged by the licensee.

(l) The Pur ose of the Inspection The inspector stated the purpose of the inspection. (Details, Paragraph 2.b.)

(2) Correlation Betwen the Facility's Re uirements and As-Built

Status for Fire Stons on Electrical Safet Related Cables and

'enetration Seals

The inspector performed a visual ev~mination of the safety related cabling boundary seals and compared them to the facility.requirements and found that they conform. (Details, Paragraph 3.b.)

(3) InvoI;emcnt of Facility Requirements for Pire Sto s and Electrical Safety Related C..olcs and Pcnetrations in Maintenance and Modification Procedues The inspector stated that flatne Parriers vere not addressed in

,maintenance procedures but that more recent modification procedures do specify flame barriers. (Details, Paragrah 4.)

DETAILS

1. Persons Contacted

'Connecticut Yankee Atomic Power Com an M. Hartley, Plant Superintendent B. Traggio, Senior Staff Engineer J. Ferguson,.Staff Engineer G. Bouchard, ~sfaintenance Foreman J; Summa, Associated Engineer, Controls and Instrumentation 2.General

a. Plant Status The plant was in power operation during the inspection.

b. ;Pur ose of Ins ection The purpose of this inspection was to examine the documented facility requirements for fire stops on safety-related cables and penetration seals, to visuaj,ly inspect these items for conformance vith the requirements,'o examine the licensee's provisions for invoking the requirements during maintenance and modification work and to determine the status of the licensee's efforts with respect to the actions listed in IE Bulletins 75-04 and 75-04A.

3. 'Correlation Between the Facility's Requirements and As-Built Status for Fire Stops or. Electrical Safet -Related Cables and Penetration Seals

a. Re uirements (1) The'inspector read a letter from the original Architect/

Engineer, Stone and Vebster, dated April 30, 1975, stating there vere no construction specifications prepared for the Connecticuit Yankee plant.

(2) The only specific reference to cable penetrations to be found was on a Stone and liebster drawing number 10899-FE-38A, Note 2, which stated the following:

~ ~

,"Upon .completion of cable installation through floor sleeves, fill voids with a.sealing compound to a depth of not less than two inches, spares to be plugged."

This applies only to the control console penetrations.

There is a detail drawing of a typical penetration con-sisting of a conduit sleeve "with coupling nuts on each end. The assembly is placed with the long axis vertical through'the concrete floor.

(3) Cable flame barr'iers are not addressed in the FSAR.

t (4) There are no requirements'for fire retardant coatings.

,,b. 'Observations The following areas were inspected and the results are as indic'ated:

,(1) Control Room The cables pass through conduit sleeves in the floor of the main control console as described in 3.a. above. The older penetrations were packed with an asbestos fiber material and a binding agent. The more recent sealings had been made with a flamemastic putty. All penetrations in the console were sealed as per drawing 10899-FE-38A.

(2) 'Switch Gear Room This room is located below the control room. 1fost cables from the control console pass directly into this room except for a few which pentrate outside the room and are brought through the wall in 9 cable trays. %%ere these cable trays pass through the wall there are no flame barriers.

The east wall has seven vertical cable trays penetrating the floor with no flame bar"iers.

The cable trays have metal covers installed over their full lengths. This is typical throughout the plant except in several areas where maintenance is in progress.

0 (3) Screen House All cabling in the screen house is in conduit. The motor control centers have large openings through the bottoms to allow entrance of the conduit. These openings are not sealed.

(4) 'Emer enc Diesel Generators.A and B

.,All cable p'enetrations.in to the Emergency Diesel Generator rooms are through the walls. The 4160 volt power cables are

,all in conduit, while the control cabling, transits the wall in conduit sleeves and into cable trays.

(5) Cable Tra Area This area is located below the switch gear room and is approxiamtely 60 ft. by 100 ft. This area is criss-crossed with cable trays and conduits. The cables drop through the switch gear room floor in conduit sleeves.

Not all of the penetrations were accessible but it was noted that 'approxi"... tely 75% of those observed were packed with a Flamemastic type compound. The remaining 25% were also in conduit sleeves but without the packing.

(6) Liaste Gas/Liauid Buildin This is a recently costructed modification (Reference Details, Paragraph 4). The cable penetrations that pass through the walls were of two types, (a) solid conduit, (b) conduit 'sleeves packed with Flamemastic.

(7) Primar Auxilar Buildin Certain areas of this building were inaccessible due to radiation. There are cable trays with covers and where the cabling leaves the trays it transitions to conduit.

The. High and'ow Pressure Safety En]ection pump cables are both made in conduit runs. The Residual Heat Removal pumps have cable tray runs to a wall which then transfer to conduit for " vertical run to the motor.

0 (8) Cable Vault This is adjacent to the Primary containment and is the penetration point for cabling into containment. 'There are five undergound-conduit groups that enter the vault and transfer to cable tr'ays with covers. The vault has a carbon dioxide fire suppression system.

(9) Smoke Detection System I I

. Area smoke detectors were observed in the following areas:

'Sw'itch'gear room, cable tray area,'cable vault and emergency Diesel room.

(10)Acct.dent Prevention annual The plant has a "Accident Prevention Hanual" which outlines the cordon fire safety recommendations to. the employees.

The control of welding and firewatches is addressed in detai.l in the plant Station Order S-A-3, dated 2/12/74 and S-N-212.

4. Invokement of Facility Re uirements for. Fire Stons on Electrical Safet Related Cables and Penetrations in Haintenance and ~fodificstion Procedures Flame barriers are not addressed in r.aintenance procedures but the

'ast major modification procedure, Haste Handling System iiodification, J. 0. 11726.19, does specify zlame barriers through walls and zloors for cable and tray penetrat'ions. The cabling used was specified to be fire resistant.

5. 'tatus of Licensee's Efforts re lE Bulletins 75-04 and 75-04A The licensee stated that there was no additional information, con-cerning the referenced Bulletins 75-04 and 75-04A, available at except that presented in the letter response, dated April 23, 1975.

this'ime

IE:I Form 12 (Zan 75) (Rev) 3

~ Uo S ~ NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEHENT REGION I XE Inspection Report No: 50-317 75-11 Docket No:

Licensee: Baltimore Gas and Electric Com anv License No:

Gas and Electric Buildinv Priority:

Baltimore, Nar land 21203 Category:

Safeguards Group.

Lusby, Maryland (Calvert Cliffs)

I Type of Licensee.. PHR 84 5 ifHe (CE)

'pecial, Announced ates of Inspection: H y Dates of Previous Inspection'. April 14 16 1975 Reporting Inspector: S~s~~

P. . ellogg, Reactor Inspector Accompanying Inspectors:

DATE DATE Other Accompanying Personnel:

DATE Reviewed By: S- ]0-7z

~ )

R. C..lfaynek, Senior Reactor Inspector DATE

0 SUHMARY OF FINDINGS

.Enforcement Action A. Items af Noncom liance None, .

3. Deviations Hone Licensee Action on Previousl Identified Enforcement Items Not Applicable Desi n Chan es None identified Unusual Occurrences None Identified Other Si nificant Findin s A. Current Findin s

1. Acce table Areas

a. Correlation Between the Facility's Requirements and As-Built Status for Fire Sto s on Electrical Safet-Related Cables and Penetration 'Seals A visual examination was performed of the installation of fire barriers and compartment boundary seals, and

~ the application of fire-retardant coating, for safety-related cables. There is correlati'on between this con-struction and the facility' documented requirements in certain areas. (Details, paragraph 3)

b. Invokement of Facility Re uirements for Fire Sto s on Electrical Safety-Related Cables and Penetration Seals in Hain tenance and Hod i f ica tion Procedures 4

An examination was made of the maintenance and modifi-cation procedures for the installation of fire barriers

Q

~ and compartment boundary seals, and the application of fire-retardant coating, for safety-related cables. There is correlation between these procedures and the facility' documented requirements. (Details, Paragraph 4)

2. Unresolved Items

a. Cable pull ropes. (Details, Paragraph 5.a)

b. Shrinkage/settling of Flamemastic 71A. (Details, Para-graph 5.b)

B. Status of Previousl Re orted Unresolved Items Not inspected Mana ement Interview At the'onclusion of the inspection, the inspector held a meeting at the site with the following personnel to discuss the inspection findings:

Baltimore Gas and Electric Comoan Mr. M. Bowman, QA Engineer-Operations Mr. R. Douglass, Chief Engineer Mr. U. Gibson, Supervisor, Operations QA Mr. J. Hoppa, Construction QA Mr. U, Lippold, Nuclear Engineer Mr. L. Russel, Nuclear Plant Engineer-Operations The following items were discussed, and the inspector's findings were acknowledged by the licensee:

A. Pur ose of Ins ection The inspector stated that the purpose of this special, announced

'inspection was to examine the documented facility requirements for fire stops on safety-related cables and penetration seals, to visually inspect these items for conformance with the requirements, to examine the licensee's provisions for invoking the requirements during main-tenance and n'iodifications work and to determine the status of the licensee's efforts with respect to the actions listed in IE Bulletins 75-04 and 75-04A.

B. Current Findinvs: Accc )table Areas

~a e

The inspector stated that his revie~ of the following areas revealed acceptable findings:

1. Correlation Betwr.en the Facilit 's Re uirements and As-Built Status for Fire Stons on Electrical Safet -Related Cables and Penetration Seals A visual examination was performed of the installation of fire barriers and compartment boundary seals, and the application of fire-retardant coating, for safety-related cables. There is correlation between this construction and the,facility's docu- .

mented requirements in certain. areas. (Details, Paragraph 3)

.Z. '.Invokement of Facility 'Re uirements for Fire Stops .on Electrical Safet -Related Cables and Penetration Seals in Haintenance and Hodification Procedures An examination was made of the maintenance and modification procedures for the installation of fire barriers and compartment boundary seals, and the application of fire-retardant coating, for safety-related cables. There is correlation between these procedures and the facility's documented requirements. (Details, Paragraph 4)

C. Unresolved Items The inspect:or stated that the following items were observed and are Considered to be unr'esolved:

1. Cable pull ropes. (Det:ails, Paragraph Sa)

2. Shrinlcage/set tling of Fl>>em<<tic 71A. (Details, Paragraph 5.b)

D. 'tatus of Licensee's Efforts re IE Bulletins 75-04 and 7S-04A The licensee provi'ded the inspector with a status report on his efforts in complying with the requirements of IE Bulletins Nos.

75-04 and 75-04A. (Details, Paragraph 6)

DETAILS

1. Pe'rsons Contacted Baltimore Gas and Electric Com an Mr. J. Basile, Nuclear Plant Engineer-Maintenance Mr. R. Douglass, Chief Engineer Mr. G. Hinton, Construction'QA Mr. J. Hoppa, Construction QA Mr. P. Rizzo, Foreman I&C

2. General

a. Plant Status The plant was operating at 100% power. Portions of the Escala-tion to Power Test Program were being performed during the in-spection.. I

b. 'ur ose of Ins ection The purpose of this inspection was to examine the documented

~

facility requirements for fire stops on safety-related cables and penetration seals, to visually inspect these items for conformance with the requirements, to examine the licensee's provisions for invoking the requirements during, maintenance and modification work and to determine the status of the licensee's efforts with respect to the actions .listed in IE Bulletins 75-04 and 75-04A.

3. Correlation Between the Facilit 's Re uirements and As-Built Status for Fire Sto s on Electrical Safet -Related Cables and Penetration Seals

a. Re uirements ( er the Architect-En ineer's s ecification 6750-E-406 Rev. No. 6)

(1) Floors and Halls Fire Stops on cable trays through electrical blockouts in the floors and wallsconsist of grouting in position after cables and covers are installed. The area around the cables i" then sealed with approximately 3 inches of

Kaowool and a. 3/8 inch coat of Flamemastic 71A on each end of the penetration. On floor penetrations, Pearlite is added r to fill the Vermiculite'or area between the end seals.

Conduits are sealed by grouting in place after installation..

Spare'conduits are plugged on both ends.

(2) Floor of the Control Room

$ Iireways and conduits passing. through the control room floor are sealed by cutting a piece of 1/2 inch Marinite 36A to fit around the.wireways and conduits. The Marinite is then attached to the underside of the floor and covered, with 3/8 inch layer of Flamemastic 71A. The blockout is then filled with Vermiculite. The upper surface is then sealed with a 1/2" piece of Marinite'6A and covered with 3/8 inch of Flamemastic 71A.

The ends of the wireways and conduits in the control room are filled with 1/4 inch of Flamemastic 71A'.

b. Observations All electrical blockouts, with the exception of the Let Down Heat Exchanger Room, due to high radiation levels, were in-spec'ted for compliance with the facility's requirements. All fire stops and seals were in compliance with the facility's requirements with the exception of those listed below:

(1) Component Cooling Heat Exchanger Room, 5 feet elevation cable tray ZB1AA6: no Flamemastic on one end, AlAA33; upper 3 inches of grout'missing.

(2) Passageway outside elevator, 5 feet elevation, cable tray AlAB01: hole through Flamemastic and Kaowool on one end.

(3) East Piping Penetration Room, 5.feet elevation; cable tray ZB1AC02: no Flamemastic or Kaowool on one end.

(4) 4160 Switchgear Room, 27 feet elevation, cable tray A1AB80: small hole through Flamemastic.

(5) Cable Spreading Room, 27 feet elevation: one 4 inch conduit not plugged on lower end.

~k

~ t (6) Computer Room, 45 feet elevation: conduits under false floor not sealed 'with Flamemastic.

/

(7) West wall of Turbine Buildin, 36 feet elevation: cable trays AITB93, AITB94: no Flamamastic on bottom of trays around cables, insufficient grouting around trays or evidenced by air flow being present.

The licensee corrected the above items during this inspection.

'4. Invokement of Facilit Re uiremants for Fire Stops on Electrical Safet -Related Cables and Penetration Seals in Haintenan'ca and Modification Procedures The licensee currently subcontracts all maintenance and modifica-tions to electrical cables and penetration seals for Units 1 and 2 to the Architect-Engineer. The modifica'tions are then completed

,in accordance with the requirements of tha'A-E's specification (6750-E-.406 Revision 6). The modifications were inspected to verify the fir'e stops and penetration seals were installed in accordance with these specifications. No descrapancies were noted.

The licensee is writing a maintenance procedure to be utilized in modifications involving remov .1 and replacement of fire stops and penetration seals which will include the requirements of the A-E specifications and provisions of ANSI 45.2.4. This procedure will be utilized when the licensee takes over maintenance in this area.

5. Unresolved Items

a. Cable ull ro es During this inspection it was noted that many fire stops had cable pull ropes (hemp) passing through the fire stops.

Tha presence of these ropes was not noted in the specifica-tions and the licensee was asked to evaluate their presence and its effect upon the function of tha fire stop.

The licensee, at tha exit meeting, indicated the cable pull ropes would be removed and the fire stops repaired; or, where it was desirable to have tha ropes left in place, they would be cut back close to tha fire stop and their ends would be covered with Flamemastic 71A.

g ~

This item is considered to be unresolved pending completion of corrective action by the licensee an NRC inspector.

and subsequent review by

~ g ~ ~

I

b. Shrinka e/settlin of Flamemastic 71A During this inspection it was noted that the Flamemastic 71A had pulled away from many .tray covers, leaving a space of about 1/4 inch across the top of the stop. This space was apparently formed by the Flamemastic 71A settling or shrinking du'ring the drying process.

The licensee was asked to 'evaluate the presence of this space on the effectiveness of the fire stop and to take appropriate action based upon this evaluation.

This item is unresolved pending completion of the licensee's evaluation and possible corrective actions, and their subse-quent review by an HRC inspector,

6. Sta'tus of Licensee's Efforts re IE Bulletins 75-04 and 75-04A

a. The licensee's response to IE Bulletin 75-04 indicated that no corrective actions were necessary.

b. The licensee's response to IE Bulletin 75-04A indicated that review of items 2, 3, and 4 was in progress and would be completed by 23 May 1975. During this inspection it was ascertained that an administrative notice was being prepared and existed in rough draft which will address items 3a through d, and f. The licensee indicated the installed'ommunication equipment was satisfactory with respect to item 3e. The licensee indicated that their policy with respect to item 2 not require any change, but would require some formaliza-

'ould tion. Initial review of emergency procedures with respect to item 4 has been completed, and final review is in progress.

0 XE:I Form 12 (Jan 75) (Rev)

Ue S NUCLE:"iR REGULATORY COMMISSION OFFICE OF INSPECTION 4.ND EiNFORCBfENT REGION I XE Inspection Report No: 50-244 75-07 Docket No. 50-244 iLicensee: Rochester Gas and Electric Corporation License No: DPR-18 89 East Avenue Priority:

Rochester, New York 14649 Category: C Safeguards Group:

lf Location: Ontario, New York (Ginna 1)

Tvpe'of Licensee: PER 490 M!<e (l>)

Type of Inspection: Special, Announced

) APril ates of Inspection:

~

Dates of Previous Inspection'. March 31 to April 2 and April 24-25, 1975 Reporting Xnspector: i) r.

JA'qu e Durr, Reactor Inspector Acc'ompanying Inspectors: None DATE DATE DATE Other Accompanying Personnel:

DATE Reviewed By:

R. C. }l ynes, Senior Reactor Inspector DATE

h I

3 SEQfARY OF FINDINGS Enforcement Action A. ,Items of Noncom liance None B. Deviations Hone Licensee Action on Previousl Identified Enforcement Items Not applicable Hone identified Unusual Occurrences Hone Other Si nificant Findinj,s A. Current Findin~s

1. Acce table Areas Hot applicable

2. Unresolved Items A visual examination was performed of the installation of fire barriers and compartment boundary seals, and the application of fire-retardant coating, for safety-related cables.

a. Correlation Between the Facility's Re uirements and As-Built Status for Fire Stons on Electrical Safet -Related

'Cables and Penetration Seals The inspector found cabling entering and leaving penetrations in Class I structures without flame barrier material, in apparent contradiction to the FSAR. (Details, Paragraph 3,b(10) )

0

/

b. Invokemcnt of Facility Re uirements =or Fire,Sto s on Electrical Safety-Related Cables and Penetration Seals in Maintenance and Hodification Procedures The inspector did not find any specific requirements for the maintenance of flame barriers during routine maintenance and no evidence that it is addressed in modification instructions. (Details, Paragraph 4)

B..Status of Previously Re orted Unresolved Items Not inspected.

Mana ement "Interview At the conclusion of 'the inspection, the inspector held a meeting at the site with the following personnel to discuss the inspection findings.

Rochester Gas and Electric Cor oration Mr. C. Anderson, Quality Assurance Coordinator Mr. J. Arthur, Chief Engineer Mr. De Herett, Supervisor, Chemistry and Health Physics Hr., L. Lang, Assistant Superintendent Mr. T. Heyer, Cadet Nuclear Engineer-Mr. C. Plat t, Superintendent Mr. B. Snow, Operations Engineer Mr. E. Smith, Fire Protection Engineer Mr. R. Smit:h, Chief Mechanical Engineer Mr. L. Uhite, Vice President, Electric and Steam Production The following items were discussed, and the inspector's findings were acknowledged by the licensee.

A. Pur ose of Ins ection The inspector stated that: the purpose of this special, announced inspection was to examine the document:ed facility requirement:s for fire stops on safety-related cables and penetzation seals, t:o vis-ually inspect these items for conformance with. thc requirements, to examine the licensee's provisions for invoking the requirements during maintenance and modification work and to determine the sta-tus of the licensee's effort:s with respect to the actions listed.

in IE Bulletins 75-04 and 75-04A.

B. Unre olved Items

'1. Correlation Between the Facility's Re uirements and As-Built

'Status for Fire Sto s on Electrical Safet -Related Cables and Penetration Seals A.visual examination was performed of the installation of fire barriers and compartment boundary seals, and the application of fire-retardant coating, for safety-related cables.

4 The j.nspector found cabl'ng entering and leaving penetrations in Class I structures without flame barrier material, in ap-parent contradiction to the FSAR. (Details, Paragraph 3.b.(10))

2. Invokemer.t of Facilit Re uirements for Fire Stops on Electrical Safet -Related Cables and Penetration Seals in Haintenance and

?1odi*fication Procedures N

The inspector did not find any specific requirements ".or the maintenance of flanie barriers during routine maintenance and no evidence that it is addressed in modification instructions.

(Details, Paragraph 4)

Subse uent Tele hone Conversation (Ha 2 1975)

Persons Contacted Rochester Gas and Electric Cornoration Mr. J. Arthur, Chief Engineer Dr. R..Hecredy, Advisor'.

Mr. B. Smith, Chief Hechanical Engineer'r.

L. hite, Vice President, L Electric and Steam Pro'duction Items Discussed

. The inspector inquired of the licensee how he would review the lack of flame'arrier material and its apparent conflict with the FSAR. (It poses a possible noncompliance with 10 CFR 50.59 as an unreviewed safety question.)

The licensee stated that he would review all unsealed Class I structure cable penetrations as per 10 CFR 50.59 and disposition each case prior to plant startup by installing .flame barx'iex material or by some alter-nate method which, after a safety analysis, would show there were no unreviewcd safety questions.

4 DETAILS'

't ~

1. Persons Contacted ~

Gas and Electric Cor'ochester oration Mr. C. Anderson, Qualit.y Assurance Coordinator Mr. J. Arthur, Chief Engineer Mr. L. Lang, Assistant. Superintendent Mr. T. Meyer, Cadet Nuclear Engineer

,Hr. J. Paris, Instrument Repair Foreman Mr. C. Platt, Plant Superintendent Mr. J. Scheetz, Manager, Electrical Engineering Mr. B. Snow, Operations Engineer Mr. B. Smith, Chief Mechanical Engineer Mr. E. Smith, Fire Protection Engineer Mr.. L. Lihite, Vice President, Electric and'Steam Production

2. General

a. .Plant Status The plant was in a refueling/maintenance shutdown during the inspection.

b. Pur ose of Inspection The purpose. of this inspection was to examine the document'ed facility requirements for fire stops on safety-related cables and penetration seals, to visually inspect these items for conformance with the requirements, to examine the licensee's provisions for invoking the requirements during maintenance and modification work and to determine the status of the li-censee's efforts w'h respect to the actions listed in IE Bulletins 75-04 and 75-04A.

c. Entrance Interview The inspector held an entrance interview with the following licensee personnel: C. Platt, 3. Smith, H. Smith, B. Snow, J. Scheetz, and L. Lang.

The inspector stated the purpose of the inspection (reference Paragraph 2.b above) and asked for all information regarding, fire stops (flame. barrier) requirements for cabling at Ginna Unit No. l.

The licensee stated that the y had determined that th ere were requirements for fire stops for cabling at Ginna Unit No.

'o

l. s

/)

3. Correlation Between the Facilit 's Re uirements and As-Built Status for Fire Sto s on Electrical Safet Related Cables and Penetration Seals 1

a. Re uirements I

The inspector requested the original installation specifica-tions for cabling for the, construction of the plant. Th plant personnel produced, "Technical Specification, Electrical Work, Unit //1 R. E. Ginna Nuclear Pot;er Plant, Rochester Gas and Electric Corporation, SP5451," dated October 20, 1967 for the inspector's review. The inspector found in Paragraph 4.26.17, "Installation of cables hhere entrance is made by the constructor, into pressurized rooms or into Class I struc-tures, for conduit or cables...these openings shall be suit-ably sealed...hhere cables extend through floors a fire stop of fiberglass matting...shall be installed in the trays. This also applies to all circuits into the main control panel."

The inspector found the following statement in Paragraph 8.2.2, Station Distribution System, General Cable Considera-tions, Ginna Unit No. 1, FSAR, Page 8.26C, dated January 1969:.

"Fire barriers are used at cable trays and cable runs where they enter or leave a Class I area. There will be fire barriers where the cable trays enter the relay room, auxiliary building, and where vertical trays pass through floor openings."

Class I structures as defined by the Ginna, FSAR include the following areas:

(1) Containment.*

(2) Intermediate Building.

(3) Auxiliary Building.

(4) Control Room.

(5) Diesel Generator Room.

(6) Screen llouse.

(7) Spent: Fuel Pit (8) Fuel Transfer Tube.*

(9) Containment Crane.*

• Outside the scope of the inspection.

There are no p lant re uirements for fire-retardant coatings The plant does have specifications for the procurement of fire-resistant cable.

b. Observations The inspector observed the following areas to the requirements of Paragraph 3.a of this report with the conditions found as noted.

(1) cantrol Room (

The penetrations go through the floor to the relay room via short, open sections of conduit set in the concrete.

The cables enter the conduits and the void spaces around the cables are packed with a fiberglass type material.

All instrument and control cabinets were inspected and several were found with the packing material lying be-side the penetration. There was a considerable amount of maintenance being performed to account for some of them not being packed.

A cable tray passing through the north wall was found not to have a flame barrier. The majority of the cables come from the control room, which is directly above, and the penetrations were inspected from there.

(3) Emer enc Hatter. Rooms 1A and 1H Cable penetrations through the east and west walls of Battery Room lA were found not to have flame barriers.

(4) Control Room Air Handlin Room This room is directly below the relay room and carries

~

a large number of cables to the cable tunnel from the relay room. This is a vertical penetration, with evi-dence of work in progress, which accounts for the flame barrier being disturbed.

(5) Cable Tunnel The cable tunnel is "T" shaped and connects the inter-mediate building, auxiliary building, and the relay

4

~ <<7m room through the control room air handling room end of the tunnel that enters the CRAH is protected (CRAII).'he by a'lame barrier but the intermediate and auxiliary buildings (which are epsentially directly connected, as evidenced by the considerable air flow through the tunnel) are not protected by flame barriers at their entrances to the cable tunnel. This tunnel is protected by a water sprinkler and smoke detection system.

(6) Intermediate Buildin The intermediate building is divided into "controlled" .

and "uncontrolled" sections. There is a vertical cable tray that passes through several floors by the elevator and has no flame barrier material installed. There is a pene'tration through the wall into the water treatment room with no flame barrier. Both of these are located in the "uncontrolled" section.

(7) Diesel Generator Rooms (DGR)

(a) DGR "A" There is a room directly beneath the DGR .

through which the generator cables and pass. The cables penetrate the ceiling of control'ables this room (floor of DGR). The cables coming from the motor control cen'ter "1II" have flame barrier material, while those of the relay cabinet do not.

(b) DGR "B" The same arrangement of rooms and cables

'xist for DGR "B" and none of these had flame bar-rier material.

(8) Screen House Cabling penetrates the southeast wall by the stairs and contains no flame barrier material. Several electrical cabinets are located within'he screen house but were inaccessible for inspection. Safeguard cabinets 17 and 18 were inspected and found to have no flame barrier material where the cabling penetrates the floor.

(9) S ent I'uel Pit (SFP)

The access door from the intermediate building to the SFP has a cable tray above the door'without a flame barrier.

(10) Auxiliar 'Buildin Xn the auxiliary building there are cable penetrations leaving through the east- wall at the intermediate level with no flame barrier material.

There are several motor control centers and assorted electrical panels in the auxiliary building which were inaccessible for'nspection. Those that were accessible contained no flame barrier material for cables passing through the floors.

The lack of flame barrier material in the relay room, the cable tunnel entering the. auxiliary bu'lding, the intermediate building, the screen house, the spent fuel pit, and the auxil-iary building is apparently contrary to the FSAR commitment as stated in Paragraph '3 above. The inspector could not as-

'certain if this lack of flame barrier material in the penetra-tions'esulted from modifications in which flame barrier material was deemed to be not safety-related and, therefore, deleted.

This item is considered unresolved, pending t'e completion of the licensee's review action per 10 CFR 50.59 and a subsequent review by an hRC inspector of the licensee's review and any modification action.

4. Xnvokement of Facility Requirements for Fire Stops on Electrical Safet -Related Cables and Penetration Seals in Naintena'nce and

>fodification Procedures The inspector did not find any specific requirements. for the main-tenance of flame barriers during routine maintenance and no evi-dence that it is addressed in modification instructions.

This item is considered unresolved, pending the completion of the licensee's review action per 10 CFR 50.59 and a subsequent review by an NRC inspector of the licensee's review and an; additional procedural documentation that he prepares relative to maintenance and modification of safety-related cable penetration seals.

5.'tatus of Licensee's Efforts re IE Bulletins 75-Oli and 75-04A The licensee indicated that approximately 75% of the procedures review required by the bulletins were completed at this time.

f;I Form 12 an 75) (Re.v)-

Uo,Se NUCLEAR REGULATORY COlQfXSSXON C

OPFXCH OP 'XNSPECTIO 1 AND ENFORCEMENT REGXON I Inspection Report No: 50-333175-07 . Docket No: 50-333 I

icensee

Niagara Hohawk Power Cor oration License'o: DPR-59

. 300 Erie Boulevard J.'est Priority:

Syracuse, New York 13202 Category. B Safeguards

. Group:

ca tion.'ames A.'it,".Patrick Nuclear Por;er Pl~r Scriha, ~ New York ype of Licensee: Bh'R'GE) .2436 1fh'

'e of Inspectio:: 'pecial, Announced m of Inspection. 'April 29 Hay 2, 1075 ates of Previous Inspection: April 16-1S, 1975 epor ting Xnspector: J /+r >c J. T. Shedlosgk , Reactor Xnspector ccompanying Xnspect; rs:

DATE DATE

..; Other Accompanying Personnel

'eviewed By'. 5. r6 R. C es, 'enior Reactor Inspector D TE 6

SENARY OF FINDINGS Enforcement Action A, Items of Noncompliance Infraction

'Correlation between the Facility's Requirements and As-Huis.t

Status for Fire Stops on Electrical Safet -Related Cables and Penetration Seals.

Contrary to the requirements of 10 CFR 50.59, the Safety Analysis Report Section 8.5.~i.2 and J. A. FitzPatrick Installation Instruction for RacewaysSection IV, F.3 changes have been made in the facility safety related seals from what was described in the Safety Analysis' Report. The licensee had not performed a safety evaluation which provided the basis for the determina-tion that the changes did not involve an unreviewed safety question. (Details, Paragraph 3.b .)

B. Devia t ion s None Licensee Action, on Previousl Identified Enforcement Items Not applicable None identified Unusual Occurrences None identified 0

Other Si,nif icant Findings A. Current Findin s

1. Accc table Areas Not applicable

~3 2~ Unresolved Items

a. Invokement of Facilit Requirements for Fixe Sto s on Electrical Safet -Related Cables and Penetration Seals in Haintenance II h

Procedures and.'odification Facility maintenance and modification procedures do not specifically reference the sealing of penetrations. Vork to date has been done using construction specifications.

(Details, Paragraph 4)

B. Status of Previousl Renorted Unresolved Items Hot inspected

'khna ement Interviev At the conclusion of the inspection, the inspector held a meeting at the site vith the folloving personnel to discuss the inspection findings:

Nia,ara Ifoha~"k Pover Corporation

&. T. J. Perkins, Acting General Superintendent Hr R U Smith, Plant Supex intendent 1

~

Hz. R. J. Pastexnak, Operations Supervisor Hr.'. H. Kerfien, Assistant Quality Control Supervisor Pover Authoritv of the State of Yev York Hz. E. A. Abbott, Acting Resident Engineer Eh . H. C. Cosgrove, Site Quality Assurance Engineer Nr. H. Rickles, Electrical Engineer-Quality Assurance Stone and LJebster Enzineerinp Cor oration Hr. A. B, Banko, Electrical Engineer kh. P. C. Kelleher, Senior Quality Control Engineer kh. H. Astle, Quality Control Engineer The folloving items vere discussed, and the inspector's findings vere acknovledged by the. licensee:

"S A. Pur ose of the Ins ection

. The inspec'tor stated that the purpose of this special, announced ins P ection was to examine the documented facility requirements.

for fire stops on safety-related cables and penetration seals, to visually inspect these items'or conformance with the require-ments, to examine the lice lsee's provisions for invoking the requirements during maintenance and modification work and to determine the status of the licnesee's efforts with respect to the actions listed in IE Bulletins 75-04 and 75-04A.

B. Items of Noncompliance The inspector stated that he found the following item of non-compliance:

Infraction Correlation Between the Facility's Requirements and As-Built Status

'for 'Fire Stops on Electrical Safet -Related Cables and Penetration Seals Contrary to the requirements of 10 CFR 50.59, the Safety Analysis Report Section 8.5.4.2 and J. A. FitzPatrick Installation Instructions for Pacew ys Section O'.F.3 changes have been made in the facility safety rel,.ted seals from what wa described in the Safety Analysis Report. The licensee had not performed a safety evaluation which provided t: he basis for the determination that tne changes did not involve an unreviewed safety question. (Details, Paragraph 3b.)

C. Current Findin s: Unresolved It:cm The inspector stated that the following item was observed. and is considered to be unresolved:

Invokement of Facility Requirements for Fire Sto s on Electrical Safet Related Cables and Penetration Seals in Haintenance and

'Hodification Procedures.

Facility maintenance and modification procedures do not specifi-cally reference the. scaling of penetrations. Liork.to date has been done using construction specifications. (Details, Paragraph 4 .)

v Se ~ ea 'I ~ e fo

~" D. Status of Licensee's Efforts re IH Bulletins 75-04 and 75-04A The licensee provided the inspector with a status report on his efforts in complying with the requirements of IE Bulletins Nos.

75-04 and 75-04A. (Details, Paragr'aph 5.)

! ~

~ !'

g l! ~ Y ~ +r ~ ~

~k ~ 4

DETAILS

l. Persons Contacted Nia ara Mohawk Power Cor oration Mr. R. H. Smith, Plant Superintendent Mr. R. J. Pasternak, Operations Supervisor Mr. J. H. Kerfien, Assistant Quality Control Supervisor

'Power Authorit of the State of New. York Mr. E. A. Abbott, Acting Resident Engineer Mr. M. C. Cosgrove, Site Quality Assurance Engineer lA'r. H. Rickles, Electrical Engineer-Quality Assurance

'Stone'and 4'ebster En ineerin Corporation Mr. H. Astle, Quality Control Engineer Mr. G. B. Banko, Electrical Engineer Mr. A. R. FitzPatrick, Electrical Engineer Mr. P, C. Kelleher, Senior Quality Contiol Engineer Mr, J, M. Lilly, Electrical Engineer Mr. J. Ronco, Construction Supervisor, Electrical Mr. Sanborn, Advisory Operations

2. General

a. Plant Status The plant was shut down for a maintenance outage. Reactor startup is pending the completion of a special.startup test program of the emergency diesel generator.

b. Pur ose of Xns ection The purpose of this inspection was to examine the documented facility requirements for fire stops on safety-related cables and penetration seals, to visually isnpect these items for conformance with the requirements, to examine the licensee's provisions for invoking the requirements durin'g maintenance and modification work and to determine .the status of the licensee's efforts with respect to the actions list in IE Bulletins 75-05 and 75-04A.

0 3, Correl" tion Between the Facilit 's Rc uiremcnt and As-Built Status for Fire Sto' on Electrical Safet -Related Cables and Penetration Saals.

Final Safety Analysis Report, Section 8.5 .4 .2 "Cables and Raceways," states in part: "Fire Stoos Fire stops are provided for cabling at walls, partitions and floors separating areas."

(2) 'Installation Instructions The installation instructions for raceways dated September 20, 3.971 and revised through September 22, 1972,Section I "General," states "This document covers the procedures, instxuctions and documents to be used and followed for installation of all cables.Section IV. F.3', "Protection

. of cables" states, in part: "After completion of the cabling system, all sleeves shall be sealed. If sleeves are unused, metal plugs shall be .used; if sleeves carry cables, they shall be packed with an approved flameproof material to provide an Adequate fire stop."

~ 3 (3) TllX' (J. 'Vainrib, Project Hanager, Stone and 4'ebster Engineering Corp. (SPEC),

Goodman, and'. Feldtmose, Chief Engineer, (Sl EC) to Construction Nanager, (SVEC); '~lfethods Used for Installation of Foam Sealant in Electxical Slee'ves,"

dated 12/19/73 and "Sealing of Electrical Sleeves and conduits for Reactor Building Pressurization" dated 1/18/74).

These teletyped instructions directed the sealing of reactor building penetrations with foam sealant. The type of foam sealant is not referenced. Sleeves to be filled are re-ferenced by drawing and detail. 'he foam sealant is to be applie'd and a sleeve filled to within two inches of the end of the sleeve. Sleeves tied to conduit are to be filled from the open side or by slipping back the conduit on one side.

Sealing other than the reactor building penetrations is not referenced. This document did not tully implement the re-quirements of paragraphs a (1) and (2) above in that it did not contain detailed installation instructions or cover all penetrations.

(4) Procuremcnt S ecifhcations (a) Cable

'The following specifications were reviewed. The insulatj.on, jacket, fillcrs and binding tape materials are as indicated. Required shop tests on each reel are stated:

'APO 76-600 volt ower cable Insulation characteristics: Cross-linked polyethylene Jacket: Neoprene Fillers: Non-hygroscopic self-extinguishing Binding Tape'. Neoprene filled cotton self-extinguishing Shop tests include a horizontal flame test.

APO 7D 500 volt ower cable Insulation characteristics: Cross-linked polyethylene Binding Tape: Neoprene filled cotton tape flame-resistant Shop tests include a horizontal flame test.

'APO'883 600-1000 volt control cable Insulation characteristics: Cross-linked polyethylene flame retardant Jacket: Neoprene flame retardant Shop tests include:

Individual conductors pass a vertical flame test in accordance with AS%1 D2633 completed cable pass a cable tray fire propagation test described in AP0-88B.

APO 88C 600-1000 volt cable Insulation characteristics: Cross-linked polyethylene flame resistance, pass ASTli D-2633 Jacket: Neoprene, ASTH D-752 flame resistance, pass 1PCEA vertical flame test Fillers: Neoprene flame resistance, pass 1PCL'A vertical flame test Binding Tape: Mylar, Asbestos Tape

jhow

(

(

Shop 'tests include:

A vertical flame test in accordance with ASTH D-2633. Completed Cable pass a cable tray fire propagation test described in APQ-88C.

APO-88D - 1000 volt shielded control cable Insulation characteristics: Cross-linked polyethylene flame resistant Jacket: Neoprene flame resistant Fillers: Neoprene flame resistant Binding Ta p e: Glass and or Asbestos Non-buring Shop tests include:

A vertical flame test in accordance with ASTH D-2633. Completed cable pass a cable tray fire propagation test described in APO 8SD.

APO-89 instrument cable I

Insultation characteristics" Cross-linked polyethylene flame resistant Jacket: Neoprene flame resistant Fillers: Neoprene flame resistant Binding Tape: Glass and or Asbestos Non-burning Shop tests include:

A vertical flame test in accordance with AS'-2633. Complete cable pass a cable tray fire propagation test described in APO-89

'APO-101 snecial instrument cable Insulation characteristics: Alkane-Inide Polymer and cross linked radiation resistant poloyolefin or Razolin F or Flamtrol Jacket: Flame retardant, nor corrosive cross-linked poloyolcfin or Radiation Cross linked Flamtrol

Shop tests include:

A vertical flame tests in accordance with 1PCEA S-19-81, paragraph '6.19.6. A cable tray fire propagation test described in AP0-101.

APO 148 Coaxial C ble I

l Xnsulation 'characteristics: Payolin F Jacket: Fla'mtrol Shop t'.ests include:

A vertical flame test in accordance with 1PCEA S-19-81, paragraph 16.19.6.

(b) Foam sealant APO F 14345 Urethane foam.

High compressive foam, self extinguishing in accordance with AS'692-59T.

The licensee has quali ied this foam to act as a fire barrier by testing in accordance with XEEE 383.

b. Observations (1) Areas examined

'eactor Buildin (300'levation)

(344'levation)

(326'levation)

(300'levation)

(300'levation) recirculation HG set room (272'levation)

Administration Buildine (300'levation) Control room air conditioning equipment room, (300'levation) Control room, (284'levation) Relay Room, (286'levation) Cable tunnels (272'levation) Cable room (272'levation) Battery rooms,

Turbine Building (272'levation) Electrical Switchgear rooms (258'levation) Cable Tunnels Screenvell Pun@house

.(260'levation) Emergency Service vater Pump rooms Emer enc Diesel Generator Buildin (272'levation)

(2) ~Findin s

a. The inspector found that penetrations through floors within the xeactor building were not sealed.

(344'levation.'0 penetiations)

(326'levation: 22 penetxations)

(272'levation: 2 penetrations)

b. The inspector found the pull. rope in two sealed conduit openings into the cable tunnel (Administration building, 284'levation).

c. The inspector found that penetrations through the valls of the battery rooms vere not sealed. These carried safety related cabling. (Administration building, 272.'levation 27 penetrations.)

d. The inspector found that penetrations through the walls and ceiling of cable tunnels carrying safety related cabling vere not sealed. These penetrations vere between the cable tunnel and the emergency service water rooms, the emergency diesel generator rooms, the electrical svitchgear rooms and the other cable tunnel. (Turbine Building, 258'levation: 361 penetrations.)

The licensee had not performed a safety evaluation which provided a

- basis for determining that these changes from the FSAR requirements did not involve an unrevieved safety question.. The inspector then cited the licensee for an infraction of 10 CFR 50,59, which states, in part,, ~ ~

"The holder. of a license ... vho desires ... to make a change in the facility ... described in the safety analysis report ... which involve an unrevieved safety question or a change in tcchnical specifications, shall submit an application for amendment of his license pursuant to para. 50.90."

4, Invokemcnt of Facility Re uirements for Eire Sto s on Electrical Sa'fct -Related Cables and -penetration Seals in Maintenance and Modification Procedures.

The licensee has no mainte. ance or modification procedures relating to. penetration seals. The licensee stated that since construction forces are on site any maintenance or modifications would be done in accordance with the construction installation procedures. This item is considered unresolved pending NRC review, of documented site instructions which direct the use of construction installation procedures for, penetration maintenance =and modifications .

5. Status of I.icensee's Efforts re EE Bulletins 75-04 and 75-04A The licensee has responded to Bulletin 75-04. He has also committed to developing procedures for leak testing penetrations. Tn the response to bulletin 74-04 the licensee stated that the review required by Bulletin 75-04A would be completed by ofay 19, 1975.

f 0

XE:X~Foim 12 (Jan 75) (Rev)

Us S ~ NUCLEiK REGULATORY COOMISSION OFFICE OF INSPECTION AND ENFORCPlENT li REGION I I

50-277 ZE Inspection Report No: 50-277/75-08 and 50-278/75-11 Docket No Licensee: Philadelnbia Electric Comnanv License No:

'301 Market Street Priority:

Philad elphia, P enn sylvan ia 19101 Category:

Safeguards Group:.

Location.'each Bottom 2 & 3. Delta Pennsvlvania Type of Licensee: B':.'R 1065 M e (GE

, Type t of Inspection. S ecial, c Announced axes of Inspection: ADril 25, 30 Hav 2, 1975 Dates of Previous Inspection: April 16-18, 1975 I

gc; l Reporting Inspector:

M. )i. Baunack, Reactor Inspector DATE Accompanying Inspectors: ~/kr~ J<l/ M< 4r 5 //7W (April 25, 1975) L. f. Gage, J. P. Durr, DA'TE

"~+///I G. Napuda and k. E. Plumlee DATE DATE Other Accompanying Personnel: None DATE Reviewed By: Ju. f- I ~s>DATE R. C. llayncs, Sf:oioi" Reactor Iospcctor

~3 SR9fARY OP FINDINGS Enforcement Action A. Items of Noncomnliance None B". Deviat ions None Licensee Action on Previously Identified Enforcement Items Not applicable t

None identified Unusual Occurrences None id ent ified Other Si.nificant 'Findines A. Current Find in s

1. Acceptable Areas'..

Correlation Between the Facility's Renuirements and As-Built Status for 1'ire Stops on Elrctrical Safetv-Re1ated Cables and Penetration Seals A visual examination was performed of the installation of. fire barriers and compartment boundary seals, and the application of fire-retardant coating, for safety-related cables. There is correlation between this con-struction and the facility's documented requirements.

(Detaill, Paragraph 3)

~ ge

b. Involvement oF Facility Rcnuircmcnts for Fire r

Stons nn Elect",.ical Sat etv-Related Cable., and Penetration Seals if in Hain'tcnance;lnd Nod ication PI occdul c No maintenance or modifications have been necessary which disturbed fire s'tops or penetration.seals and the licensee has not had to invoke this requirement.

.(Details, Paragraph 4) ~,i

2. Un'r.'esolvcd Itcms-None e

,B. Status of Previously Renorted Unresolved Items Not inspected Hang cment Interview A management interview was conducted on Hay 2, 1975 with the following personnel to discuss the .inspection findings:

~Philadel hia Elecccic Coccaav Hr. ll. T. Ullrich, Station Su perintendcnt Hr. R. S. Pleishmann, Assistant Station Superintendent

~

Hr. J. E. hinzenried, Engineer, Station Economy Hr. R. Orndorff, Electrical Construction Foreman Hr. J. Marnock, Electrical Hechanic Items discussed are sumnarized below:

A. Pur ose of'the Ins ection The inspector stated that the purpose of this special, announced inspection was to examine the documented facility requirements for fire stops on safety-relat ed cables and penetration seals, to vis-ually inspect these items for conformance with the requirements, to examine thc licensee's provisions for invoking the requirements during maintenance and mod ification work and to determine the sta-tus of the licensee's effo rts with respect to the actions listed in IE Bulletins 75-04 and 75-04A.

B. Current Findings: hccen: able Areas .

The inspector stated that his review of the following areas re-vealed acceptable findings:

l.- Correlation Between the Facility' Reouirement s and hs-Built Status for Pire Stons on Electrical Safety-Related Cables and Penetration Seals A visual examina'tion was performed of the installation of fire barriers and compartment boundary s'eal's, and the appli-cation of fire-retardant coating, for. safety-related cables.

There is correlation between this construction. and the facil-i.ty's documented requirements. (Details, Paragraph 3)

2. Invokement of Facility Reouircments for, Fire Stops on Electrical Safety-Related Cables and Penetration Seals

.in Haintenance and Hodification Procedures No,maintenance or modifications have been necessary which disturbed fire stops or. penetration seals and the licensee has not had to invoke this requirement. (Details, Para-graph 4)

':3

~ C. Status of l.icensee's 75-OAA The Ffforts Re,ardinc IE Bulletins 75-04 and licensee provided the inspector with a status report .on his efforts in complying with the requirements of IE Bulletin Nos.

75-04 and 75-04A. (Details, Paragraph 5)

k Q DETAILS

1. Persons Contacted Mr. ti'. T. Ullrich, Station Superintendent Mr. R. S. Fleishmann, Assist:ant Station Superintendent Mr; R. Orndorff, Electrical Construction Foreman Mr. J. !larnock, Fd.ectrical Mechanic Mr. J. Kalloz, Field Engineer, Electrical Engineering 2, General

a. Plant Status Both units operating at power.

b. Pur ose of the Insnection I

The purpose of this inspection was to examine the documented

=facility requirements for fire stops on safety-related cables and penetration seals, to visually inspect these items ior.

conformance with the requirements, to ex.mine the for invoking thc requirements during maintenance licensee'rovisions and modification work and to determine the status of the licensee's efforts with respect to the actions listed in IE Bulletins 75-04 and 75-04A.

To determine the woxk effort involved in performing this in-wpection, a'meeting was held with the licensee on April 25, 1975, to review fire stop and penetration seal specifications and to physically examine the applica tion of fire stops. At t'e conclusion of the meeting the licensee was informed that a detailed inspection was scheduled for the following week.

3. ~ Correlation Between the Facility's Requirements and As-Built Status for Fire 8~to s on Electrical Safety-Related Cables and Penetration Seals

a. ~Re uirewei.t:8

'Zhe licensee's construction specifications relating to fire stops and penetration seals fox safety-related cables wexe reviewed in detail. The following are the principle require-ments which relate to fire stops and penetration seals:

Openings for cables entering control equipment, switch-gear, load centers, motor control .centers from cable tray systems located above or below the equipment shall be'effectively sealed against dust, moisture and fumes, after cable pulling operations have been completed.

(2) .All conduits and trays penetrating walls and floors entering thc Class I structures below elevation'3S'-

0" except Emergency S~iitchgear Room drea below eleva-tion 135'-0", mast be sealed watertight at the structure wall. Class I structures include Reactor Building for Units 2 and 3, Pwdwaste Building, Diesel Building, Emergency Equipment Room of Pump Structure for Units 2 and 3 and Emergency Switchgear Room in Turbine Building for Units 2 and 3.

(3) All tray penetrations in ceilings, floors, and walls shall be provided with fire barriers (shops).

Fire barriers (stop ) shall be installed in vertical trays. The distance between barriers shall not exceed 20 feet.

All conduits passing through the Reactor Building inter-ior walls shal3. be sealed watertight if below elevation ill'-0". Tray runs will not penetrate walls below 111'-0".

b. Observ..tions: Seals The following are the primarily used fire stop and penetra-

.tion seals in the areas listed:

Conduit and cable tray penetrations through any wall or floor which Eorms a part of the boundaries of the Sec-ondary Containment employ one of the following:

Flamemastic and marinite board on each ide of penetra-tions with high density polyurethane foam between, or concrete.

(2) Cable penetrations into Contxol Room Cabinets Concrete or Grout and Kaowool.

(3) Penetration through walls, floors or ceilings, includ-ing cable spreatling room.

Harinite board sprayed with flamcma tic.

c; Observations: l1aterials The following are the principle materials specified for use in fire stops and penctrations seals.

(1) Harinite board 36 or 65, 1/2 inch thick. (Hfg.

fynville) by'ohns-1 (2) Flamemastic 71A mastic.

(3) Cellular concrete.

(4) Yuovool Inorganic thermal insulating wool. (Hfg. by 3abcoc1c and Milcox)

(5) Polyurethane foam (Insta-Foam 120).

Note: Foam not visable in penetrations - purchase orders for material r evie~r ed.

d. Observations: Procedures and Specifications Procedures for the preparation of 'materials used for. fire stops vere available for review as ~~~ere detailed prints and specifications for. each type of fire stop.

e. Observations: OC Inspection of Liaternroofin and'ire Sto",

Installation The licensee's procedure for inspection of conduit and race-vay waterproofing and fire stops ~ras reviewed.. Samples of documented results of these QC inspections vere revic~red and appeared to be conducted in accordance with the procedure.

Observations: Ins ection of Facility A detailed inspection of Units 2 and 3 +as conducted to vis-ually inspect the installation of fire stops and penetration seals. All accessible areas i~ere inspected. This included better than 90% of all safety-related cable. All fire stops and penetration seals on safety-related cable appear to have been installed as specified.

1 ~

~ ~

g. Observations: Testin Performed The licensee has performed tests to determine the degree of fire resistance in cable (February 1/, 1970) and to determine the effectiveness of a representative polyurethane penetra-tion seal (April 3, 1975).

I

4. Invokement of Facility Ren<<irements for. Fire Stons on Electrical Safety-Relat'ed Cable. and Penc tration Seals in Haintenance and lfodification .Procedures 1faintenance and modif ica tion which requires removal and or modif i-cation to fire stops or penetration seals was discussed with the licensee. The licensee stated that no work has been done to date which required the modification or removal of fire stops or pene-tration seals. The licensee's current Administrative Procedures would. require proper, restoration following maintenance or modification.

5. Status of Licensee'" Efforts re IE Bulletins 75-04 and 75-04A The licensee's Construction Division has completed their review of policies, work practices and procedures.

The licensee's Engineering Department has completed their review of the design of floor and wall penetration seals for flamability of materials.

A procedure fo'r thc control of ignition sources is in draft.

The above ."'.tems are updates to the licensee's response to IE Bulletin Yo.75-04A. The remainder of the licensee s actions are as described in their IE Bulletin No.75-04A response.

IZ:I. Form 12

{Jan 75} Q.ev}

~

Uo S NUCLFKR, REGULATORY CO~QfISSION I

OFFICE OF INSPECTION AND ENFORCEfEhT REGION I

~

IE Inspec tion Re por t No: Docket No:

Licensee: Jersey Central Power and Light Companv License No: DP R- 1 6 M'a'dison Avenue at Punch Bowl Road Priority:

'Morristown, New Jersey 07960 Category Safeguards Group'.

Location: 0 ster Creek, Forked River. New Jerse Ty'pe,of Licensee '1 930 MW t BWR I

Type of Inspection- Special, Announced Dates of Inspection: May 5-7,

~

av 2 of Previous Inspection: i Ap r 1 28-May 1, 197 5

~

pg, K. W.

/P~, ~

Plumlee, Reactor Inspector 3>/l~

I

\

Accompanying Inspec tors None DATE DATE DATE Other Accompanying Personnel:

DATE Reviewed By: S'zo y~

R. C. Hayn s, Se ior eactor Inspector

e SEfKARY OF FINDINGS Enforcement Action A. Items of Noncompliance None S. Deviations None Licensee Action on Previousl Identified Enforcement Items Not,applicable None Identified Unusual Occurrences

'None Identified Other Si,nificant Findin s

3 A. Current Findinos

l. Acce table Areas Correlation Between the Facility's Requirements and the As-Built Status of Fire Stops on Safet -Related Electrical Cables and Penetration Seals A visual examination was performed of fire barriers and com-

. partment boundary penetration seals for safety-related elec-trical cables. The observed construction of these items cor-related with the documented requirements for this facility.

(Details, Paragraph 3) 24 Unresolved Items

a. Invokement of Facility Re uirements for Fire Sto s on Electrical Safet -Related Cables and Penetration Seals in

~ 54'intenance and Hodification Procedures An examination was made of the licensee's documented policies and procedures for'maintenance and modification

'3

of'ire

~, 3 stops, on sa fet y-related electrical cables and penetration seals. The licensee is currently reviewing

,these and will inform IE:I by June 1, 1975 of the results of current efforts. (Details, Paragraph 5) b, S ecific Areas of Concern re: Penetration Sealin The following items are unresolved*:

(1) Cable routing (2) Combustible seal material (3) Fire retardant coating (4) Battery room cable run

',(5) ,Fire stops, seals and closures of penetrations in turbine'building, equipment building, and reactor building interior walls and floors.

B. Status of Prcviousl Re orted Unresolved Items Not inspected Mana ement Interview At the conclusion of the inspection the inspector held a meeting at the site with the following personnel to discuss the inspection findings:

Jerse Central Power 6 Light'Comoan D. A. Ross > Manager Generating Stations Nuclear J. T. Carroll, Station Superintendent D. L. Reeves, Chief Engineer E. I. Riggle, Maintenance Supervisor The following items were discussed and 'the inspector's findings were acknowledged by the licensee:

A. Pur ose of the Ins ection The inspector stated that the purpose of this inspection was to examine the document'ed facility requirements for fire stops on safety-related cables and penetration seals, to visually inspect these items for conformance with the requirements, to examine the licensee's provisions for invoking the requirements during maintenance i and modification work and to determine the status of the licensee's efforts with respect to the actions listed in IE Bulletins 75-04 and 75-04A.

• Details, Paragraph 4

"* Participated by telephone conference circuit I

B. Current Findin .s: Acce table Areas

l. Correlation Between the Facility's Re uirements and As-Built Status for Fire Stons on Electrical Safety-Related Cables and Penetration Seals A visual examination was performed of fire barriers and compart-ment boundary, penetra'tion seals for safety-related electrical cables. The observed construction of these items correlated with the documented requirements for this facility. (Details, Paragraph 3)

'C. Unre'solved Item's

,l. Invokement of Facility Re uirements for Fire Sto s on Electrical Safet -Related Cables and Penetration Seals in Maintenance and

'Modification Procedures An examination was made of the licensee's documented policies and maintenance and modification procedures .for fire stops on

'safety-related electri.cal cables and penetration seals. The

'licensee is currently reviewing these matters and will inform IE I by June 1. '975 of the results of current efforts. (Details, Paragraph 5)

2. ecific Areas of Concern re Penetration Sealin The following items are unresolved*:

a. Cable routing b.. Combustible seal material

c. Fire retardant coating

d. Battery room cable run

e. Fire stops, seals and closures of penetrations in turbine building, equipment building, and reactor building interior walls and floors.

.D Status of Licensee's Efforts re IE Bulletins 75-04 and 75-04A s

The licensee's follow-up to IE Bulletins 75-04 and 75-04A includes the. development of procedure preparation guidelines and certain pro-

'cedures and possibly the installation of a fire suppression system.

(Details, Paragraph 6)

• Details, Paragraph 4

DETAXl.S

1. Persons Contacted Jerse Central Power & Li ht Comoan J. T. Carroll, Station Superintendent D. Reeves, Chief Engineer M. Riggle, ~afaintenance Supervisor D. VanNor'twick, Plant Electrician B

2. General l

a. Plant Status The plant was in a refueling outage during this inspection.

b. Pur ose of Inspection The purpose of this inspection was to examine the documented facility requirements for fixe stops on safety-related cables and penetration seals, to visually inspect these items for conformance with the requirements, to examine the licensee's provls Jons Jor Juvosl Jug l.ut regvLrcmdlll.s llULJug llldJuLclsdul'c and, modification work and to determine the status of the licensee's efforts with respect to the actions listed in IE Bulletins 75-04 and 75-04A.

'3. Correlation Between the Facility's Re uirements and As-Built Status for Fire Sto s on Safety-Related Electrical Cables and Penetration Seals Re uirements on Cables and Penetrations (1) FSAR and Technical S ecification Reouirements Sealed penetrations are required for containment integrity in the reactor building (secondary containment) walls.

Xsolation required for 4160 volt dual emergency circuits includes a firewall between the switchgear; physical separation of bus sections, feeders, power centers and motor control centers; and enclosure of feeders to vital equipment in rigid steel conduit.

(2) Other Requirements Insulation on power cables and control cables Gas stated to be self-extinguishing material (either GE VULKE"E or PLA>1INOL brand).

b. Observations (1) . Acce table Areas Visual examination of the electrical cable trays, conduits and penetration seals verified the correlation between as-

.built construction and the above requirements, as follows:

Control room floor penetrations were examined, and 769+

appeared to be sealed. Two others were found not sealed and.the licensee sealed them before the completion of the inspection.

'The licensee stated that nine others, that could not be examined because of physical location, were sealed.

Except fnr a few unused thimbles closod off bv steel discs and plastic bushings, the control room penetrations appeared to be sealed by a (dry) mineral wool-"- packing material.

Reactor building (secondary contain,ent) wall and roof penetrations were examined. All 167*

• electrical conduits and spare thimble penetrations identified cable'rays, appeared to be sealed (described below); The licensee stated that a typical cable tray:penetration seal was:

(a) (Original application) two injections were made (inner and outer seal) of pourable Kaowool which hardened in place.

(b) Periodic leak testing and resealing resulted in the additional application of one or more of:

Pourable Kaowool or similar material Dry packed Kaowool or similar mineral woo1 Duxseal Isofoam

• Inspector s count

+* Kaowool, manufactured by Babcock & Milcox

• • + Inspector's count

~ .

Inspection of the 4160 volt ducts and switchgear" verified that isolation was provided as described by paragraph 3.a. (1).

Inspection of the emergency diesel generator rooms and cables verified that isolation was provided and there was a concrete wall between the diesel generators and between

.the two control panels.

Fire-fighting equipment was visible. As an example a fire-hose and portable fire extinguishers were available near the entrance to the cable room.

Thy lower bays of the turbine building were equipped with automatic overhead sprinklers.

Insulation on power cables and control cables was examined on a sampling basis and was identified as either GE VULKENE or FLQfINOL, on each sample.

4. S ecific Areas of Concern re Penetration Sealin The inspector examined a combination storage/cable pulling room containing 25 cable trays, 67 rigid conduits and 14 non-'rigid~

conduits. Areas connecting"-* .to this room included:

Main cable room (openings 5X5 and 5X3 ft)

Pipe tunnel (opening 4X4 ft) 460 volt distribution room (opening 2X4 ft)

DC battery room (tunnel 5X6 ft)

The main cable room also has openings to an equipment room above the control room (a pipe chase opening, 2X10 ft, partly filled by ventilation ducts, conduits, pipes, etc.) and to the turbine building (nine cable trays through a corridor).

The inspector found that there were no cable-penetration fire stops. 'he licensee stated there was no requirement to provide cable fire stops, or to close up or seal the "bove openings.

b. Combustible Seal Material The licensee's review of fire stops and seals following issuance of IE Bulletins 75-04 and 75-04A apparently identified Isofoam

• Greenfield type

+* Estimated sizes of openings follow

as combustible. The licensee removed' piece of Isofoam from an electrical penetration seal. It was ignited and burned completely.

The licensee statec that the Isofoam was at most only an inch or two thick and did not extend from one side of the seal to the other; thus propagation of fire through a seal was stated to be unlikely.

No test data were'vailable that would substantiate the licensee's position on flame resistance of seals. The licensee stated that there was no requirement to remove or coat over the Isofoam.

c. Fire Retardant Coatin No fire retardant coating was evident and the licensee did not commit to apply such coatings to electrical cables or penetration

.seals.

d. 'atter Room Cable Run I

All electrical cables supplied from battery room DC distribution panels A and B are collected into a single cable tray.

The licensee stated that the specifications do not require isolation of these cables.

e. Fire Sto s Seals and Closures of Penetrations in Turbine Bu ldinn.

E ui ment Buildin and Reactor Building Interior 4'alls and Floors

.Turbine building, equipment building and reactor building interior wall and floor penetrations were examined where electrical cable trays, conduits and spare thimbles pass through. Typically, no seal or closure of these penetrations was evident. (No requirement was identified to seal or close the openings identified.)

The above items a through e are considered to be unresolved pending completion of the licensee's follow-up on IE Bulletin No.75-04A'nd a subsequent review of their actions by an NRC inspector.

5. Invokement of Facility Requirements for Fire Stops on Electrical Safet -Related Cables and Penetration Seals in Maintenance and Modification Procedures Job orders are used to initiate work on cables, fire stops and penetration seals. The licensee's supervision controls the work to

o ~ ~

be done, states what procedures are to be used, supervises work as it progresses, and accepts the completed job. However, no maintenance or modification procedures for penetration seals were provided by the licensee.

This item is 'considered to be unresolved pending completion of the licensee's review of their procedures as a part of the licensee's response to IE Bulletin No.75-04A (Details, Paragraph 6) and sub-sequent review of their findings and actions by an NRC inspector.

6. 'Sta'tus of Licensee's Efforts re IE Bulletins 75-04 and 75-04A The licensee's reply* to;IE Bulletins 75-04 and .75-04A'described their efforts on procedure preparation guidelines that specifically address the concerns of Item 3, parts a through e of IE Bulletin 75-04A-. This is scheduled for completion by June 1, 1975.

• Licensee's letter.to IE:I dated April 24, 1975

U.S NUCLEAR REGULATORY CO:MISSION OFFICE OF INSPECTION AND ENFORCE~~'T

.REGION I 50-220/75-06 50-220 XE Inspection Report No: Docl;et No:

Licensee: Niagara kfohawk Power Corporation License 300 Erie Boulevard, Hest Priority:

Syra,cuse, New York 13202 C Category:No'ype

. Location: Nine Nile Point, Unit 1, Scriba, NY Safeguards Group:

of Licensee: BUR (GE) 1850 Hy(t) of Inspection: Routine, Announced

~

Type Dates of Inspection:

April 29 <<hy 2, 1975 ual.eo Gf x revivals xnspeca.ioni A ril 15-18, 1975 r</~

importing Inspector:

J. T. Shedlosky, eactor Inspector Date

'ccompanying Inspectors:

Date Date Date Date Other Accompanying Personnel: NONE Date Reviewed By:

R. C. Haynes, Sdnior Reactor Inspector Date

0 S&ikfARY OF FINDINGS Enforcement Action ~ 4 A. Items of Noncom liance None'.

Deviations None Licensee Action on Previousl Identified Enforcement Items Not Applicable None'dentified Unusual Occurrences None Identified Other Si nificant Findin s A.. Current Findin s

1. Acce table Areas

a. Correlation Between the Facility's Requirements and As-Built Status for Fire Stops on Electrical Safet Related Cables and Penetration Seals A visual examination was performed of the installation of fire barriers and compartment boundary seals, and the application of fire-retardant coating, .for safety related cables. Generally there is .correlation between this con-struction and the facility's documented requirements; (Details, Paragraph 3)

24 Unresolved Items

a. Invokement of r'acilitv 'Requirements for Fire Sto s on Electrical Safet -Related C.oles ..nd Penetration Seals in >hintcnance and ifodification Procedures Facility maintenance and modification procedures do not specifically reference the sealing of penetrations. Work to date has been done using the station's original con-structio'n spec'ification's. (Details, Paragraph 4)

B. 'Status of Previousl Reported Unresolved Items Not Inspected Mana ement Interview At the conclusion of the inspection, the inspector held a meeting at the site with the'ollowing personnel to discuss the inspection findings:

Niagara Voh 't" k"-Pc'ver Co~roration 2ir. T. J. Perkins, Station Superintendent, Nine Mile Point kfr. R. W. Smith, Plant Superintendent, J, A. Fit zPa tr ick Mr. R. J. Pasternak, Operations Supervisor, J. A. FitzPatrick Mr. J. H. Kerfien, Assistant Qua3.ity Cont'rol Supervisor The following items were discussed, and the inspector's findings were acknowledged by the licensee.

A. Pur ose of the Inspection The inspector stated that the purpose of this special, announced inspection was to examine the documented facility requirements for fire stops on safety-related cables and penetration seals, to visually inspect these items for conformance with the requirements, to examine the licensee's provisions for invoking the requirements during main'tenance and modification work and to determine the status of the licensee's efforts with respect to the actions listed in IE Bulletins 75-04 and 75-04A.

3

'I

• B. Current Findin s: Acceptable Areas The inspector stated "that his review of the following areas.revealed acceptable findings:

1. Correlation Between the Facilit 's Requirements and As-Built Statbs for Fire Stops on Electrical Safety-Related Cables and Penetration-Seals A visual examination was performed of the installation of fire barriers and.compartment boundary seals, and the application of fixe-retardant coating, for safety related cables. Generally there is, correlation between this construction and the facility's documented requirements. (Details, Paragraph 3)

C. Unresolved Items The inspector stated that the following items were observed and are considered to be unresolved:

1..Invokement of Facilit Requirements for Fire Stops on Electrical Safety-Related Caoles and Penetration Seals in ~wintenance and 1fodif ication Procedures Facility maintenance and modification procedures do not speci-fically reference the scaling of penetrations. Work to date has been done using the station's 'original construction speci-I 1 fications. (Details, Paragraph 4)

D. Status of Licensee's Efforts re IE Bulletins 75-04 and 75-04A The licensee provided the inspector with a status report on his efforts in complying with the requirements of IE Bulletins Nos.

75-04 and 75-04A. (Details, Paragraph 5)

DETAILS Persons Contacted Nia ara Mohawk Power Cor oration Mr. R. R. Schneider, Vice President Electric Operations Mr. T. J. Perkins, Station Superintendent Mr. R. Baker, Maintenance Supervisor-

2. General

a. Plant Status The plant was operating at about 97% power.

b. Pur ose of Inspection The purpose of this inspection was to examine the documented facility requirements for fire stops on safety-related cables a~d na~nt ra t ~ nn c'Pa1 s > to visua 7v 9nsnpct these ltc ms 1

conformance with the requirements, to examine the licensee's provisions for invoking the requirements during maintenance and modification work and to determine the status of the licensee's efforts with respect to th" actions listed in IE Bulletins 75-04 and 75-04A.

3~ Correlation Between the Facilit 's Requirements and As-Built Status for Fire Sto s on Electrical Safet -Related Cables and Penetration Seals (1) Final Safet Analysis Re ort Supplement 4, Question 4, Response states in part: "Cable Penetrations - Cable penetrations of the primary contain-ment (drywell and pressure suppression chamber), reactor building, auxiliary control room and the cable room below have been designed to provid'e adequate fire stop and to prevent a fire from spreading through the penetration.

Reactor building penetrations consist of standard conduit (pipe) sleeves, which vary in diameter from 3/4" to 4",

and which will be sealed at both ends with Duxseal. The

.auxiliary control room and the cable room below have

formed pipe sleeves. These sleeves will be sealed at the ends with rock;wool filler and externally applied fire-resistant material for fire proofing. C02 equipment is also provided, in these'wo rooms as an added precaution".

~

"Protection in Hazardous Areas '- Cables in trays which run through hazardous areas such as the diesel-generator (oil fire or explosion) will be protected mechanically 'ooms by the tray its~if and will be coated with the externally applied fire-resistant material for fire '-resistance.

1 Tray shields over the top tray (raised to allow normal

,ventilation), will,be provided .at, selected locations where an, opening occurs above the tray to prevent hot weld material or missile damage from above.

Types of Cable "Power Cable 24-kv and 4160-volt cables are Kerite in-sulated with neoprene jackets.

Cables for 2400-volt service and below are Vulkene in-sulated. (General Electric Corn~any trade name for cross-linked polyethylene)."

"Control Cable General use, multi-conductor control cables are Vulkene insulated and 1000.-volt rated (except supervisory control cable, which is 600-volt rated), with mylar binde; tape and polyvinyl chloride (PVC) jacket overall.

Special controls cables for. control'-ride-drive instrumen-tation, area radiation monitors, etc. are multi-conductor

.. PVC insulated, coordinatdd-voltage rated, with suitable binder tape and PVC jacket overall.

Single-conductor cable inside drywell penetration (AUG 88, 810 and P12) is General Electric Company extraflexible Vulkene insulated type SXS switchboard wire."

"Special Cable Coaxial and triaxial cables generally are polyethylene insulated, with mylar tape wraps and polyet'hylene jackets.

Shielded cables generally are polyethylene insulated with PVC.jackets.

Thermocouple extension wire is PVC insulated and jacketed except that in the drywell the vessel temperature thermo-couple extension wires .are magnesium-oxide insulated, with 304 stainless steel sheath.'-'2)

Installation S ecifications "Cable Tray 'Covers and Fire Pro'tec'tion, Details and S'ections "Index 3-N2-E27, No'. C-19448-C, dated 3/14/69".

Detail B "Sealing, of Wall Sleeves in Auz Control Room.

and Cable Room" re'quires Flamastic F-71 on both sides to seal all cavities over Kaowood'eramic fiber which the voids.

fills Detail E "Vertical Tray thru Floor (261') opening (Tray 12 CAV only).", requir'es all voids filled with Kaowood ceramic fiber, the lower cover coated with Flamastic F-71 and a stccl psate covering tne topo Detail F "Sealing of Tray in Auxiliary Control Room

.Wall Sleeves Cll and C32",'equires Flamastic F-71 over Kaowood ceramic fiber material filling voids.

Detail G "Sealing conduits thru control room, auxiliary control room and cable room walls", requires sealing with "Duzseal" at both ends, and sealed on the exterior surface with motor.

Detail H and J "Vertical Tray thru Floor", requires filling all voids with Kaowood ceramic fiber.

Detail L "Vertical Tray thru Floor", requires filling voids with Kaowood ceramic fiber, a i layer .of Flamastic F-.71 on the top.of floor level and a 1/8" steel plate at the bottom.

Detail H "Trays Passing thru Wall Sleeves", requires filling all voids with Kaowood ceramic fiber, a 1/8" steel plate on both sides and Flamastic F-71 on both sides.

"Wall Sleeves and Duct Banks in Reactor'uilding Halls",

requires Duxse 1 on both ends of pipe sleeves.

These requirements appear to be in conformance with commitments made in the Safety Analysis Report; (3) Procurement S ecifications Cable S ecification N-147; N1PNS for insulated cables for 4,160 volt power cables, June l7, 1965.

Insulation Characteristics'5Kv, Kerite ground, polyvinal chloride Jacket:. Neoprene Standards: the "latest" IPCEA Standards

~S eciiication N-193, Ntppd for multiple conductor cables for controls and misc. purposes, uateu ieuruary Ol ACR 1 Insulation Characteristics: Vulkene Jacket: Polyvinal Chloride, in accordance with 1PCEA, S-61-402, Section 4.31.

Standards: the "latest" IPCEA Standards Specification 2E, Revision 1, 600-1000 volt cable for stores, dated February 26, 1975.

Standards: XPCEA S-19-81, S-68-516, S-66-524 as applic-able to insulation. All AST~if as applicable.

Qualified in accordance with IEEE 383 (latest revision).

Control Cable Insualtion: Vulkene Jacket: Flamenol Supervisory Insulation: Vulkene Jacket: Flamenol

Shielded Cable Insulation: Polyethylene Jacket: Flamenol Coaxial Cable RG59 B/U Insulation: Radiation resistant irradiated polyethylene Copper Constantan Insulation: Polzninal Chloride Single Conductor 2~iK volt Insulation: Kerite double permashield Jacket: NS Neoprene Sirigle Conductor 4160 volt Insulation: Kerite ground, Polyvinal Chloride or

, Vulkene or Polyvinal Chloride Single Conductor 600 volt Insulation: Vulkene RHH ground, polyvina1. chloride UL approved These purchase specirications represuit thos~ available at'the site during the inspection.

Observations The inspector visually inspected all safety-'related cable penetrations, except those which could not be examined without interfering with the operation of the facility or removing material and equipment previously installed. Floors, walls and ceilings were examined in the following areas:

'urbine Building (300'levation) Reactor Building wall sleeves (277'levation) Reactor Building wall sleeves Battery Rooms Control Room (261'levation) Reactor Building wall sleeves Auxiliary Control Room Battery Power Board Rooms Diesel Generator Rooms Diesel'enerator Board Rooms (250'levation) Cable Room Reactor Building wall sleeves Reactor Building duct banks

0 Reactor Building (340'levation)

(318'levation)

.(301'levation)

(281,'levation)

(261'levation)

The inspector found that the installation of cable penetra-tion seals and fire stops was generally in accordance with the licensee's 'commitments in the Safety Analysis Report and with the plant's construction specifications. Exceptions which were observed were: I (1) Auxiliary Control Room, two safety related penetrations through the floor require the Flamastic coating.

(2) Cable Room, one new penetration outside of the cable room requires a Flamastic coating. Two new penetrations inside the cable room require.a Flamastic coating.

(3) Turbine Building, one Reactor Buiding Penetration ll-c, A-1) penetration'(250'levation} was not sealed with Duxseal. The inspector verified that this penetration was sealed within the Peactor Building.

(4) Reactor Building, several penetrations through the floor at various levels were not.sealed with Duxseal. These were:

SL 318 i)12 11A SL 318 M12 11B SL 281 H4 14A SL 281 Q11 6B All of these penetrations are within the reactor building.

Licensee representatives noted these findings and initiated action to correct these items. Full corrective action could not be accomplished during the inspection because of the need to procure material.

The inspector noted that the cable leaving control room panels to the auxiliary control room pass .thorugh seventy-four openings below those panels. According to design these penetrations are open.

The inspector also noted that the pull ropes have been left in reactor building penetrations at thd 250'levation of the .

Turbine Building. This does n'ot appear to- be in accordance

. with the installation specifications.

4. Envokement of Facilit Re uiremcnts for Fire Sto s'on Electrical Safet -Related Cables and.Penetration Seals in Vmintenance and Hodification Procedures The 1'icensee has no maintenance or modi'fication procedures relating to 'penetration seals. The licensee stated that maintenance or modifications have been in accordance with the construction install-

.ation .procedures.. This item is considered unresolved pending NRC review of documented site instructions which direct the use of con-struction installation procedures for penetration maintenance and

'modifications.

5. Status of Licensee's Efforts re IE Bulletins 75-04 and 75-04A The licensee has responded to Bulletin 75-04. He has also committed to developing .procedures for leak testing penetrations. On the ssaa i(

1 he@

Jcdpvlloc l o alukI J% e 04 thh a A'l. w v v ns cf'at nA t'nott thD i~<view aAa~ 1 hn~c a ev) required by Bulletin 75-04A would be completed by i~ay 19, 1975.

XE ~ I Fora '2

{Jan 75) (Rev)

'U Se NUCLEAR REGULATORY COiQfISSION OFFICE OF INSPECTION AND ENFORCB1ENT REGION I tion Re rt No. 50-245/75-09 Docket No: 50-245

.Z,icensee; Northeast Nuclear Energy Company License No: DPR-21 P. 0. Box 270 Priority:

Hartford, Connecticut 06101 Category.

Safeguards Group:

Waterford, Connecticut (afillstone 1)

Type of Licensee BWR 2011 hat

~"q .e of Inspection: Special, Announced o f Inspec tion April 28-30, 1975 D"tes of Previous Inspection'. p i Reporting Inspector: ~l,;','r:f;~

K. E. Plumlee, Reactor Inspector DATE Accompanying Inspec tors:

DATE DATE Other Accompanying Personnel:

DATE Reviewed By: 3-R. C. )haynes, Senior Reactor Inspector DATE

StBQfARY OF FINDINGS Enforcement Action "

A. Items of Noncom liance None B. Deviations None Licensee Action on,Previousl Identified Enforcement Items Not applicable Hone identifieid Unusual Occurrences None identified Other Si nificant Findin s A. Current Findings

l. Acce table Areas Correlation Between the Facility's Requirements and the As-Built St:atus of Fire Sto s on Safety-Related Electrical Cables and Penetration Seals.

A visual examinat:ion was performed of fire barriers and compart:

ment boundary penetration seals for safety related electrical cables. The observed construction of these items correlated with the document:ed requirements for this facility. (Details, Paragraph 3) 2.. Unresolved Items a.'Licensee's Review of Policies and ~faintenance and kfodification Procedures for Installation of. pire Sto s on Safet -Related Electrical Cables and Penetration Seals.

An 'examination was made of the licensee's documented policies and maintenance and modification procedures for installation

0 of fire stops on safety-related electrical cables and pene-tration seals. The licensee is currently reviewing these matters and will inform the Region I Office of Inspection.

and Enforcement (IE:I) no later than June 1, 1975 of the results of the review and any changes made as a result of the review. (Details, Paragraph 4.)

b. .S ecific Penetration uestions I

The following -itt ms are unresolved (Details, Paragraph 3.b.2.)

(1) Control, room floor penetr'ations.

(2) ,Flame retardant coating on cables.

'.,"." '-;:(3) Floor openings in .the cable vault.

B. Status of Previously Reported Unresolved Items Not inspected t 1fana ement W. G.

E. R.

Interview At the conclusion of the inspection, the inspector held a meeting at the site with the following personnel to d'iscuss thc inspection findings:

Northeast Nuclear Ener v Com Counsil,'tation Superintendent an Poster, Assist'ant Station Superintendent Northeast Nuclear Utilities Service Comoan J. Suma, Assistant Engineer, Generation, El'ectrical Engineering Department The following items were discussed and the inspector's finding's were acknowledged by the licensee:

A. Pur ose of the Ins ection The inspector stated that the purpose of this special, announced inspection was to examine the documented facility requirements for

fire stops on safety-related cables and penetration seals, t'o visually inspect thcse items for conformance .arith the requirements, to examin'e the licensee's provisions for invok ng the requirements during main-tenance and modificatior work and to determine the status of efforts with respect to the actions listed in IE Bulletins the'icensee's 75-04 and 75-04A.

B. Current Findin s: Acce table Areas A visual examination was performed of fire bardiers and compartment boundary penetration seals for safety-related electrical cables. The observed construction of these items correlated with the documented requirements for this facility. (Details, Paragraph 3) .

C. Unresolved Items Licensee's Review of Policies and Tfaintenance and Nodification Procedures for Installation of Fire Stops on Safet '-Related Electrical Cables and Penetration Seals.

a. . An examination was made of the licensee's documented policies and maintenance and modification .procedures for installation of fire stops on safety-related electrical cables and penetra-tion seals. The licensee is currently reviewing these matter and will inform the Region I Office of Inspection and Enforcement

.(IE:I) no later than June 1, 1975 of the results of the review and any changes made as a result of the review. (Details, Paragraph 4.)

b. S ecific Penetration uestions The following items are unresolved (Details, Paragraph 3.b.2.)

(1) Control room floor penetrations.

(2) Floor openings in the cab'le vault.

(3) Plame retardant coating on cables.

D. Status of Licensee's Efforts re IE Bulletins 75-04 and 75-04A the licensee's letters to Regional Office I dated April 17, and April 24, 1975 replied to IE Bulletins 75-04 and 75-04A and stated that further information would be provided in writing by June 1, 1975. (Details, Paragraph 5)

DETAILS 3

l. Persons Contacted Northeast Nuclear Ener Com an W. G. Counsil, Station Superintendent E. R. 'Foster, Assistant Station Superintendent M. Hills,. Operations Supervisor J. Kiskunes, Plant Electrician (A) 1 R. Luther, Overhead/Underground Systems Fngineer A. Roby, Chief of Generation; Electrical Engineering Department J. Suma, Assistant Engineer, Generation; Electrical Engineering Department

2. General a, Plant Status The plant was operating during this inspection.

b. Pur ose of Ins ection The purpose of this inspection was to examine the documented facility requirements for fire stop on safety-related cable and penetration se,.l , to visually inspect these items for conformance with the requirements, to examine the licensee's provisions for invoking the requirements during maintenance and modification work and to determine the status of the licen ee's efforts with respect to the actions listed in IE Bulletins 75-04 and 75-04A.

3. Correlation Between the Facility's Reauiiements and As-Built Status for Fire Stops on Safet -Related Flectrical Cables and Penetration Seals.

ao Re uirements on Cables and Penetrations (l) FSAR and Technical S ecification Re uirements Sealed penetrations are required for c'ontainment integrity in the reactor building (secondary containment) walls. No detailed specifications were provided for electrical pene-tration seals.

The licensee stated* that one or more of the Zol1owing are used to seal electrical'penetrations:

Hard setting,sealant** inside trays and conduits.

Duct seal,= alone or with other sealants.

Polystyiene blocks used with duct seal.

Conduit bushing and a steel disc, on unused sleeves.

~ Steel pipe plugs.

Separation of certain redundant systems, including Reactor Protection Systems RPS I and RPS II electrical cables, is required.

Metal clad ducts and switchgear are required for 4160 volt power circuits.

(2) Additional Re uirements The licensee stated plans to develop a satisfactory seal and to seal all penetrations of the control room floor.

The iollowup report on Bulletin No.75-04A, due to IE:I no later than June 1, 1975 is to state requirements being determined by the licensee's review of such matters.

b. Observations (1) Acce table Areas Visual examination of the electrical cable trays, conduits and penetration seals verified the correlation between as-built construction and the requirements, stated above, as follows:

Reactor building (secondary containment) wall penetrations were examined. All 160 electrical cable trays, conduits and spare thimble penetrations identified appeared to be sealed.

• Licensee's letter to XE:I dated April 17, 1975.

• • Typically Grouse-Hinds "Chico A" sealing compound.

Turbine building, equipment building, .and reactor building interior wall and floor penetrations weie examined where trays, condui>s and spare thimbles pass through. Typically no seal, or closure of these penetrations was evident. No requirement was identified to seal or close these openings.

Visual examination of 95 trays and conduits that penetrate

~

the cable vault walls verified that all 28 penetrating secondary containment were sealed. ,No other sealed

~

penetrations were identified in the cable vault walls.

I

Except'or york described to be in progress and incomplete, all the cable vault cabling was in m tal covered trays (non-ventilated). -A few raised covers, removed covers, and exposed cables were seen (estimated to be below one percent of the total).

Trays labelled S-1 or S-2 (safety system cables) were

. separated by a fire barrier* wherever one passed over the other.

. A wall separated the NPC-1 cable vault from the hPC-2 cable vault. Some apparently incomplete penetrations were evident.

The licensee stated that these will be completed and sealed or closed up.

A thermal fire alarm system was provided in the cable vault.

CARDOX fire suppression system controls as well as a port-able extinguisher and a fire hose were provided near the entrance to the cable vault.

Znspection of power cabling and switchgear verified that required fire barriers were provided and that:

4160-volt cables were segregated from lower voltage cables and were in metal ducts or conduits.

460-volt cables were segregated from cables operated at higher or lover voltages.

Separate conduits were used'Xor cabling to the diesel engine driven and the gas turbine driven emergency generators.

The barrier was a composition board covered with an asbestos cover on two sides.

(2) S ecific *Penetration Questions (a) Control Room Floor Penetrations Visual examination of 568 control room floor penetrations showed that duct seal was visible on 481, a drypacked miner'al wool seal material was visible on 6, and no seal was visible on 81 penetrations. The licensee stated that study of possible techniques and procedures to seal these penetrations was being performed and their resolution of this matter would be reported to IE:I.

(b) Floor 0 eninps in the Cable Vault An approximately 3 ft. by 8 ft. floor grating and other openings were evident in the cable vault. The ventilation rate was estimated (by the inspector) at about 5,000 cfm passing through these openings.

(c) Flame Retardant Coatin on Cables No flame retardant coating was evident, and the licensee did not commit to apply'uch coating to electrical cables or penetrations.'he above items (a), (b), and (c) are considered to be unresolved pending a review b'y an hRC inspector upon com-pletion of the licensee's followup on IE Bulletin 75-04A, which includes a review of such matters by the licensee.

4. Licensee's Procedures for Maintenance and Modifications to Fire Sto s and Seals Job orders are used to initiate work on cables,- fire stops, and penetration seals. The licensee's supervision controls the work to be done, states what procedures are to be used, supervises work as it progresses, and accepts the completed job.

No detailed written procedures were identified during this inspection.

This item is considered to be unresolved, pending a review by an NRC inspector, upon completion of the licensee's review of his procedures as a 'part of the response to IE Bulletin 75-04A.

0

~ ~

3 Status of Licensee's Efforts re IE Bulletins 75-04 and 75-04A The licensee's representative stated* that sealing of penetrations through the control room floor would be completed by Hay 15, 1975 except for those penetrations requiring techniques and procedures which are under review. ,(Paragraph 3.a.(2))

The licensee had obtained a test by Kerite Cable Company, Seymour, Connecticut of a penetration seal design that is i being evaluated by the licensee.

• The licensee's followup letter to the replies on Bulletins 75-04 and 75-04A is scheduled by June 1, 1975. The 1icensee',s. review of these matters is expected to be complete by that time 'and the following are expected to be resolved thereby:

a. identification of cable penetrations to be .sealed or repaired.

b. Techniques and procedures for sealing all penetrations still to be sealed or repaired.

c. Specifications for,mate'rials and the construction of cable penetrations.

~ '

Followed up by telephone contact on Hay 2, 1975 (Greenman and Plumlee to Counsil).

k p~o 7 .I'o~ 1>>

(J'n 75) ("ev)

A U. So NUCLEAR RKULATORY CO:f."fISSION OFFICE OF ISSP FCTIOi AI~ E FORCE. iF.:V REGIO'.I I IH Inspection Report Yo: 0-309 75-07 i

Licensee: Ifaine Yankee Atomic Po~.er Covnanv License No: Dpi>->

,20 TurnpiIce Road Priority:

~ '>~ ';or'<4P~~,+

~

Ifestboro, 1fassachusetts 015S1 " Category:

tlat Safe uards Group:

Iiiscasset, ~faine 04578 (~! ine Yanlcee)

'Type of Licensee.'I"R', 2440 lP"t (CE)

~ et

~~ I"\ ~ t+ fg >> <+' ~ ~ ~ ~ ~ ~ avionic<>

4~~

Da.'f Inspection: Ifay 12-13, 1975 ates of Previous Ins pec tion.'ay 6-7 1975

~ 0 Reporf:irg Irspector:

DME J. F. Streeter, Reactor Inspector Accompanying Inspectors:

atone DATE DATE DATE Other Accompanying Personnel: 'L' DATE Revieved By:

J~i; ( ) 5-z 7-7.o "enior Reactor Insrector DATE R, C; IIaynes, 1

SU~I'fARY OF FXHDXHGS Enforcement Action A, Items of Noncomnliance None B. Deviations None Licensee Action on Previousl Xdentified Enforcement Items Not Applicable

.Desi n Chances Xdnns i fied Unusual Occurrences Hone Xdentified Other Sipnificant Findin"-s

l. Acce table Area Correlation Bet<:een the Facility's Renuirec~ents and As-Built Status for Fire Stoos on Electrical Safetv-Related Cables and Penetration Seals A visual examination vas performed of the installation of fire barriers and compartment boundary seals for safety related cables.

There is correlation betveen this construction and the facility's documented requirements in certain areas. (Details, Paragraph 3.)

3

~ 2. Unresolved Items

a. Invokcment S

of Facility Requirements'for 'Fire Stons on Electrical

~fetv-Related Cables and Penetration Seals in i!aintenancc and kfodification Procedures

' lack of documented coverage vas ascertained for maintenance an4 modification procedures for fire stops on safety-related

- cables and penetration seals. (Details, Paragraph 5.)

b." 'S 'ecific uestions re Penetration Sealin~

The inspector noted six cases where it appeared that the licensee's criteria for fire stops and boundary seals varied from the FSAR require. orts or the architect-engineer 's suggestions. (Details, Paragraph 4.)

B. 'tatus of Previously Reported Unresolved Items Not Inspected vien n( n~n>> t 7e trirv hv 3

At the conclusion of the inspection, the inspector held a meeting, at the site vith iver. C. D. Frizzle, Assistant to the Plant Superintendent, to discuss the inspection findings.

The following items vere discussed and the inspector's findings vere acknovledged by the licensee:

A. 'ur ose of the Inspection The inspector stated that the purpose of this special, announced in-spection vas to examine the documented facility requirements for fire stops on safety-related cables and penetration seals, to visually inspect these items for conformance with the requirements, to ezamine the licensee's provisions for invoking the requirements during main-

~

tenance and modification work and to determine the status of the licensee's efforts vith respect to the actions listed in IE Bulletins 75-04 and 75-04A.

R g

Current Findins,s 1, Acce table Area Thc inspector stated tha.t his review of the following areas revealed acceptable findings:

Correlation Between the laci3.itv's Peauire-. ents"and As-Built Status. -'-

for Fire Stop. on Electrical Safet '-Relate<i Cables and Penetration Seals' visual examination was performed of the installation of fire

'arriers and compartment boundary seals for safety related cables.

There is correlation between this construction and 'the facility 's documented requirements in certain areas. (Detaisl, Paragraph 3.)

2. Unresolved items a..Xnvo)'ement of Facilit Require-,.:ents for Fire Sto s on Electrical Sa'fetv-)le3ated Cables,.nd Penetration Seals in .'Jaintcnance and lfodifica ti c n Procedures A lack of documented coverage was ascertained for. maintenance and modification procedures for fire stops on electrical safety-related cab3es and penetration seals.. {Details, Pa ~ h 5 )

b.' 'ecific Questions re Penetration Sealinr,s The inspector noted six cases where it appeared that the licensee's criteria for fire stops and boundarvf seals varied from the FSA)< requirements or the architect-engineers suggestions.

(Details, Paragraph 4.)

C. Status of Licensee's Efforts on lE Bulletins 75-04 and 75-04A The licensee provided the inspector with a status report on l.is efforts in complying with the requirements of lE Bulletins 75-04 and 75-04A. (Details, Paragraph 6.)

DFTAILS

1. Per. ons Contacted Maine Yankee Atomic Pover Company i.

Mr. C. D. Fri"zle, Assistant to the Plant Superintendent

~

Mr. D. E. Hoody, Plant Sup'erintendent Hr, R. Li'ilkinson, Flectrici n Mr. E. C. Liood, Assistant Plant Superintend'ent Hr. C. G. Pebler, Assistant Project Engineer

2. GeneraI

a. Plant Status The plant vas in a refueling shutdovn during the inspection. Plant startup is not expected before June 15 .

b., Pur. ose of Inspection The purpose of this inspection vas to examine the documented facility require- ents for fire stops on safety-relat.ed cables and penetrations seals, to visually inspect these items for conformance vith the require... nts during maintenance and modification vork and to determine the status of the licensee's efforts vith respect to the actions listed in IE Bulletins 75-04 and 75-04A.

3.:'Correlation Betveen the Facility's Reouirements and As-Built Status

'or Fire Stops on Electrical Safety-Related Cables and Penetration Seals The inspector. revieved the licensee's Final Safety Analysis Report to determine vhat require...ents vere established for fire stops. The FSAR in Section 8.3.7.7, states that "Fire stops are provided around trays and in sleeves vhich penetrate areas vhere carbon

,dioxide protection is used." The FSAR lists the C02 protected

~,

I areas outside reactor containment as the Cable Vault, both Outer Containnent Penetration Rooms, and both Cable Tray Rooms.

.The inspector requested all construction specifications and other applicable documentation 'related to facility requirements for fire stops or safety related cables and penetration seals.

The licensee provided copies of communications bet~ een he and his architect-engineer and copies of engineering drawings showing conduit sleeves and cable runs. The communications in-dicated that the architect-engineer suggested the use of the following construction'echniques:

(1) Use duct seal (putty-like compound} to seal corduits in the Control Room for the purpose of containing breathing air .

(2) Use duct seal to contain CO2 in C02 protected areas.

(3) Use Plamemastic 71A to make a fire stop in. conduit sleeves.

("Principal fire barriers" specifically mentioned were (a}

the walls of the Switchgear and Control Room areas, and (b) the walls and floors of the Cable Tray Room, Reactor Con-tainment NCC, and the Reactor Containment Outer Penetration Rooms..)

There is no requirement for the application of fire-retardant coatings on safety-related cables.

b. Observations The inspector visually inspected all accessible safety-related cable penetrations in the following areas:

Control Room and Cable Chase Cable Vault Primary Auxiliary Building Circulating 4'ater Pump 11ouse Reactor Containment Outer Penetration Rooms Protected Cable Tray Room Protected Switchgear Room Emergency Diesel Generator Rooms Reactor Containment NCC Rooms Containment Spray Pump Area Auxiliary Peed Pump ('1otor) Area

~ ~

k I,

3 The inspect:or geperally f ound fire 3iarriers and boundary seals instal'led in accoxdance with the licensee's criteria whexe safety-re'lated cables pass through floors', walls, and ceilings.

The 'fire =barriers in most cases vere inst:a3.led by stuffing asbestos rope into a cab3.e sleeve and filling in the well formed with Flamemastic 71A. The compartment boundary seals were composed of duct seal stuffed in penetrations or end caps on spaxe sleeves.

I I

4, S 'ecific uestions re Penetrations Sealing I

The inspector noted siz.cases where it appeared that the licensee's.

cr'iteria for fire stops and 'boundary seals varied 'from:the architect-engineer's suggestions or the ISAR requirements.

(1) 4'all Penetrations 11, .20, and .21 in the Protected Cable Tray Room were observed to be con:posed of a combination of Flamenastic 71A and duct seal. The seals were not all effective since air vas noted to be passing fron> the tuxbine hall into the Protected Cable Tray Boo:n.

1 (2) Liall Penetration 1 in the Protected Cable Tray Poom was observed to have only the asbest:os -rope vi.thout Flamemastic 71A applied.

~ 3 (3) One

'ad.

floor penetration in the lover the boundary seal-removed.

(4) Seventeen Reactor Containment floor penetrations in the Control- Room ViCC Room were not sealed.

(5) The licensee did not intend or atten:pt to seal conduit sleeves safety-related povex and'ontrol cables between the 'arrying Protected Svitchgear Room and the Protected Cable, Tray Room, and between the upper and lover Reactor Containment PCC Rooms.

(6) Tvo conduits between the Cable Vault and the lover level of the Primary Auxiliary Building were not sealed. The inspector could not readily determine if all conduits that were 'not sealed in'he Cable Vault {~ 400) vere sealed on the opposite end.

The licensee stated that he intends to consider these issues in his efforts related to XE Bulletins 75-04 and 75-04A. These items are unresolved pending EE:I evaluation of =the licensee's Bulletin response and of any subseque'nt action that the licensee takes.

1

0

~ ~

t 5". Invol oncet of Fncili~el'eauirenente for Fire Stone on Electricel,

~

~

~

Safety-Related Cables and penetration Seals in ~t.'aintenance and lfodification procedures

\

The inspect.cr determined from discus ion ~ith the licensee that there s;ere no procedures available to plant personnel that addressed the issue of restoring fire stops and boundary seals disturbed during maintenance operations.. .The inspector also determined from di cussions vith personnel that some of the findings in paragraph 4 above resulted from not having fire stop and boundary seal restora'tion instruc'tions.

.'The licensee, stated 'that this vill b addres ed in his final re-sponse to IE Bulletins 75-04 and 75-04A. This item is unresolved pending IE:I evaluation of the licensee's Bulletin response and of any subsequent action that the licensee takes.

6. Status of Licensee's Response to IE Bulletins 75-04 and 75-04A The inspector requested a status report from the licensee regarding IE Bulletins 75-04 and 75-04A. The licensee stated that a survey t1>e requn rements of Bul 1 et ins 75-Q4 and 75 0/ P rel atiere to t he plant 'has been made and an evaluation is in progress. ('l'he Licensee mailed the NRC a letter, No. 4~Z 75-43, dated April 24, 1975, from J. L. French (Van1:ee Atomic Electric Company) to J. P. O'Reilly (U.S.N.R.C.) . This letter provides a schedule for eleven different types of surveys and reviews being conducted by the licensee in response to Bulletins 75-04 and 75-04A. The final plant policy reviev is scheduled for completion on 9/30/75 .)

The licensee stated that after definite criteria have been established for material to be used for various fire stops and boundary seals as part of his response to the Bulletins, he intendseto conduct another indepth survey of existing stops and seals and modify them as necessary to eflect the criteria established.

a are -" ~

' ~ a

• smv

~ ~

IF;I Fc,an 12 (J'..n 75) (Rcv)

~ C) Ua S ~ NUCLEAR REGULATORY COMMISSION

/

OFFICE OF XNSPECTXON AND ENFORCEI1EINT REGION I iIE Xnspection Report No: -2 7 7 Docket No:

Licensee:Cp License No'..

Priori ty.

Category:

Safeguards Group:

Iacacicn: ~Ind.', n P t

Type nx .Licensee: PER Bhv tI Type of Xnspect'on: S ecial, Announced D. s of Inspection: 4/29 30 5/1 2 1975 Dates of Previous Xnspection.'/8-9/75

~ A Reporting Inspector:

G. Napuda, Reactor Inspector.

Accompanying Inspectors.

DATE DATE ~

DATE Other Accotnpanying Personnel:

DATE Revieved By: J R. Haynes,

~

Senior Reactor Xnspcctor.

5-zx-DATE J

0

, SlRMXRY OF FINDINGS Enforcement Action A. Items of Noncompliance None S. Deviations None

'1'icensee Action on Previousl Identified Enforcement Items Not Applicable None Identified

'Unusual Occurrences Hone Identified Other Siznificant Findinps A. Current Findin s

l. 'cce table Areas

a. Correlation Between the Facilit 's Requirements and As-Built

Status for Fire Sto s on Electrical Safet -Related Cables and Penetration Seals A visual examination of the fire barrier and compartment seal installations and fire retardant coating applications +as performed by the inspector..

I There is correlation between the As-Built Status and the documented requirements.'Details, Paragraph 3.)

ilit

~ M b Invokement of Fac Reouxrements for Fire Stoos on Electrical S .Eetv-!'elated Cables and Penetration Seals in Haintenance and l.fodification Procedures An examin"tion was made of the maintenance and modification procedures for the installation of fire barriers and com-partment boundary. seals, and the application of fire-re-tardant coating for safety related cables. Present pro-cedures appear adequate to control maintenance or modifi-cation to fire barriers. (Details, Paragraph 4.)

B. 'Status of Previousl Reported Unresolved Xtems Not Inspected'ang ement Interview At the conclusion of the inspection, the inspector held a meeting at the site with'he following personnel to discuss the inspection findings:

'Consolidated 'Edison Comtian Mr. H. B. Byster, QA Engineer Hr. P. M. Duggan, Electrical Engineer Mr. J. Technical Operations Director

~

H. Makcpeace, 3 Mr. S. G. Salay, Station Vanlger Mr. R. A. Saya, Division Engineer The following items were discussed and the inspector's findings were acknowledged by the'licensee A. 'Pur ose of Inspection

'The inspector stated that the purpose of this special, announced inspection was to'examine the documented facility requirements for fire stops on safety-related cables and penetration seals, to visually inspect these i'tems for conformance with the requirements, to examine the licensee's provisions for invoking the requirments during maintenance and modification work and to determine the status of the licensee's efforts with respect to the a'ctions listed in IE Bulletins 75-04 and 75-04A.

0 I ~

s B, Current Findines: Acce table Area The'inspector stated that his review of the following areas revealed acceptable findings:

1, Correlation Between the Facilit 's Requirements and As-Built Status

'for Fi.re Sto s on Electrical Safet -Related Cables and Penetration Seals A visual examination was performed of the installation of fire barriers and compartment boundary seals, and the application of fire retardant coating, for safety related cables . There is correlation between this construction and the facility's documented requirements. (Details, Paragraph 3.)

2. 'Invokement o Facility Requirements for. Fixe Stops on Electrical Safct -Related Cables and Penetration Seals in ~~wintcn nce and

'Hodification Procedures An e>:amination was made of the'maintenance and modification pro-cedures for the installation of fire barriers and compartment seals, and the application of fire-retardant coating, for safety related cables. Present procedures appear adequate to control ma'intenance or modification to fire barriers. (Details, Paragraph 4.)

s C. 'Status of Licensee's Efforts re XE Bulletins 75-04 and 75-04A The licensee provided the'nspector with a status report on his efforts in complying with the requirements of IE Bulletins Nos.

75-04 and 75-04A. (Details, Paragraph 5.)

DETAILS

1. Persons Contacted Mr. 0. Buesse, Electrical Construction 'Superintendent Mr. P. M. Duggan, .Electr.cal Engineer Mr. J. M. Makepeace, Technical'perations Director

,Mr. T,. NcKernan, Electrical Engineer Mr. R. A. Saya, Division Enginner

2. General

a. Plant Status

.The plant was operating during-the inspection.

b. Pur ose of Ins ection Th'e purpose of this inspection was'o examine the documented facili.ty requirements for fire stops on safety-related cables and penetration seal , to visually inspect these items for conformance with the requirements, to examine the licensee's provisions for invoking tne requirements during maintenance and modification work and to determine the status of the licensee's efforts with respect to the actions listed in IE Bulletins 75-04 and 75-04A.

3. Correlation Between the Facilit 's Requirements and As-Built Status for 'Fire Sto s on Electrical Safet -Related Cables and Penetration Seals The inspector reviewed the licensee's Final Safety Analysis Report.

In response to NRC Question 7.6.d, page Q 7.6.(d) 1, which asks, in part: "Please discuss your criteria with respect to fire stops....

during design and installation," the licensee stated: "Firestops are provided where cable trays pass through walls and floors, and enter switch'gear or other equipment. Three 'types of firestops are used according to the function of the cable in the tray (control, power, etc.) and ventilation requirements of the areas involved. The first type of firestop is used in trays containing control cables passing through walls, floors, or into equipment where an* air seal is not required. It is composed to two aluminasilica ceramic fiber

blankets, 36 inches long, laid in'he tray and compressed around the cables using a cable tray cover. An ignited cable is extin-guished, by thi's firestop .because the ceramic fiber blanl et cuts off'he oxygen supply. The blanket has a low thermal conducti- .

vity and can. be used at temperatures up to 2300oF, without show-ing any g iysical,change. Even beyond that temperature, it still retains its 'fire preventive characteristics.

"Because of its low thermal conductivity and the fact that it covers three feet of cable surface area, this blanket cannot-be used .with power cables, which dissipate considerable amounts of heat. Xn addition,.it cannot easily be.inytalled in control -trays, where an air seal of the wall or floor .opening is required for

'ventilation purposes. The firestop used for these configurations consist basically of (1) a transite sheet, to substantially close the opening, (2) Flamemastic '71A Hastic sprayed on the cab'les 6" on either side of this sheet, and (3) Flamemastic 71A ~hstic trowelled into the cable tray on top of the cables to seal any remaining air passage bet'en rooms. Flamemastic 71A has re-cently been accepted and used by a number of uti.lities for this purpose. It is non-toxic, not damaging to cable insulation, and requires no.derating of cables when applied over a one-foot section. Tests by various power companies and cable manufacturers

..have'horn that a 1/16" coating of Flamemastic 71A will not burn through after 15 minutes exposure to a propane torch at 2050 F.-

"The third type of fircstop is used only for openings in the floor where control or power cables enter switchgear, motor control centers, supervisory cabinets', or other equipment from the tray below. This configuration combines packed fiberglass with 1/0" coating of Flamemastic 71A sprayed on either side of the closure . It provides both protection and separation of cables as they pass through the floor. This 'type of fire stop is used where control cables enter the panel in the contro1 .room."

The inspector requested all construction specifications and other applicable documents related to the installation of fire barriers and penetration seals. Specification "Indian Point No. 2 - Reactor Protection and Engineered Safety Feature Installation Criteria,"

dated 11/18/69 and Print >>o. 9321-F-3107-1 were provided to the inspector for his review.

The specification and print requirements complied wi'th the FSAR commitments. In certain instances, the specification requirements

'exceeded FSAR commitments: (1) Troughs entering equipment cubicles from the top and conduits entering cubicles form the bottom should be packed with fiberglass from the topside after the cable is pulledi and (2) only cable jacketed in fire-retardant insulation shall be procured for facility use.

The licensee identified all penetrations and electrical equipment on prints 9321-F-2503-9, 2510-16, 3052-16, 3059-11, 3060-18, 3063-18, 3081-19, 3089-28., 3107-4, 7054-12 and H-2250. These were reviewed and utilized by the inspector for his observations,

b. Observations (1) Frimar Auxiliar Buildin The cable and conduit floor penetrations in the Hotor-Control-Center cabinets were packed with fiberglass and vere sealed with Flamemastic., as required. i I

Other penetrations in the building were Flamemastic sealed and appeared to meet the transite sheet or fiberglass packing requirements, as applicable.

The splice boxes were Flamemastic sealed, where required.

Conduit passing through openings in walls or floor generally did not have the air spaces packed with blocking or sealing material. The licensee stated that a determination had been made that this vas not necessary and was therefore, not made a requirement. This condition was co.,~on throughout the facility.

(2) Control Buildin All floor penetrations entering equipment in the Control Room were sealed with Flamemastic, and sufficient evidence of fiberglass existed so that a determination cou'd be made that packing had been accomplished per requirements; Other penetrations in the building vere sealed with Flamem>astic and appeared to meet the transite sheet or fiberglass packing re-quirements.

Cables from trays entered equipment cubicles, sucha as the 480 V.

Switchgear, through a connecting trough or conduit.

All bottom entz'y conduits were packed with fiberglass and suffi-cient evidence existed to ascertain that this was also accompli-shed for top entry troughs.

(3) Diesel-Generator Room Conduits are =used exclusively within this room. The penetrations to the electrical tunnel, originally constructed for Unit 81, are not required to have fiberglass packing or sealing.

(4) Electrical Tunnel Host of the cables are contained within open tiays; nuclear instrumentation cable is enclosed in conduit. Hhere these trays and conduit penetrate walls, there is a transite sheet and Flamemastic seal. ,The cable that- enters the Diesel-Generator Room is enclosed in a conduit.

In addition to a water-deluge system, this area is provided with ionization and smoke-detector systems.

(5) General

. Extensive use of asbestos wrapping on cables within cubic'les, as required by the specification, was noted. Flamemastic has been applied to both sides of penetrations; the FSAR commit-ment was for such application on only one side.

The inspector reviewed purchase order/requisition numbers 05952, 05971, i'-36189, 6035, and .invoice numbers 7029, 7083, 7145, 7462, and 7481. The required fire-barrier material was purchased and delivered to the site during the construction

=period. Pages one through fix'e of "Tr,.cer Cable-Redundant Syst: em" check-sheets were reviewed by the inspector; This record indicated that spot inspections were performed to ascertain that a complete routing was to design requirements.

In the areas examined, the inspector noted that all non-safety related cables were protected with fire barriers in a fashion similar to that utilized for safety-related cables.

4. Invokement of Facilit Requirements for Fire Sto s'n Electrical Safct -Related Cables and Penetration Seals in >hintenance and Hodification Procedures The inspector reviewed Station Administrative Order No. 104-

Haintenance l~ork Request (~iGK) Procedure," and No. 127, "Hodifications to Indian Point Facilities." They require work instructions and provide control for maintenance and modification activities.

An instance of transite-barrier replacement occurred prior to the

'specific requirements established by these proce'dures. The activity was controlled under a maintenance work request procedure and documented on HMR 85N0485. The licensee stated construction specifications and prints were utilized as work instructions.

5~ Status of Licensee's Efforts re IE Bulle'tins~ 75-04 and 75-04A The insp'ector requested a status report from the licensee regarding IE Bulletins i5-04 and 75-04A. The licen ee provided the inspector .

with copies of two letters from Villiam J. Cahill, Jr., (Consolidated Edi.son Company) to J. P. O'Reilly (U.S .N.R.C.) dated April 10 and 23, 1975 which indicate that their efforts are expected to be com-pleted by 6/1/75.

I

4

'L IE:I For%1 12 (Jan 75) (Rcv)

Ua S. NJCLEAR REGULATORY CGl%1ISSION OPPICE OF INSPECTION AM) HiG:ORCEvfL'NZ

. REGION I IE Inspection Peport No: Docket No. 5 0-'2 9 3 Licensee: Boston Edison Company License No. DPR-35 800 Boyls ton S tr eet Priority:

Boston, Hassachusetts Nixie 02199 Category: C Safe~uards Group.

Type of Licensee'. Bl! R 678 Type of Inspection. Special Announced

. ies of Inspection: April '29-l'say 1, 1975 Dates of Previous Inspection. April 16-17, 1975 Reporting In pector: t '. 'r'. ~-44, ~..q ..-,.'.

'1 Star xbanp, Qaacto'r Inspactor ncconpnny9np Xnspactors: , . f 4>i'$+~+~3

.D. L. Chyhton, Senior Reactor Inspector Other Accompanying Per onncl:

DATE D. L. Caphton, Senior R actor Inspector

0 0

SUK'tARY OF FINDINGS Enforcement Action A. Items of Noncom liance None B. Deviations None .

Licensee Action on Previousl Ide>>tified Enforcement Items' Not Applicable Hone Identified Unusua3: Occurrences None Identified Other Si nificant Findin s A. Curr'ent Fi.ndinr s

1. Acce table Areas

a. -

Correlation Between the Facility's Requirements and As-Built Status for. Fire Stops on Electrical Safet -Related Cables and Penetration Seals A visual examination was performed of the installation of fire barriers and compartment boundary seals, and the application of fire-retardant coating, for safety related cables. There is correlation between this construction and the facility's document'ed requirements. (Details, Para-graph 3) b.

trical Safety-llelated Cables and Penetration Seals in l1ain-tenance and Hodification Procedures An examination was made of the maintenance and modification procedures for the installation of fire barriers and co)a-partment boundary 'seals, and the application of'fire-retardant coating, for safety related cables.'here is correlation

~

7, 1

between these procedures and the, facility's documented-require-ments. (Details, Paragraph 4}

2. Items Rc uirin, Follow-u

a. Lack of Correlation Between 'the .Facilit 's Re uirements and As Built Status 'i A During the visual examination described-in paragraph la,. a  :

lack of correlation was found between the construction and the facility's documented requirements. (Details, Paragraph 5)

. B, Status of Previousl Re orted Unresolved Items Not Inspected Hang ement Interview At the conclusion of the inspection,'he inspector held a meeting at the site with the following personnel to discuss the'nspection findings.

G. Baston, Pilgrim Division Head J. Smith, Pilgrim Division Head (as of Hay 1, 1975)

A. Horisi, Senior. Electrical Engineer S. Hartin, Process Engineer The following items vere discussed, and the inspector's findings were acknowledged by the licensee.

The purpose of this inspection was to examine the documented facility requirements for fire stops on safety-related 'cables and penetration seals, to visually inspect these items for conformance with the requirements, to examine the licensee's provisions for invoking the requirements during maintenance and modification work and to determine the status of the licensee's efforts with respect to the actions listed in IE Bulletins 75-04 and 75-04A.

B. Current Findin,s: Accc table Areas The inspector stated that his review of the following areas revealed acceptable findings:

1. Correlation Between'he Facilit 's Re uirements and As-Built St:atus for Fire Sto s on Elect:rical Sa'fet -Related Cables and Penetrat:ion Seals A visual 'examination was performed of t: he .installation of fiie barriers and compartment boundary seals, and the application of fire-retardant: coat'ng, for safety related cables. ,There

~

is correlation between this construct:ion and the facility's

'documented requirements. (D'etails, Paragraph 3)

2. Xnvokemen't: of Facilit Rectui're'nents for Fire 'Stops on Electrical Safet -ltelated Cables and Penetrat:ion Seals in Haintenance and Hoclification Procedures An examination was made of the maintenance and modification procedures for thc installation of fire barriers and compartment boundary seals,,and the application of fire-retardant coating, .

for safety .related cables. There 'is correlation between these procedures and the facility's documented requirements. (Details, Paragraph 4)

C. Items Pc uirin Follow-u The inspector. stated that the following items were observed and are considered to be unresolved:

1. Lack of Correlation Between the Facility's Re uiremc.nts and As-Built Status During the visual examination described in. paragraph Bl, a lack of correlation was found between the construction and the facility's documented requirements in one area. (Details, Paragraph 5)

D. Stat:us of Licensee's Efforts on TE Bulletins 75-04 and 75-04A The licensee provided the inspector with a status report on his efforts in complying with the requirements of ZE Bulletin Nos.

75-04 and 75-04A. '(Details, Paragraph 6)

E. Re ort bv Stat:e of Kentucky Relatin, to Pil,rim Shi in Cask Sent for Dis osal Containin Excessive lAster

/

The inspector discussed this item with the licensee and observed a typical cask and'the sealing and preparation for shipment. (Details, Paragraph 7)

P. Chan,e of the Pil rim Div'ision 1iead The licensee'reported a change in the Division lkead had taken place.

(Details, Paragraph 8)

G. Iodine Release Rate Information Re ort

~ -The licensee stated he was preparing an information report pertaining to the recent Iodine release rate situation. (Details, Paragxaph 9)

DETAILS 1.. Persons Contacted G. Baston, Pilgrim Division'ead J. Smith, Pilgrim Division Head (as of May 1, 1975)

S. Martin, Process Engineer J. Lucero, Health Physics Engineer

'J, Seery, Chief Technical Engineer D. Clark, Plant Engineer S. Nicholson, Chief Maintenance Engineer M. Roche, tiuclea'r Operations Manager V..Stagliola, Radwaste Engineer A. Morisi, Senior Electrical 'Engineer R, kennedy,'gA Administrative As'sistant J. Sullivan, Electrical Engineer

. '. General

a. 'lant Status Du'ring the inspection, the facility was in the process of returning power following a short maintenance outage.

b. Pur ose of Ins ection The purpose of this inspection was to examine the documented facility requirement for fire stops on safety-related cables and penetration seals, to visually inspect these items for conformance with the requirements, to examine tlie licensee's provisions for invoking the requirements during maintenance and modification work and to determine the status of the licen-see's'fforts with respect to the actions listed in IE Bulletins 75-04 and 75-04A.

3. Correlation between the Facilit 's Re uirements and As-Built Status for Fire Sto s on Electrical Safet -Related Cables and Penetration Se"ls (1) The plant was built in accordance with Drawing E-347, "Conduit and Cable Tray Notes, S>mbols, and Details."

Revision 36 was used as .the'basis for this inspection.

'(2) . The basi'c requirements p~rtaining to penetration sealing.

are presented below along with paragraph number reference to the specifi (and detailed) requirements.

(a) All cable openings in walls and floors shall have fire stops installed. (Paragraph 12)

(b) .The=inside of all block-out openings down to the conduits, conduit sleeves and,tray enclosures shall be completely filled with solid concrete .matching the thickness of the floor and as a minimum 6" in

,walls. (Paragraph 12A & 128)

(c) Conduit sleeves (Vertical Penetration)

(I) Base of Kaowool or non-burning Hinitfoam.

(IX) 4-6 inches of foam on the base.

(III) minimum 1 inch of non-shrink pourable grout (Paragraph 12Al)

I (d) Cable Trays (Vertical Penetration)

(I) Packing, foaming and grouting requirements similar to (c) above. (Paragraph 12A2)

(e) Conduit sleeve (Horizontal Pcnetrations)

(I) A minimum of 6 inches of foam in the center of-the wall thickness, II At least six inches of air space on each side of the penetration.

XII Kaowool optional on one side to 'ensure minimum of six inch air space.

IV If less than 6 inches results, use 1/8 inche layer of Plan!emastic 71A. (Paragraph 1281).

(f) Cable Trays (I) The foaming requirement and packing options are similar to those in (e) above. (Paragraph 12B2)

b. Observations (1) All accessible penetrations were inspected. Except as noted in paragraph 5, no problems were identified.

(2) The following represents a summary of the areas and penetrations inspected.

~Bld; Elevation Room Wall,'loor or Ceilin No. of Penetration

'RB 51 , .East, Wall F&U 80 RB 51 South Hall F&U 66 RB 51 West Wall F&U '50 RB 51 Recirc HG F&W 105*

~

RB 74 84 Fan Room p 16 RB ~

74 . 83. Fan Room F 8 .

RB 74 East Wall F&W 20 RB 74 North Ilail F&U

.RB 7.4 South Wall p 41 RB 91 East Wall p 16 RB 91 86 Fan Poom F&W 26 RB 91 North Hall F '4 RB. 91 South Hall F&W 22 RB 117 East Uall F 38 RB 117 Spent tuel Pool F 12 RB 117 West Wall. F 28 p-

'B 117 South Wall ~

44 RB 23 Hast Wall F 124 RB 23 North Wall F&W 2 RB 23 West Wall F&U 69 RB 'B 23 South Wall F&W 16 RllR Quad. A F&U&C 1OO*

RB CPJ) Quad. F&U&C 50*

RB RllR Quad. B, F&U&C 50*

RB RCIC Quad. F&U&C 65*

Intak e Struc all F&W&C 160 RB. Diesel Gen. A F&W&C 34**

RB Diesel Gen. B F&U&C 56*x RB Hake up Demin F&U 80 Tux'bine Bldg. Ilouse Boiler F&U 44 51 SBGT Room F&U&C 20 Radvaste Area F&U 150 II II Turbine Deck F&W 50.

Control Room F 250 Cable Spreading Rm F&U&C 280I'I It'Areas so marked contained some penetrations vith poor'ccessibility but no problems vere obvious.

• >Certain penetrations in these areas appear to have a silicone (RTV) type material used for sealant. (See Paragraph 5 for discussion)

4. Invokcmcnt of Fe'ciiitrtke circments for Tire Sto s on Electricel Safet -Related:Cables and Penetr'ation Seals. in Maintenance and Modification Procedures a~ Discussions with the Chief Maintenance Engineer indicate that all maintenance work is accomp'lished in accordance with the re-quirements of the E-347 drawing vith the objective being to maintain the plant as it was built.

i

b. Discussion vith the Senior Electrical Engineer responsible for the High Energy Pipe Break cable, modification also indicate that the E-347 drawing vas used as the basis for the statement of work to the contractor'erforming the work. He stated that work is being accomplished 'in accordance vit:h this drawing.

5. Items Re uirin Follow-uo This section of the report documents and serializes matters of inspector's concern vhich vill be investigated by the licensee and inspected and closed out in a subsequent inspection.

75-11-1 Draving E-347, Paragraph 12.A.(1)(b) and 12.B.(1) (a) require the use of "rigid closed cell type ureth ne foam with "non-burning" flame characteristics as defined in ASTM Designation D1692-59T (Minit-Foam by Kerr Chemical or approved equal)." A review of purchase orders in 1971 and 1972 indicate a "Self-extinguishing type of foam vas procurred. The licensee st'ated he will identify the type of. foam used and its adequacy and compliance with the ASTM standard and review the E-347 drawing in use during 1971 and 1972 to determine if "Self-extinguishing foam" was called for.

75-11-2 The inspector noted that certain penetrations in the Recirc MG room and the Diesel Generator rooms were sealed vith a silicone material. The licensee stated he will review the use and adequacy of this material.

75-11-3 The inspector identified 4 penetrations in the Reactor Build'ng which are part of the High Energy Pipe. Br ak modification which are not yet sealed with cement. The licensee stated work is in progress to have this work finished and that it should be 'finished by about May 17, 1975.

6'. Status of T.icensee's Efforts reference IE Bul].ctins 75-04 and 75-04A The inspector was provided i~ith a copy of the response letter to Bulletin 75-04A. This contained a schedule for accomplishment of the, requ'red action and'he licensee stated this action is is progress and the dates i.ndicated will be met. All required action vill be completed by June 25, 1975.

7.,~Re ort .h State of 1:entnckr Relatino to Pilatin Shi in Cask Sant

. The inspector received word on site that a cask containing spent Diatomaceous Earth (DE) vas received for disposal by a site in Yentucky with excessive water. 'The inspector examined a similar cask and the lid used to seal the cask. )le also discussed with the licensee the procedures used in the filling and verification that the cask is dry prior to shipment. The licensee stated that the material shipped is essentially dry and he cannot understand the source of water. found in the cask. He plans to investigate this matter and review the procedures used in shipments of this nature to preclude the possibility of a similar event. The inspector stated an inspection of the circumstances surrounding this event would be conducted in the near future.

ga Chancre of Pil rim Division llead On Hay 1, 1975 Hr. James A. Smith replaced Hr. Grant Baston as Pilgrim Division Head. The inspector met Hra Smith and discussed the current inspection program and was informed that an orderly transition period was expected.

9. Iodine Release Rate Information Re ort The licensee informed the inspector that high Iodine release rates were being experienced from the Reactor Building vent. He stated that different measures vere being taken to correct this situation and although no Abnormal Occurrences had taken place an Information Report detailing the recent events and the current and planned corrective actions would be made to t)ie NRC by Hay 2, 1975. The inspector acknowledged this.

IE:I Form 12 (Jan 75) gcv)

U S NUCLLt& REGULATORY CO.QtXSSXON v

e ~ 4 ~

OFFICE OF XNSPECTXO"i AND., ENFORCEfENT REGION I IE Inspection Repoit No: . 50-271/75-03 Docket No: 50-271 icensee: Vermont Yankee Nuclear Power Corporation License No: DPR-28 20 Turnpike Road Priority:

Westborou h.

Vermont'ategory:

M~

Safeguards Group:

Location.'ernon Type of Licensee: Eb'R (1593 >fw Th TyZ )f Xnspection: Special, announced ates of Inspection: ~y 6 6 7:, 1975 I

Dates of Previous Inspection:

Repor ting Xnspec tor:

L.

m4, W. Gage, eactor Xnspector 5r -/

DATE Accompanying Inspectors:

DATE

. DATE DATE Other Accompanying Personnel:

DATE Reviewed Sy:

p'.,

~ G C. Haynes, Senior Reactor Inspector a, c r vz'e w " 't 'r ~ ~ nt 'vrv'r V' * ' ' +sv ' "' ag 'e + V' 'o I

v;g,g

S'R&fARY OF FINDINGS

~ t Enforcement Action A. Items of Noncompliance None B. Deviations None Licensee Action on. Previousl Identified Enforcement Items Not applicable None identified Unusual Occurrences Hone identified Other Si ificant Findin s A. Current Findin s

1. 'cce table Areas a, 'orrelation Bet<<een the Facility's As-Built Status for Fire Sto s on Electrical Safet -Related Cables and Penetration Seals.

A visual examination was performed of the installation of fire barriers and compartment boundary seals, and the application of fire-retardant coating, for safety related cables. There is correlation between this construction and the facility's documen-ted requirements. (Details,'aragraph 3.)

I

2. Unresolved Items a, Invokement of Facility Requirements for Fire Sto s on Electrical I

'afet -Related Cables and Penetration Seals in Maintenance and Modification Procedures.

~s

During the examination described in paragraph A.l.a, a lack of documented coverage was ascertained for main-,

tenance and modification procedures for fire stops on electrical safety-related cables,and penetration seals'.

(Details, Paragraph 4;)

B. Status of Previousl Re orted Unresolved Etems Not inspected Mana ement interview At .the conclusion of the inspection,,the inspector held -a meeting .at the site with the following personnel to discuss the inspection findings:

Vermont Yankee Nuclear Power Corporation Mr. George Thomas, Assistant Plant Superintendent Mr. Warren Murphy, Engineering Support Supervisor The following items were discussed-, and the inspector's findings were acknowledged by the licensee:

t s

A. 'Pur ose of 'the Inspection 3

~ The inspector stated that the purpose of this special, announced inspection was to examine the documented facility .requirements for fire stops on safety-related cables and penetration seals, to visually inspect these items for conformance with the requirements, to examine the licensee's provisions for invoking the requirements during maintenance and modification work and to determine the status.

of the licensee's efforts with respect to the actions listed in.

IE Bulletins 75-04'and 75-04A.

3. Cur'rent Findin s: Acce table Areas-e The inspector stated that his review of the following area revealed acceptable findings:

Correlation Between the Facilit 's Re uirements and As-Built Status

'or Fire Sto s on Electrical Safet -Related Cables and Penetration Seals.

A visual examination was performed of the installation of fire barriers and compartment boundary seals, and the application of fire-retardant coating, for safety-related cables. There Xs correlation between this construction and the facility's documented requirements. (Detail's, Paragraph 3.)

C. Unresolved Items

~

The inspector stated that the following item was observed and is is considered to be unresolved:

Invokement of Facilit Requirements for Fire Stops 'on Electrical Safet.'-Related Cables'and Penetration Seals i'n i~mintenance and Modification. Procedures

.During the examination described in .paragraph B, a lack of documented coverage was ascertained for maintenance and modification procedures for fire stops on electrical safety-related cables and penetration seals. (Details, Paragraph 4.)

D. Status of,Licensee's Efforts .re IE Bulletins 75-04 and 75-04A The licensee provided the inspector with a status report on -his efforts in complying with the requirements of IE Bulletins bos; 75-04 and 75=04A. (Details, Paragraph 5.)

Q

~ \9 ~

DETAILS 1, Persons Contacted Vermont Yankee Nuclear Power Corporation Mr. Marren Murphy, Engineering Support Supervisor Mr. Milliam Hittmer, Technical Assistant

2. General

a. 'lant Status The plant was operating during the inspection.

b. Pur ose of Ins ection

'V

. The purpose of this inspection was to examine the documented facility requirements for fire stops on safety-related cables and penetration seals, to visually inspect these items for-conformance with the requirements, to examine the licensee's provisions for invoking the requirements during maintenance and modification work and to determine the status of the

.3icensee's efforts with respect to the actions listed in IE Bulletins 75-04 and 75-04A.

3. Corrdlation Between the Facility's Re uirements and As-Built

'Status for Fire Stops on Electrical Safet -Related Cables and

'Penetration Seals less' The inspector reviewed the licensee's Final Safety Analysis Report. On response to this NRC question (Number 7.5 on page I.2-50, dated 10/23/70): "Submit the cable installation design criteria...The discussion of cable installation criteria should include: .... Criteria with respect to fir'e stops...,"

the licensee stated:

"Fire stops are provided in vertical tray runs at floor lines ol at 10 foot intervals, whichever is "

Ol The inspector requested all construction specific actions'nd other applicable documentation related to facility requirements for fire stops on safety-related cables and penetration seals.

The licensee provided a procedure, titled, "Ebasco Services Incorporated, Vermont Yankee Nuclear Power Station, Cable Pulling, Terminating, Cable Tray, Conduit and i~larking System Procedure," dated 11/9/71. This procedure states, in a paragraph titled "Fire Barriers

<<Pire barriers are to be installed whenever a tray penetrates a floor or wall. The fire barrier shall extend along the cable tray for a minimum distance of 4 inches.

itA11 cable trays entering the cable spread room shall have fire barriers extending from the'all for a minimum distance of three feet..

<<79xe barriers are to be installed at all the control room floor penetrations. (To act as a seal against ingress of C 02 from the cable vault fire protection system.)

~ I

'Xn all vertical tray runs fire barriers shall be installed at reasonable intervals, say at 10 ft. spacing.

uThe fire barriers should be formed from "FLANK'fASTIC 71A" applied over fiberglass wadding. Application can be made e'ther by spray-ing or spreading with a trowel depending upon the location.

"FLQG2fASTIC 71A" is manufactured by the Dyna-Therm Corporation.

The licensee stated that this procedure was the only documentation at the site related to facility requirements for fire stops on safety-related cables and penetration seals.

Observations The inspector visually inspected all safety-related cable penetra-tions, except those which could not be examined without (1) inter-fering with the operation of the facility, or (2) removing material and equipment previously installed. Floors, walls, and ceilings were examined in the following areas: control room, cable vault, high-voltage switchgear room, reactor building (at elevations 345',

318', 303', 280', 252', and 213'), turbine building (operating floor, ground floor, and basement), and pump house.

~ ~

~

The inspector found'ire barriers installed wherever safety-related cabling penetrated floors, walls, and ceilings. In the vast ma5ority of instances, the fire barrier was as described in the licensee's procedure: Flamemastic 71A applied over fiberglass wadding.

In a minority of instances, the inspector found that the licensee used Crouse-. Hinds Company's "Chico A5" sealing compound. The catalog specification for this compound states that it is "... a seal whi'ch withstands pressure several times greater than the explosion pressures met in

~

conduit systems, stops the passage of flames, and prevents leakage of unexploded gas from hazardous to non-hazaidous areas."

In a few instances, the inspector found that the licensee used Plamemastic 71A applied over grout.

The cable trays in the cable vault aze covered, top and bottom, with sheet-metal plates. The cable vault also has a C 02 fire-suppression system. Windows from the computer room, which are normally open and vent into the cable vault, are designed to automatically close when the C 02 system is operated.

When covered cable trays pass through walls or floors, the fire barriers are normally inside the cable trays. Evidence that these barriers exist can usually be determined'y looking through louvers in the cable-tray covers or (where

-practical) by lifting the covers..

The inspec'toz found three instances where the licensee had performed some maintenance or modifications, disturbed the fire barrier, and had not repaired it:

(1) The base of a cabinet in the control room, located near the south wall, between columns 13 and 12.

(2) A floor penetration in the cable vault, located'.near the north wall> near a reactor protection motor.

(3) A wall penetration in the reactor building, seen from the catwalk above the 213'levation, penetrating the residual-heat-removal exchanger room at approximately 60 on the floor plan.

The licensee stated that all of the distrubed fire barriers would be repaired.

4 ' Invokement of Facility Re uirements for Fire Sto s on Eleciri'cal Modification Procedures The inspector determined that, other than the Ebasco construction procedure described in Details, paragraph 3.a., the licensee did not have any maintenance or modification procedures for fire stops on electrical safety-related cables. and penetration seals. The inspector further determined that this Ebasco procedure was not designed to insure satisfactory tracking and close-out of penetration modifications such as the three instances described in Details, paragraph 3.b.

The licensee stated that'e was presently involved in a program to review methods and materials for cable-penetration sealing, and expected to complete this review by ~ofay 15,'1975. He further stated that all future penetration repairs and modifications would be handled in accordance with the procedure used to carry out design changes ("Design Changes Review and Approval," No. A.P. 032, Rev. 3, presently being revised); fol'lowing this procedure would insure satisfactory tracking and close-out of penetration modifications.

This item is considered to be unresolved, pending review by an HRC inspector of the program developed by the licensee for cable-penetration sealing and of his revi ed design-change procedure.

5. 'tatus of Licensee's Efforts re IE Bulletins 75-04 and 75-04A The inspector requested a status report from the licensee regarding IE Bulletins 75-04 and 75-04A. The licensee provided the inspector

. with a copy of a letter, Ho. MVY 75-43, dated April 24, 1975, from J. L. French (Xankee Atomic Electric Company) to J. P. O'Reilly (U.S.N.R.C.). This letter provides a schedule for eleven different types of surveys and reviews being conducted by the licensee in response to Bulletins 75-04 and 75-04A. The first plant surveys are scheduled for completion on 5/15/74; the final plant policy '

review is scheduled for completion on 9/30/75. '

p ~/jj~j IE'I 'Foun 12

(~an 75) gcv)

Ue S'UCLEAR REGULATORY 'CO~QlISSION OFFICE OF INSPECTION AND ENFORCI'fENT REGION I Insp ec t ion Fiepo rt No ~ 50-289/75-10 Docket No: 50-289 Licensee: Hetropolitan Edison Company License'o':

P. 0. Box 542 Priority:

~

Reading, Pennsylvania 19603 C Category:

Safeguards KMdletotm, Pennsylvania, 3 5Lil.e Island 1 Group:

Loca tion:

Type of Licensee,: ,PER B&H (871 li"~'e)

Tyoe of Inspection. Special, Announced 1

D, s of Inspec tion: thy 8, 9 & 12, 1975 oz'-7 Dates of Previous Inspection. April 15, 1975 Reporting Inspector: 7-7~

. Napuda, Rqactor~ lnspec DATE Accompanying Insp'ec tors: NONE.

DATE DATE DATE Other Acconpanying Personnel: NONE Reviewed By:

R. 1laynes, Senior 'Reactor Inspector DATE

~:)

~ g ~

~ ~

SKDfARY OF FINDINGS Enforcement Action A. Items of'oncom liance None

. B. Devi.at ions None Licensee Action .on Previousl Identified Enforcement items Not Applicable None Identified Unusual Occurrences None Identified Other Si~nificant Findin s A. Current Findin s

l. Acce table Areas

a. Correlation Between the Facility's Requirements and As-Built Status for Fire Stops on Flectrical Safet-Related Cables and Penetration Seals A visual examination of the fire barrier and compartment seal installations and fire retardant coating applications was performed by the inspector. There is correlation between the as-built status and the documented require-ments. (Details, Paragraph 3)

b. Invokemont of Peeilit Requiremente for Fire Sto' on Electrical Safety-Related Cab)cs and Penetration Seals i, ?hintenance and t<<odiCication Procedures The procedure that controls maintenance, modification, and

. repairs and a recently'pproved'work instruction written specifically for installation and repair of fire barriers were reviewed. They appear to adequately control activi-ties 'in the subject areas; (Details', Paragraph 4)

~ ~

e B. Status of Previousl Reported Unresolved'tems Not Inspected Hang ement Interview At,the conclusion of the inspection, the inspector held a me ting at the, site wit?i the following personnel to discuss the inspection findings:

• Metro olitan Edison Company J. Co'z, Unit Number One Superintendent C. E. Hartman, Electrical Engineer J. Herbein, Station Superintendent G. ?uy, Senior St" ff Engineer W. E. Potts, Quality Control Supervisor Gilbert Associates P. Shipper, Project Electrical Engineer'he following items were discussed and the inspector's findings were acknowledged by the licensee.

A. Pur ose of Ins ection The inspector stated that the purpose of this special, announced inspection was to examine the documented facility requirements for, fire tops on safety-related cables and penetration seals",

to visually inspect these items for conformance"with the require-ments, to examine the licensee's provisions for invoicing the requirements. during maintenance and modification work and to determine the status of the licensee's eZforts with respect to the actions listed in IE Bulletins 75-04 and 75-04A.

1 B. Current Findin s: Acce tabIe Areas The inspector stated that his review of the following areas .re-vealed acceptable findings:

e

1. Correlstion Detnoen the Pecili~t 's Reouirer e.n.ts nnd As-Built Status fox' ire Stons on Electrical Safct -Related Cables and Penetration Seals A visual ezamination was performed of the installation of fire barriers'and compartment boundary seals, and the application of fire, retardant coating, for safety related cables. There is correlation between this construction and the facility's requirements. (Details, Paragraph 3) docu-'ented

2. Invokement of Facilit Requirements for Fire- Stops on Electrical Safety-Rel"ted Cables and Penetration Seals in Maintenance and hfodification Procedures The procedure that controls maintenance, modification, and re-pai'rs and a recently approved work instruction written specifi-cally for 'nstallation and repair o .fire barriers were reviewed.

eThey appear to adequately control=activities in the subject areas. (Details, Paragraph 4)

C. Status of Licensee's Efforts re IE Bulletins 75-04 and 75-04A The licensee provided the inspector with a status report on his efforts in complying with the requirements of IE Bulletins Nos.

75-04 and 75-04A. (Details, Paragraph 5) s

'r I

e I

F 1'II

's

.I

)

~ e fwAt r ' r '~7~' .1

DETAILS

l. Persons Contacted

>Ietro olitan Edison Com an C. Hartman, Lead .Electrical Engineer G. Hay, Senior Staff Engineer J. Zenyuch, Student Engineering Trainee Gilbert Associates V. A. Brannen, Supervisory Fire and Safety Engineer P. Shipper, Project Electrical Engineer

.2. General

a. Plant Status The plant was operating during the inspection.

PUL osc oa Insuection The purpose of this inspection was to examine the documented faci3;ity requirements. for fire stops on safety-related cables and penetration seals, to visually inspect these items for conformance with the requirements, to examine the licensee's provisions for invoking the=require..ents during maintenance and modification work and to determine the status of the licensee's efforts with respect to the actions listed in IE Bulletins 7S-04 and 75-04A.

3. Correlation'Between the Facilit 's Re uirements and As-Built Status for Fire Stcns on Electrical Safet -Related Cables and Penetration Seals Re uirements The inspector reviewed the licensee's FSAR, Paragraph 8.2.2.ll.b states: "Fire barriers are used at cable trays. and cable runs where they enter or leave a Class I area. There will be fire barriers where the cable trays enter the control and auxiliary buildings and where vertical trays'ass through floor openings".

A The inspector requested all construction specifications and other applicable documentation related to facility require-ments or fire barriers'n safety-related cables and penetra-tion seals. 'The inspector was provided with and reviewed Specification SP-5616, Revision 2 and Prints 4192-E-214-011, E-215-011, C-201-128, C-201-129, and S-201-121.

fire barriersI These documents describe the following types of and where they are installed:

(1) Trays penetrating metal walls: Kaowool packed, encased

..in a rectangular sheet metal sleeve, with a marinite board on one side of the wall.

(2) Trays penetrating Class T. building (e. g., Control Build-ing and Intermediate Building): exterior concrete walls Kaowool packed, with metal covers bolted onto the angle iron which frames the exterior side of the penetration.

'Voids under the cover to be filled with Flamemastic, without intending to provide an air seal.

(3) Trays penetrating interior walls: Kaowool packed, with the packing extending six inches from both sides of the wall, supported by the tray construction.

(4) Cable penetrations in the Control Room floor, for elec-trical equipment cubicles: Kaowool packed, with 'a Marinite board on both sides of the penetration.

(5) Vertical penetrations: Kaowool packed, and the tray pro-vided.with a cover for approximately six feet above floor level.

The licensee had identified all penetrations and electrical equipment locations on Prints 4912-E-214-014, -022, -023,

-024, -025, -026, -034, -036, -037, -038, -041, -042, -226

-105 and D-214-.035. The inspector reviewed and utilized these for his observation.

Observation (1) Auxiliar Buildin The inspector found that the fire barriers conformed'o specii ica tion requiremcn ts.

Where cables exited the building through sleeves, "Dux-seal" was used to seal the opening.'The required Harinite board fire barriers between re-dundant channels, on-elevations 281 and 295 were noted by the inspector)..

(2) Control Buildin The inspector discover'ed that the top marinite board had been omitted from the Control-Roon-Cubicle floor pene-trations. The licensee produced Engineering Change .'temo S/N 432 which permitted the penetration to have a marinite board on only the bottom side. The installation of fire barriers appeared to be acceptable.

(The inspector noted that armored cables served "the CRD strip breakers).

(3) Intermediate Buildin The fixe barrier installations appeared to conform to the requirements.

(The inspector observed the required liarinite board fire barriers between redundant channels, on elevation 295 and noted metal fire doors on the Emergency Diesel Pump Rooms) .

(4) Screenhouse The inspector found that the fire barriers conformed to requirements.

(5) General The inspector noted the occassional application of Plane-mastic on interior wall penetrations. The licensee stated this was done in certain cases to hold the Kaowool together and not for sealing purposes. /

I I

I S

2 The irispector'also noted the widespread use of Flame-mastic, troweled onto penetration covers.

Tace inspector noted the general practice packi".g the penetrations, through which conduits passed, with Kao-wool. Kaowool.was also packed into conduits at their entzy point into cubicles.

i A water-deluge system is provided and protects, areas including the Cooling Tower,, Diesel-Generator, Oil Reservoir, Service Bui1ding,,Intake Screen House, Charcoal Filter, and Hea'jt'h Physics axeas.

The licensee stated that an automatic C02 fire suppres-sion system has been designed for. the cable spreading and xelay areas and preparatory work is underway.

The licensee a3so stated that no PVC jacketed cable was used inside the facility, and produced "Z1 -E!: Bill of M'aterials" that appeared to confirm that only fire-retar-

'ant insulated cable'was purchased and used.

The 5aspectoz reviewed Purchase Orders 9459-01-63618,

-63"30, -63850, -64900, -64932, -65251, and -65279. They confirmed that the required fire-barrier material had been purchased during constzuction.

.The inspector noted that the non-safety rel'ated cabling appeared to be pzotected .by similar fire stops and pene-tration seals.

4. Invokcment of Facilit Renuirements for Fire Stops on Electrical Safet -Related Cables and Penetration Seals in ~Laintenance and Modification Procedures The inspector reviewed "Station Administration Procedure 1016" which specifies that all'required maintenance, modification, and, x'epair work must first be entered on a "Work Request For ". .his is reviewed by Supervision. Safety related items are identified and reviewed by whomever is necessary, including the Quality Assurance group. All work must be performed to a written woxk

,instruction and inspected by the foreman (and, when applicable, Quality Control). Work Requests .Numbers.2745, 2746, 3353, .359 ,

4278, 4661, 4796, 4873, and 6335 were inspec'ted and followed the procedure.

~

The inspector reviewed "(cwork Request Procedure-. Installation/Repair of cable tray and conduit Pire Barriers, 1420-FB-1" dated Hay,

~

1975. It appears to adequately control activity in the subject area+

5. Status of Licensee's Efforts re I .'04. and 75-04A The inspector requested a Status Report from the licensee regarding IE Bulletins 75-,04 and 75-04A. The licensee provided .the inspector with a letter dated April 28, 1975 from M. H. Creitz (Hetropolitan Edison Company) to J. P. O'eilly (U.S.N.R.C.) containing two

. encl: ~ures which answered al1 but Item 4 of Bulletin 75-04A. A review of this .item is underway by the licensee; the results will be reported to N.R.C. by Hay 23, 1975.

0

IE

I Form 12 l (Jan 75) (Rev)

Uo ST NUCLEAR REGULATORY COlQHSSION

~ 4 ~

OFFICE OF INSPECTION AND EiiFORCPfENT REGION I

'E

'icense Inspection Report No: 50-29/75-05 Docket No:

Licensee: Yankee Atomic Electric Comnanv No: DPR-3 20 Turn ike Road Priority.'ategory:

Vestborough, 5fassachusetts 01581 C Safeguards Group..

.'ocation: (Yankee Rove)

~

Type of Licensee: PLJR 17 NJ tJ

, Type of Inspection. S ecial Announced ~

'im of Inspection: Ha 5 1975

! Dates of Previous Inspection: 3/ll/75 3/13/75 Reporting Inspector: rg drI Jacq e Durr, Reactor Inspector g)AT .

Accompanying Inspec tors:

DATE DATE DATE Other Accompanying Personnel: None DATE Reviewed By: -/ 1-~.0 R. C. 1laynes, Senior Reactor Inspector DATE

SRQfARY OF FINDINGS Enforcement Action A.'tems of Noncom liance None B. Deviations None Licens'ee's Action on Previousl Identified Enforcement Items Not applicable None identified Unusual Occurrences None identified Other Si nificant Findinps A. Current Findin s

l. Acce table Areas

a. Correlation Between the Facility's Re uirements and As-13uilt Status for Fire Sto s on Electrical Safety-Related Cables

'"and Penetration Seals A visual examination was performed of the installation of fire barriers and compartment boundary seals, and the application of fire-retardant coating for safety-related cables. There is correlation between this construction and the facility's documented requirements. (Details, Paragraph 3)

b, Xnvokamant ot'Pa ailit~vRe uiramants for Fiva Stops on

'Electrical Safety-Related Cables and Penetration Seals in Maintenance and Modification Procedures There are no x quirements for fire stops in this plant and, therefore, they are not addressed in the maintenance and modification procedures. (Details, Paragraph 4)

2. Uniesolved Items Hone B. Status of Previousl Re orted Unresolved Items Not inspected Mana ement Interview At the conclusion of the inspection the inspector held a meeting at the site with the following personnel to discuss the inspection findings: I Yankee Atomic Electric Comnan Mr. H. Autio, Plant Superintendent Mr. H. Jones, Assistant Plant Superintendent Mr. J. Thayer, Assistant Engineer Mr. P. Laird, Maintenance Supervisor The following items were discussed and the inspector's findings were

'acknowledged by the licensee.

A. Pur ose of the Ins ection The inspector stated that the purpose of this special, announced inspection was to examine the documented facility requirements for fire stops on safety-related cables and penetration seals, to visually inspect these items for conformance with the requirements, to examine

-the licensee's provisions for invoking the requirements during maintenance and modification work and to determine thc status of the licensee's efforts with respect to the actions listed in IE Bulletins 75-04 and 75-04A. (Details, Paragraph 2.b)

B. Current 1'indin s: Acce tab'le Areas The inspector stated that his review of the following areas re-vealed acceptable areas:

W3M

-1. Correlation.Between,the Facilit 's Re uivemcnts and As-Built Status for Fire Sto s on Electrical Safety-Related Cables and "Penetration Sea1s

,,4 y

The inspector performed a visual examination of all tray penetrations within the scope of the inspection and safety-related'able found the flame barrier requirements were met. (Details, Paragraph 3) I

~ ~

2. Invokement of Facility Re uirements .for Fire Stops on Electrical Safet .-Related Cables .and Penetration'ea1s in .Maintenance .and Modification Procedures The inspector stated that fire stops are not addressed in maintenance and modification procedures. However, there are no requirements for them. (Details, 'Paragraph 4)

3. Status of Licensee's Efforts re Bulletins 75-04 and 75-04A The licensee provided the inspector with a status report of his efforts to comply with IE Bulletins '75-04 and 75-04A.

(Deta'ils, Paragraph 5) 1

DETAILS

1. Persons Contacted Yankee Atomic Electric Com an Mr. H. Autio, Plant Superintendent .

Mr. W. Jones, Assistant Plant Superintendent Mr. J. Thayer, Assistant Engineer Mr. P. Laird, Maintenance Supervisor

2. General

a. Plant Status The plant was operating during the inspection.

'L

b. Pur ose of Ins ection The purpose of this inspection was to examine the documented facility requirements for fire stops on safety-related cables and penetration seals, to visually inspect these items for conformance with the requirements, to examine the licensee's provisions for invoking the requirements during maintenance and modification work and to determine the status of the licensee's efforts with'respect to the actions listed in IE Bulletins 75-04 and 75-04A.

3. , Correlation Between the Facility's Requirements and As-Built Status for Fire Stops on Electrical Safet -Related Cables and Penetration Seals The information for the installation of cable trays is found on the plant drawings. An example of this can be found on plant drawing number 9699-FE-36G-. 7 which has details of specific penetration construction.

The normal penetra'tion is depicted as going from cable trays into conduit sleeves through floors and walls.

There are no requirements for flame barriers or fire retardant coatings on the drawings or in the FSAR.

&I

b. Observations The inspector examined the following ar'eas,with the results indicated: 'W

/J (l) Control Room (a) Main Console The cables pass through slots cut in the floor. All penetrations were sealed with duct seal from above and a fiber-glass type insulation from below.

(b) Safet In ection Cabinet The penetrations are conduit sleeves through the floor. All penetrations were sealed with a fiber-glass type of insulation; (c) Control Room Walls Several cable trays pass through the floor against the walls. The fit up between the cable trays and floor was very close. The front side of the trays were covered with sheet metal while the backside (approximately 3 inches from the wall)'as open. The inspector could not ascertain if flame barrier material was installed. The licensee stated that flame barrier material was installed.

The inspector took a small sample of the fiber-glass type insulation and applied a flame to it. It would not burn.

(2) Switch Gear Room This room is directly below the main control room and all wall penetrations are either conduit or cable tray to conduit sleeves. Cable tray penetrations through the ceiling are closed with Masonite Board'nd duct seal compound.

(3) Ca'bio Tra 1louse This room is directly above 'the control room and most cabling-to-primary-containment penetrations pass through

, here. All cabling comes up. through the floor through conduit sleeves. There is no insulation material packed in these sleeves.

..ry The reactor coolant pump leads are asbestos-cloth ~rapped for additional protection.,

(4) Primar Auxiliar Buildin All areas had the cabling enclosed in conduit except for several runs of mineral insulation cable in cable trays.

(5) Safet In ection Building All areas had the cabling enclosed in conduit. However, there is an area, "Manhole 83", which is all safety injection cabling. that transitions from underground conduits to @bort sections of unprotected cables and then back to conduits.

(6) Emer encv Diesel Generators Nos. l, 2 and 3 All cabling is enclosed in conduit. Each diesel-generator is in a separate room with interconnecting fire doors.

Screen House All cabling is enclosed in conduit.

Additional-Features Smoke Detection S stem A smoke detection syst: em has been installed in the following critical areas:

(a) Cable Tray House (b) Hain Control Console (c) Switch Gear Room (d) Control Room Ceiling (e) Safety Injection Building (f) Vault (documentation)

4. Invokement of Facilit Rcruirements for Fire Sto s on Electrical Hodification procedures I

The inspector determined that the licensee did got have any maintenance or modification procedures for fire stops on electrical safety-related

~ ~ ~

cables and penetration seals. The inspector further determined that there 'were no requirements for fire stops in the plant speci-fications, drawings and FSAR.

~I

5. Status of Licensee's Efforts re IE Bulletins 75-04 and 75-04A The inspector requested a status report from the licensee regarding XE Bulletins 75-04 and .75-04A. The licensee stated that a survey of the requirements of Bulletins 75-'04 and 75-04A relative to the plant has been made and an evaluation is in progress. (The licensee has mailed the NRC a letter, No. VYR 75-47, dated April 24, 1975, from J. L. French (Yankee Atomic Electric Company) to J. P. O'Reilly (U.S.N.R.C.); This letter provides a schedule for eleven different types of surveys and reviews being conducted by the licensee in response to Bulletins 75-04 and 75-04A. The first plant surveys are scheduled for completion on 5/15/75; the final plant policy review is scheduled for completion on 9/30/75.)

I

UNITED STATES NUCLEAR REGULATORY CO.'ilMISSIOIV OFFICE OF II4SPECTION AND ENFORCEMENT REGIOiV IV 611 RYAN PLAZA DRIVE, SUITE 1000 ARLINGTON. TEXAS 76012 Fwy 21, 1975 Omaha Public Power District Docket No. 50-285 ATTY: kfr, T. E. Short Division Hanager - Production Operations 1623 Harney Stree" Omaha, Nebraska 68102 Gentlemen:

This letter refers to the inspection of your activities at Fort Calhoun Station, Unit iso. 1, authorized under IRC Facility License i . r, conducted by 'srs. Dickerson and S ith oz the Ozfice of Inspection and Enforcement on Hay 7-9, 1975. It also xe. exs to th discussion of our inspection findings held by the inspectors with '.fr T. E. Short and oth xs of vouix stair a' tnc, clusioin of t11e gnspection on jjay 9q 1975 ~

Within the scope of this inspection, no inconsistencies vith KRC require-ments were identi ied. Other inzractions identiz'ed through your int "'ral

'audit program and which were corrected by OPPD are discussed'n the Su.,~ry of Findings section o'f the enclosed inspection report. Ho additional

'information is needed for tnese items at tnis ti .e.

During this inspection ve also examined your corrective action relative to items of nonconformance as reported in IE Inspection Report icos. 50-285(75-01 and 50-285/75-03. We have no further ouestion relative to these'ems.

In accordance with Section 2.790 of thc i~RC's "Rules of Practice",,Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report vill be placed in XRC's Public Document Room.

If this report contains any information that you believe to be proprietary, it is necessary that you make a written application within 20 days to this office to l'ithhold such information from public disclosure. Any such

h

Omaha Public Power Distr'ct May 21, 1975 Q application must include a full statement of the reasons it is claimed the information is proprietary. Xt should be prepared so that 'hat proprietary information identified is contained in a separate part of the document, since the application, excluding this separate part, will also be placed in the Public Document Room. Tf we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.

Should you have any qustions concerning this inspection, we wi11 be pleased to discuss them with you.

Sinceiely, G. L. Hadsen, Chief, Reactor Construction and Operations Branch

Enclosure:

IE Inspection Report No. 50-285/75-06

Cf-'

I fMpf p/ UNITEo sTATEs NUCLEAR REGULATORY COMMISSION REGION II 230 PEACHTRKK STREET, N. Wo SUITE $ 11 ATLANTA,CKORCIA 00303 e '. p1y Refer 1o:

E: II: AKH lgY 5 l975

'50-250/75-7

-.50-251/75-7 Florida Power and Light Company Attn: Dr. R. E. Uhrig, Vice President of Nuclear Affairs P. 0,. Box 013100 Miami, .Florida 33101

, Gentlemen:

This refers to the inspection conducted by Mr. A. K. Hardin of this office on May 12-14, 1975, of activities authorized by NRC Operating License Nos. DPR-31 and DPR-41, for the Turkey Point 3 and 4 facilities, ahd to the discussion of our findings held with Mr. Yaeger at the c'onclusion of the inspection.

Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection

~

~nsisted of selective examination of procedures and representative

~

records, interviews with personnel, and observations by the inspector.

~

-'lecithin the scope of this inspection, no items of noncompliance were disclosed.

During the inspection an apparent deviation from an FSAR commitment was observed. The deviation is identified in Section VI of the summary of the enclosed report. You are requested to inform us of your plans for implementation of this commitment.

In accordance with Section 2.790 of the NRC's "Rules of Practice,"

Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains any information that you believe to be proprietary, it is necessary that you submit a written application'o this office requesting that such information be withheld from public disclosure. If no proprietary information is identified, a written statement to that effect should be submitted. If an application is submitted, it must fully identify the bases for which inform"tion is

~oiuTloh

("'.:G ',;==

tPPG

4, V ~ V r

0 Florida Power and Light Co. MAY R 9 Bye claimed to.be proprietary. The application should-be prepared so that I

~

information sought to be withhdld is incor'porated in a separate paper and referenced in'the application since the application will be placed in .the Public Document Room. Your application, or written statement, j should be submitted to us within 20 days. If we are not contacted as specified, the enclosed report and this letter may then be placed in I the Public Document Room.

Should you have any questions conce'ming this letter, we will be, glad J I

to discuss them with you.

Very truly yours, I t

Norman C. Hoseley Director.

Enclosure:

a IE Inspection Report Nos.

50-250/75-7 and 50-251/75-7 I.

eked g~

~

~ ~

~

'<<v<<

,=~ILi ~I ElORIOA POWER 0 LIGH1

@gilix~

OOMPAIll'une Q

L-75-304 20, 1975 I

~ <<II Hr. Norman C. Hoseley, Director

'. "S. Nuclear

'ffice of Inspection and Enforcement, Regulato'ry C'ommission Region II 230 Peachtree Street, N.. W., Suite 818

, Atlanta, Georgia,30303

Dear Hr. I~ioseley:

Re: ~ IE:II:A'.(H 50-250/75-7 50-251/75-7 During the course of an inspection conducted by personnel from your office on Yiay 12-14, 1975, an apparent deviation from an FSAR commitment was observed. The specific finding states:

"I'. ing, an inspection of cable tray penetrations,'wo locations

~ ~

eieobserved'hich appeared to deviate from the fire stop installa-

.tion ~

commitment made in =the

~

FPL FSAR, page 8.2-9." .

FSAR page 8. 2-9 states in part:

"Cable trays passing through 'walls or floors are provided with fixe stops as shown in Figure 8.2-19."

One tray of contxol cables in the Unit 4 control rod drive room (not Unit 3 as stated in the inspection report) and four large cab'le trays entering the auxiliary building above the main corridor doors did not have fire stops. All of these cable trays now have fire stops.

~ There'is no proprietary i'nformation in the subject x'eport.

Yours very truly,

)

'obert E. Unrig

~

~ ""

Vice President

)

REU: HAS: nch CC: Jack,R. Ne~-an, Esquire

i t

UNITEO STAI~-

NUCLEAR REGULATORY COMMISSION REGION II 220 PEACHTREE'STREET, N. W. SUITE did ATLANTA,GEORGIA 20300 JUL 2l 1975 n Reply Refer To:

IE: II:AKH 50-250/75-7 50-251/75-7 Florida Power and Light Company ATTN: Dr. R. 'E.'hrig Vice President of Nuclear Affairs

,P,. O.,Box .013100 Miami, Florida 33101 Gentlemen:

Thank you for your letter of June 20, 1975, informing us of steps you have taken to correct the deviations concerning activities under NRC Operating License Nos.,DPR-31 and DPR-41 which were brought to your attention in our letter of May 29, 1975. We will examine your corrective actions and plans during suosequent inspections.

We appreciate your cooperation with us.

Very truly yours, Norman C. Moseley Director

1 1

~

~

1 r ~

UNITED STATES NUCLEAR REGULA'TORY COLIMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV 611 RYAN PLAZA DRIVE. SUITE 1000 ARLINGTON, TEXAS 76012 July 8, 1975 Nebraska Public Power District ATTN: . Hr. J. Ei. Pilant,, Director Licensing and Quality Assurance

'P. 0. Box 499 3

Columbus, Nebraska 68601 Gentlemen:

Thank you for your letter'f June 30, 1975, "n response to our letter and Notice of Violation dated ofay 29, 1975. As a result of our review, we find

.that additional information is needed. Specifically, your, response does not indicate the coriective steps which will be taken to avoid further noncompliance nor does it indicat'e the date when full compliance will oe achieved.

As a result of a telephone conversation oetween you and Hr. J. E. Gagliardo of this office on Duly 8, 1975, we u.derstand that you will promptly submit the aoove additional information for our review.

'Sincerely, G. L. Ywdsen, Chief, Reactor Construction and Operations Branch t J all bcc: w/ltr J. !E. Pilant to GZZ E.:I; Ho"ard, dtd 6/30/75 H. D. Thornburg, XE:HQ (1)

~HQ (4)

DR Central Piles L:HQ (4)

'DR:HQ Local PDR TXC NSXC Nebraska State Department of Health

F CE.NEAAL OFF )c(

COLvt Ov Nt l I(A KA I

debt gqkg PUbI]c pp~ey D~gg~tCt J July 15, 1975 Mr. E. Morris Howard, Director Office of Inspection and Enforcement Region IV U. S Nuclear Regulatory Commission 611.Ryan Plaza Drive Suite 1000 Arlington, TX 76012 Subject IE Inspection Report No. 50-298/75-07 Cable Separation Status Additional Information

Dear Mr. Howard:

This letter is in response to your letter to the District dated July 8, 1975 which requested additional xnformation regarding the subject inspection r'eport.

In our response to the inspection report, dated June 30, 1975, we indicated that carrective action had been taken with regard to five of the six noted discrepancies. We believe that, with the exception of the two cable trays within the reactor drywell, we are in full compliance with the cable separa-tion criteria. We believe that a physical inspection of the reactor drywell is required to determine a proposed solution to the remaining discrepancy, and therefore, are planning to complete such inspection during the outage necessary to effect a repair of the in-core instrument tube vibration problem, tentatively scheduled for October, 1975. ~0 WJ We believe that further non-compliazrce in this area is effectively precluded by our requirement of strict adherence to the procedural controls governing design changes to the facility.

'We believe that the above information is complete, however, should you have any questions or require additional information, please do not hesitate to contact me.

Sincerely,

~

ay M. Pilant Director of Licensing

~

and Quality Assurance

La~ fv ..r UNITED STATES NUCLEAR REGULATORY CO( IhlISSION

,OF FICE, OF. INSPECTION ANO ENFORCEMENT REGION IV 611'RYAN PLAZA'DRIVE;SUITE 8000 ARLINGTON, .TE XAS 76012 'uly 18,. 1975 Nebraska Public Power District.

ATTN: Mr. J. M. Pilant, Director Li'censin'g 'and Qual'ity Assurance P. 0. Box 499 Columbus, Nebraska 68601 Gentlemen".

Tnank you for your letters dated June 30, 1975, and July 15, 1975, in response to our letters dated May 29, 1975, and July 8, 1975. We have no furthei questions at this time and will review your corrective action during a future inspection.

Sincerely, ggL. @a~ g7~~

G. Ma'dsen, Chief,

• Reactor Construction and Operations Branch Pilant to E. M. Howard, dtd 7//15/75 /

bcc: w/ltr J. M.

H. D. Thornburg, IE:HQ (1)

. LJZ1HQ (4)

DR Central Files ar L:HQ (4)

PDR:HQ

~ Local PDR TIC NSIC Nebraska State Department of Health Kansas State Department of Health

I I

'I P

coovEu wvcae~o srrvioN D.o. OQX 98. ElROv::4vlLLL,rent llAASrl<<.yy:

Nebrasl<a Public Power District TCLEPHGNC [402) 8 "~.38 I 1 June 30, 1975 Mr. E. Morris Howard U. S. Regulatory Commission Office of Inspection and Enforcement Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington,, Texas 76012

Subject:

IE Inspection Report No. 50-298-75-07 Cable Separation Status

Dear Mr. Howard:

P This letter is in response to your letter dated May 29, 1975 which transmitted the subject inspection report.

Six discrepancies were noted in the subject report in the area of cable separation. The following corrective actions have been completed for each of the discrepancies under C. Cable Senaration:

(1) On the northeast end of the Reactor Building where a Division I and a Divisi'on II cable tray 'run vertically from the 931'-6" 903'-6" elevation to the elevation with a horizontal separation of .

approximately eight inches, a solid metal cover was installed along

. the complete length of the inside of the Division I tray. This installation satisfies the separation criteria of the FSAR.

(2) 'On the northeast corner of the Reactor Building, near the ceiling of the 903'-6" elevation, where a Division II cable tray crosses

~

over a Division I cable tray with a vertical separation of less than eighteen inches, the solid metal cover on the bottom of the Division II cable tray was shifted during cable pulling exposing a gap in the metal barrier of approximately one inch. This gap has been closed and a solid metal barrier separates the two cable trays.

(3) On the east end of the Cable Spreading Room (918'-0" elevation), a terminal box has Division I and Division II cables leaving the box and running in cable trays which parallel each other with a horizontal separation of less than six inches for a length of about two feet. A fire barrier has been installed between these two trays by the addition of metal covers on the bottom of each tray thus completely surrounding both trays'ith a metal barrier for approximately six feet. These trays are now in accordance with the FSAR separation criteria.

0 Mr. E. Morris Howard June 30, 1975 Page 2 (4) On the northwest corner of the Cable Spreading Room where a Division I cable tray crosses over a Division II cable tray, the metal cover over the Division. II tray was estended to five feet on each side of the cross-over area as required by the FSAR cable separation commitment.

(5) In the Auxiliary Relay Room the Division II cables from the Division II cabinet are laid in a cable tray which runs west and north and exits through the northwest area of the ceil'ing. The cable tray is installed. in such a manner that it passes within a three feet horizontal separation of the Division I cable tray which collects the cables from the Di'vision I re1ay cabinet. A vertical fire barrier approximately 30" x 40" has been installed between the two cable trays as required by the FSAR cable separation commitment.

(6) Two cable trays ring the Reactor Drywell with most of the runs being in the upper position of the 903'.-0" elevation. The trays are designated C85 (Division I) and C84 (Division II) and are run with C85 above C84 with a separation of about one foot. Evaluation of this reported discrepancy is currently in progress and we will advise your office, as soon as possible, with regard to an acceptable resolution. We would like to point out that the Reactor Drywell is currently, and will remain, inerted with nitrogen which precludes the ability of the Drywell atmosphere to support combustion.

Should you have any questions, or require additional information regarding the above responses, please do not hesitate to contact me.

Sincerely, Pilant Director of Licensing and Quality Assurance mrh

UNITED STATES NUCLEAR IIEGULATORY COMMISSION OFFICE GF INSPECTION AND ENFORCEMENT

'REGIOiI 'IV 6'l1 RYAN PLAZA DRIVE. SUITE 1000 ARLINGTON. TEXAS 76012 Buy 29, 1975 Nebraska Public Power.,District . Docket No. 50-298 ATTN: llr. J. <<ii. Pilant, Director Licensing and Quality Assurance P; 0. Box 499 Columbus, ilebraska 68601 GentlenenI This refers to the inspection conducted by Hr. J. E. Gagliardo of this office during the period ofay 5-7, '1'975 and <<hay 16, 1975, of activi = s

~

authorizad by i'RC Operating License DPR-46, ~~ d to his discussion of the findings .-ith ~ir. L. C. Lessor and other members of your staxx on Hay 7, and with ~<<lr. K. L. obeyer on Hay 16, 1975.

Princip e "-reas examined during the inspection included: (1) construc-tion specifications .for xire barriers ~ compartment boundary seals for sa ety related cables; (2) construct on specixications for fire retardant coating fo" saf ety related cables; (3) ma 'ntenance and modification procedures; (4) visual e~:a='nation of fire barriers and boundary s..als; (5) reactor operations at reduced power; (6} power ascension tes" results; (7) follow-up on actions reported under XEB's 75-03, 75-0+ and 75-04A; (8) actions taken on Abnoa.al Occurrence Reports; and (9) tiaining. Mithin these areas, the inspection consisted of se1ectiva examinations of procedures and representative records, interviews wi"h personnel, and observations by tne inspector.

During th's in pection it was found tha" certain of your activities werc not cond cted in full compliance th 'iRC requirements, as set forth in th .'iotice of Violation, enc1osad herewith as Enclosure (1).

This nnt cc "s sent to you pursu nt to the provisions of Section 2.201 of the hZC's "Rules of Pra'ctice", Part 2, Title 10, Code of'ederal lheguxr talons ~ Sect j.on 2 201 reqIuiras 'v c>> to suL "' to this nFfi cn wxthin 30 days of your eceipt of th's notice, a written state.""nt or e~:p~an"=tion in reply including: (1) corrective steps whicn lIave

Nebraska, Public Power District May 29, 1975 been. taken by you, and the results achieved; (2) corrective steps which will be taken to avoid further noncompliance; and (3} the date when full compliance will be achieved.'n accordance with Section 2.790 of the NRC s "Rules of Practice",

10, Code .of Federal Regu3.ations, a copy of this letter and the Part.',

Title enclosed 'in'spection repor't will be placed in the KRC's Public Document Room. Xf this report contains any information that you or-your contractors

'elieve to be proprietary,

'to it is necessary that you make a written applic>>

this office to withhold such infor,ation from ation within 20 days public disclosure. Any such application must include a full stateme a emen t o f it tth e reasons on the basis of which is claimed that the information is proprietary, and should be prepared so that proprietary information identified in the application is contained in a separate 'part of the document. If'we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.

=

Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely, g 5 77yuA~>

G. I . Madsen,.Chief, Reactor Construction and Operations Branch

Enclosure:

1. Notice of Violation

2. XE Inspection Report No. 50-298/75-07 cc: L. C. Lessor, Superintendent, w/encls.

Cooper Nuclear Station P. 0. Box 98 Brownville, Nebraska 68321

Cooper Nuclear Station License No. DPR-46 ENCLOSUPZ (1)

NOTICE OF UIOI KTIOVi' Based on the results of an NRC inspection .conducted-on Ha 5-7,

~

, , pp s hat certain or your activities were not conducted in full compliance with NRC requirements as indicated below.

Contrary to 10 CFR Paxt 50, Appendix B, Criterion U and the licensee's response to FSPR Question No. ?.4 in FS R amendment 15, six (6) d'iscrepancies d were found in' "

the imple en"~a~won o f the h cableb separation.

cr'eria and several of the fixe barriers for saf a e t y re 1 ate d e 1 ectrical

. a es contamed combustible urethane foam sstrreps whi c h had h d not been

~ covered with fire retardant paint.

This infraction had the potential for causing or contributing to an occurrence related to health and safety.

Other infractions identi':ied '

through your internal audit pxogram and

mely which were re p orted in a manner and corrected are set out i at the inspection report. No additional inzornati on xs needed. for these tems this time;

~w

/ ~g ~ylA UNITED STATES NUCLEAR REGULATORY COh'IMISSIOJJ DIRECTORATE OF REGULATORY OPERATIONS REGION II 230 PEACHTREE STREET, N. W SUITE 818 ATLANTA,GEORGIA 30303 June 3, 1975

'Karl V. Seyfrit, Office of'nspection and Enforcement, Headauarters CAROLINA POHER AND LIGHT, BRIPilSMICK 2, D/N'0-324,'SPECIAL PIRE INSPECTION Attached is a copy of Inspection Report No. 50-324/75-06 covering the special fire inspection conducted at Brunswick 2 on Nay 5-9, 1975.

,A deviation from commitments in the FSAR is identified in the report and the licensee has been reauested to inform us of his plans for implementation. l.'e believe that the bulletin responses and the ~

existing,commitments in the FSAR and construction specifications will be adeauate for resolution of the problems until such time as other criteria may be developed and imposed bv NRC.

. Long, Ch3. f Facilities Operations Branch

Enclosure:

Rpt No. 324/75-06 cc: wo/e F. S. Cantrell M. S. Little

4 h, -: h

&h UNITEO STATES

~ NUCLEAR 'REGULATORY COMMISSION REGION II 220 I EACHTREE STREETh N'N SUITE 414 ATI-AQTA,CEORGIA 00300 JUL ."Z trna t ~

t In Reply Refer To:

IE:II:FSC 50-32 4/75-06 Carolina Power and Light Company

.,ATTN'. Mr. J.. A. Jones Executive Vice President Engineering, Construction and Operation

.336 Fayetteville Street.

Raleigh, North Carolina 27602 Gentlemen:

Thank you for your letter of June 30, 1975, informing us of steps you

are taking to correct the deviation from 'commitments in your Final Safety Analysis Report concerning activi'ties under NRC Operating License No. DPR-62 which were brought to your attention in our letter of June. 5, 1975. Me will examine your corrective actions and plans during inspections. 'ubsequent I

Ve appreciate your cooperation with us.

Very truly yours, 0

Norman C. Moseley Director qO<IJ"Oe z

1pp6.1916

t Cq

4

<L <<

~ <<

,( '>'">

r

~ ~ ".:";i '.ir.>>t Cow~:nsq.

Junc 30, 1975 PnE: m-35l3 (B) .SE~'- HC-75-1000 .

Rr. Norman C. Hoseley, Director

'U, S, Nuclear 'Regulatory Co~ssion

,Region IZ - Suite 818

,230 >cachtreo Street, R.Q.

ht3.ante, Georgia 30303 Qeur Nr. Hoseley:

BRURStUCN STEAN ELECTRIC PLANT, UHXT hO. 2 LICEHSE HO. DPR-62

'ESPONSE TO PSAR DEVXhTION In your letter of 3une 5,,1975, you forvarded a copy 'of IE Inspection Report 50-324/75>>06 for the Brunsvi& Steam Electric Plant, Unit'-No'., 2'.- he, h'eve rei~ieSed'he> r'cp'dr<<t and'Hnd. that in ormation of a proprietary nature.

it does not contain'ny As noted in your letter, the report identifies an'ctivity that appears to be a "deviation" from a co~tm nt in the Final Safety Analysis

~e apparent deviation and Carolina Power.h Light.Company's 'eport.

response to ik are addressed in the following text:

DevJstion Prom CESAR Commitment During, an inspection of firestops, numerous locations vere observed vhich appeared to deviate from the fire retardant barrier installation commitment made in the. Brunsvick and 2 FSAR. l

'CPA Res onse

. Xn our response to you conc>ming IE. Bulletin 75-04A dated June .ll., l974, ~m provided additional information concerning our program Xor ensuring that plant firestops for Brunsvick Unit llo. 2 are installed as outlined in the applicable specification. Ve believe this report dequately outlines our plans for implementation of our FSAR commitment.

~ ~ <<i

~ ~  :~<<i' ~ '7

r ~ 52M June 30, 1975 Hr. Norman C. Hoseley

~ ~ ~

e Xf you have any further questioni concerning, tMs matter>

please contact us.

Yours very truly, E. E. Utley,"

Vice-President

'BuLk 'PoMer "Supply RBS:bn CC: Hr. N. B. Bessac

. Nti. E. C. Hollovel1 Nr. P P. Hove Hr., J. A. Jones Hr. R..E. Jonei .

Hr. Q. B. FJ.ncaM Hr. D. B. floaters

UNITED STATES NUCLEAR REGULATORY CotJIMISSION OF INSPECTION ANO ENFORCEMENT'FFICE REGION IV

'11 RYAN PLAZA DRIVE, SUITE 1000 ARLINGTON, TEXAS 76017 July 22, 1975 Public Service Company of Colorado Docket No. 50-267 ATTN: Hr. C. K. ifillen Senior Vice President

'P. 0. Box'840

,Denver, Coloiado 80201 Gentlemen:

Thank you for your letter of July 11, 1975, in response to our letter and Not'ice of Violation dated June 19, 1975. Me have no further. questions at. this time and we will review your corrective action during a future'nspection..

Sincerely,

, ~ G.

n+g<

L. Madsen, Chief, Reactor Construction and Operations Branch bcc: w/ltr C. K. Hillen to E. M. Howard, dated 7/11/75 H. D. Thor'nburg, IE:HQ (1)

~lE:HQ (4)

DR Central Files L:HQ (4)

PDR:HQ Local PDR TIC NSIC Colorado State Department of Health

UNITED STATES NUCLEAR REGULATORY COMMlSSlON REGION II 230 REACHTREE STREET, N. W SUITE @II ATI ANTA, GEORGIA 20202 Reply Refer To:

E:II-FSC JUg 5 1975

'50-324/75-06 Carolina Power and Light Company ATTN: Mr. J. A. Jones Executive Vice President Engineering, Construction and Operation 336 Fayetteville Street

.Raleigh, North Carolina .27602 Gentlemen:

This refers.to the inspection conducted by Mr. F. S. Cantrell of this office on May 5-9, 1975, of activities authorized by NRC Operating License No. 62 for the Brunswick facility, and to, the discussion of our findings held with Mr. E. G. Hollowell, on May 9, 1975, at the conclusion of the inspection.

Areas emmined during this inspection included Carolina Power and Light Company investigation of two Reactor Blowdowns, and the Status of Fire-stops. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.

Within the scope of this inspection, no items of noncompliance were disclosed.

An infraction identified =through your internal audit program is shown in the details of the enclosed inspection report. The appropriate report was made and corrective action initiated or completed .and no additional information is needed for this item at this time.

During the inspection it appeared that a commitment in the Final Safety Analysis Report had not been met. The item is identified as a "deviation" and appears in Section VI of the summary of the enclosed report. You are requested to inform us, within '20 days, of your plans for implementation of this coImnitment.

In accordance with Section 2.790 of the NRC's "Rules of Practice,"

Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains any information that you believe to be proprietary, it is necessary that you submit a written application

<pUOTIOy O~

( a C ).

/276.1916

/

4 *"0*

Carolina Power and Li.ght Company ~

~

~

to this office requesting .that such information be withheld from public disclosure. If no proprietary information is identified, a written statement to that effect should, be submitted. If an application is submitted, it must fully identify the bases for which information is claimed to be proprietary..'The application should be prepared so that information sought to be withheld is incorporated in a separate paper and referenced in the application since the application will be placed in the Public Document Room. Your application, or written statement, should be submitted to us within 20 days; If we are not contacted as specified, the enclosed report and this letter may then be placed in

.the Public Document Room.

Should you have any questions concerning this letter, we will be glad to discuss them with you.

...Very truly. yours, 1

I

~'7P >u' g Norman C. i~foseley Director

Enclosure:

.IE Inspection Repoxt Ho.

50-324/75-06

A PUBLIC SERVICE COMPANY OF COLORADO P 0

~ ~ 80X 840 'CNVCRe COLORADO 8020l G. E. HD~Y SCNIOR VICE PRCSIOENT July 11, 1975 Mr. E. Morris- Howard U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region XV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76012

Subject:

Docket 850-267 NRC Inspection Report 75-07 of June 19, 1975

Dear Mr. Howard:

In response to the Inspection Report of June 19, 1975, concerning the audit by Mr. T.F. Uesterman during the period May 11-16, 3.975 and May 27-30, 1975 of activities authorized by NRC Operating License No. DPR-34 and pursuant to the provisions of Section 2.201, Part 2, Title 10, Code of Federal Regulation, we submit the following:

The response numbers reference the corresponding number under the appropriate heading of the audit report.

A. INFRACTIONS

1. The infraction stated that GAC Field Inspection Reports 4230 and 4231 documented sign-off of specific requirements which were subsquently found to be nonconforming. Field inspection Report 4230 documented that 100% inspection and acceptance of installed fire stops by the contractor QA. The fire stops and covers for the vertical river fire stop from the di'esel room had not been installed and were inadvertently signed off with FIR 4230. This was the only discrepancy noted on the rather extensive fire stop installation program. This matter has been brought to the attention of GAC and PSC has been advised by GAC that their personnel involved have been notified of the discrepancy and the consequences thereof. GAC inspection personnel have been instructed to document in detail results of inspection to avoid further infraction of this type.

Field Inspection Report 4231 was written to indicate that the specific items which had been tagged as problems by GAC Engineering and assembled into a packa'ge denoted as WA92F1863.

(No Revisions) were complete. The segregation criteria for those specific problems denoted in WA92F1863 (No Revisions) had been met utilizing zipper tubing where minimum seperation

'riteria could not be achieved. The sign off of FIR 4231 was not intended to conclude that the bus and loop segregation problem in all tray areas was satisfactorily resolved, only those specifically denoted in WA92F1863 (No Revision). While the wording on FIR-9231 may have be'en misleading, we do not feel this to be an infraction since the specific work (WA-92-F1863) was refezred to on FIR-4231.

2a A comprehensive inspection and evaluation is currently being conducted throughout the plant to determine the extent oi

~

problems regarding compliance with existing separation and segregation criteria. Upon completion of this effort problem area wil1 be indentified and corrections will be applied as applicable. Discussions are'pres'ently under way,with NRC to determine an approved resolution to this matter.

2b A comprehensive review of the cable tabulation is being con-ducted in conjunction with the present inspection and evaluation pzogram. A new cable tabulation list will be prov'ded upon completion of this work.

2c No response required pez NRC cover letter dated June 19, 1975.

2d Separation of control relays 9200A and 9200B which were found to be lacking in proper separation will be correction upon completion of our overall separation and segregation identifi-cation and evaluation program.

2e The solid metal snap-on covezs for trays will be provided following the completion of the on-going separation inspection, correction and audit effort.

Due to the nature of the entire separation and segregation criteria subject, we cannot give estimated completion dates for items 2a, 2b, 2d and 2e at this time. We will keep your office advised of our progress on these matters.

We trust the foregoing information satisfactorily answers the infractions identified. If there are further questions, please advise.

C.K. Hillen Senior Vice President CK<i/FES/ds

7j.

, UNITEO STATES NUCLEAR REGULATORY CGI.IMISSION OFFICE OF INSPECTION ANO ENFORCEMENT REGION IV 611'RYAN I'LAZA OHIVE. SUITE l000 1 E X AS, 7001? 'RLINGTON, June'9, 1975 Public Service Company of Colorado Docket ?!o. 50-267

.-ATTil'. ~lir. C. K. ~iillcn Senior 'Vice President P. 0. Boz 840

'Denver, Colorado 80201 Gentlemen:

This refers to the inspection conducted by .'lr. T. F. Lobsterman, of this office duriT:I", the per'od '.'i y 11-16 and 27-30, 1975, 'of activiti s utnorized by iiRC Operating License Ko. DPP,-3~I, and to the d'scussion of the findings with member of your staff at the conclusion of the inspection.

Areas e?'amined durinG this inspection are described in our report, lrllich is ellclosed '..-iti?I t?lis letter (enc'oaure 2). t;ithin thiese areas, the inspection cons'st d oi select-'ve e::amin tions of p"oc dures and:epr scn-tative records, interviel"s 17ith p"rsonn <<, and o'cservations by the inspector.

Based on the results of thi inspect~on, i" pp ars that certain of your.

activities re not conducted in full co-;;.pl'ance:;ith ZRC requirements, as v

set forth in the 'Aotice of Violat'on, enclosed herel'itn as nc o"urc '.

These items of nonco-. p'iance have been categorized in"o the levels as de"cribed in our correspondence to you dated December 31, 1974. This notice is sent to you pursuant to the provisicns of Sect.'on ."Ql of the ZIRC s Rlles o" Practice", Par" ", T'"le 10, Cod" of ."ed. ral Re@'atio s.

Section 2.201 r 0uires you to s mit to this of <<ce, 1;ithin tl:enty (20) oays of your. receipt o this not'ce, a l?ritten st"tement or explanation in reply including'1) corrective steps 4'hi h have been taken Dy yo and tria results'chicve0; (2). corrective stops hic?1 vill be taken to avoid iurth =

violet'ons; an (3) the date x?hcn =ull cc pliance l?ill be achi ved. One other infraction idcntif 'd through your internal audit progr"m for 1'rich correctiv action nas bee:l i:litiated, 's set out in the attached 'nspect'on report. .'io audition 1 information is needed for tnis item at this ti"I .

Since Xtcm AD c 'as co ected prio" to tha co-,piet'on of t.lis inspection,

~

no reply to this itc- is required.

Public Service Company of Colorado June 19, 1975 In accordance with Section 2.790 of the NRC's "Rules of Practice", Part 2, Title'10, Code of Federal'egulations, a copy of this letter and the enclo cd inspection report will be placed in the NRC's Public Document koom. If this report contains any information that you or your contractors oelieve to be proprietary, it is necessary that you ma<:e a written application within 20 office to withhold'uch infor-ation from public disclosure.

days to this Any such application must include a full state .ent of the reasons it is claimed that the information is proprietary. It should be prepared so that proprietary information identified is contained in a separate part of the-document, since -the application,-excluding *this separate part, will also.,be placed in the Pbblic Document Room. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room. 'I Should you have any questions regarding this inspection, we will be pleased to discuss them with you.

Sincerely,

+j / c Li <i;~

't G. L..'!adseri, Chief, Reactor Construction and Operations ranch

Enclosures:

1. Notice of Violation

2. IE Inspection Report No. 50-267/75-07 cc: F. E. Swart, Superintendent, w/encls.

Fort S t. Vrain Nuclear Station P. 0, Box 368 Platteville, Colorado 80651 D, M. Parembourg, Resident Engineer Fort St. Vrain Nuclear Station P. O. Box 368 Platteville, Colorado 8065'cc:

w/o encl. 2 H. D. Thornburg, IE:HQ (1)

IE:HQ (~)

DR Central Files (1)

L:HQ (1)

PDR:HQ Local PDR TIC NSIC Colorado State Department of Health

,kkI k ~

~ ~

'ublic Service Company of Colorado Docket -No. 50-267

.License DPR-34

~ 'ENCLOSURE 1

.NOTICE OF VIOLATIONS Based on the resultsf an NRC inpsection during the period of tf y 11-16, and 27-30, 1975, it appear that certain of your activities were not con-ducted in full compliance with conditions of your NRC License No. DPR-34 as'indicated below:

A. INFRACTIONS .

k

1. Contrar v to 10 CFR 50 , Appendix B, Criterion XVI, which states in part that, "i~ieasures shall be established to assure that conditions adverse to quality . . . and nonconformances are promptly indicated and corrected.", Field -Inspection Reports 4230 and 4231 document sign-off 'of specific requirements which were subsequently found to be nonconforming.

This infraction constituted the potential for causing an occurrence related to health and safety.

2 ~- Contrary to 10 CFR 50, Appendix B, Criterion V, which states in part that, "Activities ffecting quality si:all be prescribed by docu. ented instructions . . . and snail be acco-. plished 'n accordance with those instructions . . . .", the folio"ing activities affecting quality were not accomplished in accord-ance with documented FSM requirements and/or Construction Specification 1-N-2:

at The routing of redundant .circuits in separate trays has not been maint 'ned as specified in the FSAR, Question 7.4(").

Tray 23:i2 was found to contain 18 as'oestos zipper covered bundles of Bus 1 cable in a tray'ontaining Bus 2 cable.

b. Essential. circuit cable (c'ables 7096, 7097, 75194, 26673, and 26715) associated with the emergency diesels had not been identified to be essential in the cable tabul tion as specified in Construction Specification 1-N-2, Supplement l.

C~ Separation of essential redundant instrument bus powe supply cable was no" maintained as pecified in the FSAR, Question 7.4(d). Bu" 2, essential instrument pc::er supply cable (cables 25590 and 25'593)'erc installed in cable raceway in Panel I-10, Ba> 900, which contained Bus 1, essential instrum nt power'supply cable. Separations had not been provided.

d~ .Separations of essential redundant emergency power load shedding'elays was not. maintained as specified in the FSAI:,

Question 7.4(d). Control relays 9200K and 9200B were found to be side-by-side. Separations had not been prov'ded.

e. The solid metal snap on-off covers for trays carrying low-level signal cable located in the 480 switchgear room and the auxiliary electric equipment roon has not been I

installed as specified in the FSAR, Question 7;4(a).

This infraction constituted the potential for using an occurrence related to 1

c health and safety.

0 U. S. NUCLEAR REGULATORY COl~-fISSXON f

OFFICE OF INSPECTION AND ENFORCEHENT j REGION .IV IE Inspection Rcport No. 50-267/75-07 Docket No. 50-267 7

Licensee: Public .Service Company of Colorado License No. DPR-34

\

I Facility: Fort St. Vrain Nuclear Generating Station=- Category .B

'Location. Platteville, Colorado Type of Licensee: Povc'r Reactor (HTGR 330, Mle-GGA)

Type of .Inspection: Special,,Announced Dates of Inspection: Hay 11-16, 27-30, 1975 Dates of Previou Inspection: Hay 5-7 1975 h

)'nspector T. F. Vysterman, Reactor Inspector (p- l~'- 'IP Accompanying Inspector: Hone Other Accompanying Personnel: C. F. Hiller, Division 'of Licensing, Technical Review Branch V; D. Thomas, Senior Instrument and Control Engineer, IE:HQ Reviewed By: (, 1g "g,1 G. L. Had en, Chief, Reactor Construction Date and Operations Branch

t f SUM%AY OF'FINDINGS

-0 t

Enforcement Action Items of Noncom liance

1. . Violations None

'2.' Infractions a ~ Contrary to 10 CIR 50, Appendix B, Criterion XVI, measure have

'not beon established in the fie'ld inspection program to a ure

<that nonconformanccs are promptly -identified and correc'tcd.

Field Inspection Reports 4230 and 4231 document sign-offs of specific requirements which vere found to be nonconforming by the IE inspector in the accompaniment of licensee personnel.

(DETAILS, paragraphs B.l and 'B.4.a(2))

b., Contrary,to 10 CFR. 50, Appendix B, Criterioq V, activities affecting quality were not accomplished in accordance with documented FSAR requirements and/or Construction Specification 1-N-2.

t (1) The licensee has identified that separation of nonessential/*

essential circuits has not been maintained in the Reactor Building as pecified in the FSAR, Question 7.4(a).

.(DETAILS, paragraph 4.b(1)(a))

(2) Cables of different bu c and/o'r loops have been installed in the same tray using asbestos zipper covering to maintain sep'arations. The FSi'D, Question 7.0(a) specifies that cables of different buses and/or. loops are to be routed in separate trays and/or trays with a iretal divider. (DETAILS, paragraph 4.b(l)(b))

(3) Essential circuit cable associated with the emergency diesels was not dc ignated essential in the cable tabula-tion listing. Construction Specification 1-N-2, Supplement, 1, specifics that such essential cable wi.ll be identitficd by a hexagonal symbol. (DETAILS, paragraph 4.b(4))

(4) Separations of redundant instrument bus power supplies in panel I-10, Bay 900 has not been maintained as specified in the FSAR, Question 7.4(d). The licensee rcroutcd the affected cables prior. to the completion of this in pection.

(DETAILS, paragraph 4.b(3)(a))'continued)

0 (5) Separation or redundant emergency power load shedding rel'ays ip panel I-66 has not .been maintained as specified in the FSAR, Question 7.4(d). (DETAILS, paragraph 4.b(3)(b))

(6) The solid metal snap-off covers for trays carrying low-level signal cable have not been installed as specified in the FSAR', Question 7.4(a). (DETAILS, paragraph 3.4.b(4))

Deficiencies Hone Licensee Action on Previously Identified Enforcement Actions The following items of noncompliance identified in IE Inspection Report 50-267/75-02 were reviewed and are considered closed:

a. 'lant 0 aration Review Committee Hcmbershio (DETAILS, paragraph B.7.a)

b. Nuclear Facility Safety Committee Hembershio (DETAILS, paragraph H.7.b)

C~ Semiannual Report/Record of Scrams (DETAILS, paragraph. B. 7. c)

'd ~ Late Abnormal Occurrence Renorts (DETAILS, paragraph B.7.d)

The status of the following items of noncompliance identified in IE Inspection Report 50-267/75-04 was reviewed. (Each of these items are under review by IE:ilQ with respect to enfoicer~ent action):

ae Fire Protection Physical installation of fire stop was verified as complete.

Cable separation is incomplete. Permanent corrective action with respect to flammable material in the cable spreadin rocm and the open battery zoom door was not complete and. thcrei'orc not inspected. (DETAlLS, par"graph I'.1 and 4) b, Seismic Desi.n of Reserve Shutdown System Installation of cismic restraints and bottle racl:s werc verified a complete. Calculations have been completed rhat verify the adequacy of the design. (DETAILS, paragraph 3.2)

(continued)

None

- Other Si;nificant Pindinr,s Current Unresolved Items

1. . 7507-01 Cable/J liall Penetration.".

The .practice of maintaining cable separati.ons by use,nf asbesto" zipper covering fron the cable trays to the J wall pe>>etrations i"

,considered an unre olved item. The .FSAR .does not,describe tlris;as an acceptable practice. (DETIALS,- paragraph E.4(c))

Status of Previousl Identified Unresolved Items 7504-4 Seismic Re. traints for. Class I Bottle Calculations have been.performed which demonstrate 'the seismic adequacy of Class I Bottles.

This item is considered resolved. (DETAILS, paragraph 3.3)

Mana ement Intervier; 0 Management I>>terviews were held with Mr. Swart, Superintendent, 1'.uclear Production, and oth r plant staff o'n 1!ay 16 and 30; and with Mr. Drey, Superintendent, Operations on M"y 28, 1975. 1 r. 'Ihoras, IE:1/Q, and Yir. Hiller, Division of Licensin ," were present during the May 28, 1975 exit meeting (only) ..

A. General I

The'reas inspected, as reported in the Details Section of this report, were surmarized. The inspector also stated that the main purpose of this inspection was to determine the status of the plant prior to escalation of power above 2%.

Items of Noncompliance The apparent items of noncorapliance with the Cormission's requirements were discu J

sed as identified in the Enforcement Section of this report.

(continucd)

heal DETAILS Persons Contacted Public Service Com anv of Colorado R. Kishiyama, Electrical Engineer J. Reesy, Electri.eal Engineer J. Reader, Resident Engineer F. Svart, Superintendent, Nuclear Production L. Brey, Superintendent, Operation F. Hathie, Superintendent, iiaintenance D. >larembourg, Director of QA J.. 'Bissett, Qualit:y Assurance J. Solakievicz, Jr., Quality Assurance D. Rogers, Operation Supervisor E. Hill, Senior Results Engineer General Atomic

'. Zanot, Site Project Iianager D. Glenn, Site Engineer.

R. Ayres, Electrical Engineering J. Bauer, Electrical Engineering Sar ent & Lund ~

A. Nathan, Electrical Engineering B. Rc ort of Sub'ects Ins ected j

Fire Protection (

Reference:

Inspection Rcport 50-267/75-04)

The inspector verified, by random visual. inspection, that fire stops have been installed per Construction Specification 1-N-2 as modified by Fi.eld Change Notices (FCN) S&L 483, 479, 482, and 484. (FCN S&L 483 documented the addi+ion of vertical fire .stops. FCN's S&L 479, 482, and 484 vere added to justify material deviations from Specifi-cation 1-Ii-2).

Field Inspection Report (FIR) 4230 documented 100K inspection and acceptance of installed fire stops by contractor QA.

During the random visual in paction the inspector, in the accompanir.:cnt:

of the licensee engineering personnel (vho vere performing a concurrent inspection), found that covers for the vertical riser fire stop fro-.

the diesel rooms had not been inst:alled as stat.ed in FIR 4230. Thc riser opening through the overhead had not been sealed as required by construction droving E-54. Tive fire stop installation vas co..>>) ctcd prior to the end of this inspection.

(continued)

No furt1icr inspection of the physical installation of fire stops 4s to be peiformcd.by IE:IV; however,'nforcement action is under

, review by IE.Headquarters regarding thi item of noncompliance.

IE:IV will followup on the licensee's response to IE Bulletin 75-04/04A regarding fire stops at a subsequent inspection.

The failure to identify the incomplete diesel room fire stops as nonconforming is identified a an item of noncompliance with respect to 10 CI'R 50, Appendix B, Criterion XVI.

Seismic Desi~n of Reserve Shutdown System (

Reference:

Inspection Report 50-267/75-04)

The inspector visually verified that seismic restraints and bottle racks have been installed for. the instrument panels and helium bottles associated with the Reserve Shutdown System.

The inspector was shown vendor seismic calculations (dated 5/7/75) for this modification which confirm the adequacy of the Reserve Shut'doom System during a seismic event. The licensee's engineering organization has documented their review and concurrence of the design in' memo dated 5/9/75.

Ko further inspection of this item is to be performed by IE:IV; however, enforcement action is under review by IE Headquarters for this item of noncompliance.

7504-04 Seismic Restraints for Class I Bottles The inspector was shown calcul tions summarized by a licensee's memo dated 5/9/75, that show that the seismic adequacy has been determined for gas bottles associated with other Seismic Class I oottle racks (Helium and Hydrogen blanket gas bottles for. the surge tank , and the Helium circulator brake and seal system gas bottles). 1;o changes to these systems were indicated by the'calculations to be necessary.

Unresolved Item 7504-5 (inspection Report 50-267/75-04) is considered resolved with respect to seismic restraints for Class I. Bottles.

Corrective action is still in progre..s with respect to cable separations. Thc: insppctor, in the accompaniment of the licensee, found numerous areas within t.he auxiliary electric equipment room where the FSAR guestion 7.4(a) Separations Criteria (6 inches of separations or (continued)

asbesto zipper .cover, had not been met for both temporary. test cable'and permanent cable. In example, above panel I-368,.Loop 1, Bus 1 (orange) cable eros cd a Loop,2, Bus 2 (blue) with le..s than 6-inch separations.

An asbc tos zipper .cover had not been provided. Also, on top of the panels there was a considerable amount of cable laying together which had not been properly separated.

(2) The inspector did find that Fic1d Inspection Report FIR 4231, 'dated 5/13/75, stated that bus and loop segregation in the'ray'areas had been found satisfactory,

.,althoug>h..tl>e licensee. and inspector were continuing to identify problems. The licensee stated, with respect to -FIR 4231, that there had been no clo'scout of this item by Public Service Company of Colorado and that the inspection effort by licensee was still continuing.

The apparent improper sign-off of FIR 4231 is considered an item of noncompliance with respect to 10 CFR 50, Appendix E, Criterion Pill.

(3) The licensee estimated that an approximate 10,000 feet of asbestos zipper covering had .been in tailed during the period of April 24 oi'his a'estos, zipper through Hay 1975. The majority covering was installed to obt..in separati.ons for. cable running from the panels located in the auxi.li"ry electric room to the cable tray (above),

and from the cable trays to thc floor level of the control room (abovc).

At the exit meeting on 5/30'/75, the licensee reported that all work .had been completed in the auxiliary electric equipment room with exception of nine cables in 'the outh-east corner and some temporary cabling.

New Problem Areas (1) Nonessential/Essential Cable Separations (a) The licensee has identified that problems exist in the reactor building with re"pect .to the crossover of none"sential cables within essential trays." The FSAR,'uestion 7.4(a), states that nonessential circuit., may be routed in trays with esscntal circuits; hor;ever, nonesscntia3 circuits assi.gncd to segregated tray or section are required to (continued)

4 follow thc,sc.parathion criteria for,.an esscnt,ial

'cable in that same tray until tliey enter' control board. The magnitude .of this problein has not been determ'incd.

This 'is considered an item of noncompliance with respect to 10 CI'R 50, Appendix B, Criterion V.

The inspector found cable in the same tray of oppo'site bus or loop. had been routed using .asbe"tos zipper covering to provide separation . The I:SAI',,

Question 7.4(a), make no,provision ior this type oi routing, but requires that cable bc routed by

,segregated trays. Jw example, in .tray 23!I2 (auxiliary clcctric equipment roon)'he 'in pcctoi counted 18 separate 'bundle of yellow color coded (loop 2, bus 1) asbe tos zippered cable . Tbe other cable in this tray was color coded blue (loop 2, bus 2).

This is considered an item of noncompliance with respect to 10 CUR 50, Appendix B, Criterion V.

The inspector also iound that for caoles routed from trays to the J wall penetrations, asbestos zipper covering ':.as been installed to.maintain separ tion of segrr".;atcd cables. The I:SAR, Question 7.4(a) and (d), pecifies thc u"e of asbestos zipper covering from the trays to the control boards located in or above the auxiliary electric equipment room and the 480 vital switch-gear room area, and within control'oards. This applies where 6 inch separation cannot be maintained. Penetration I.'P-6..frcm the auxil'"ry electric equipment room 'into the reactor was cited 0 as an example in which approximately 100 cables had been routed with zipper covering. All buses and loops pa sed through this penetration.-'he use of asbestos zipper covering from the tray to the J wall pcnctrations is'onsidered ..n unresolved item, since the PSAR doe not describe this method of cable routing.

Thr licensee has initiated an extensive audit to dcterniinc the extent of the eparation" problem with respect to nonessential/essential c"blc Gcparati ons a the licensee believes that "he majority of thc c "ble which is <<ot meeting the I'SAR', gu tion 7.4(a),

(continued)

separations,critcri'a,is,nonessential .cable.

is based on an audit that was performed in 'his 1971 by the licensee to determine the separations of essential cable and circuits.

(2) Cable Tabulation During the tracing of cable, the inspector found that a part of the control cable associated with the emergency diesel generators was not designated as essential in the Cable Tabulation listing. These cablch are as follows:.'.7.096

...Control (Bu ..2) 7097 Standby Generator 1A and 1B Control Timer (Bus 2) 25194 Interlock Auto Sequences Programmer'or ESS Load (Bu 2) 26673 Sequence Programmer lB Control (Bus 2) 26715 Control (Bus 1/Bus 2)

Specification 1-N-2, Supplement 1, specifies that essential.

'cables are to be designated by a hexagonal symbol in the

'cable tabulation listing. Such identification was not evident for thc above listed cables.

The licensee seated in response to this finding, that although the C&le T"bulation appeared in error, these cables had been inspected during the 1971 audit conducted by thc licensee and. werc treated as essence:ial circuits.

.The licensee 'i.s, however, reviewing the Cable Tabulation

. List's.as part of the ongoing audit 'of the essential/

nonessential separations pr'oblcm.

~

This is considered to bc an item of nonco.pliance with respect to 10 CFR 50, Appendix B, Criterion V.

(3) Redundant Circuits tiithin Control Boards (a) The inspector found essential redundant cable" 25590 and 25593 (color coded blue/Loop 2, Bus 2) in the save race way in panel I-10, Eay 900, with essenti"3.

redundant cables 25722 and 25777 (color coded orange/

Loop 1, Ms 3.), and 25724 (co'or coded yellow/'-p 2, Eus 1). This intermixing of cable was idcntificd as a failure to maintain separation of redundant in trumcnt bus power supp3.ies (Bus 1 and Bus 2).

These two buses are associated with shutdown cooling actuatioh. Thc 1SAR, Question 7.4(d) specifics (continued)

that redundant circuits'ithin control 'board" .

will be separated by a minimum of 6 inches or atherwise suitable barrier're to be provided.

Modification and rerouting of 25590 and.,25593 was accomplished prior to,the .completion of this inspection. The licensee stated that this was felt to be only an isolated case.

This is considered to be an item of noncompliance with respect to 10 CFR 50, Appendix 3, Criterion V.

I (b) The inspector found that redundan't load shading

.relays 9200A .and .9200F~ for buses 1A and 19 were setting side-by-side in panel I-66. A. barrier for separations had not been provided as specified by PSAR, Question 7.4(d).

This is, considered to be an item of noncompliance with respect to 10 Ci'R 50, Appendix 3, Criterion V.

(c) The licensee stated at the exit meeting on 5/30/75 that a 100/ audit of all control panels .s"ociatcd with"'essential circuits would be performed for all circuit changes since the licen ee's 1971 audit of essential circuit (4) Low Level Sign~); Cable Trav Covers Thc inspector found that the solid metal snap-off covers had not been installed for tray" carrying low level signal

'cable in the 480.vital switchgear room "nd the equipment room. The CESAR, Question 7.4(a), speci-auxiliary'lectric fies that metal snap on-off covers are to be used for such trays.

The licensee stated at the exit meeting on 5/28/75 that covers will be provided following the completion of all.

ongoing inspection and corrective action.

This is considered to be an item of noncompliance with respect to 10 C1R 50, Appendix 3, Criterion V..

(continued)

ci Other Electr'cal 'Item" Di.scusse<l (1) Method .of 'Identi fvin Electrical Se >aration Def icicncies The inspector found that the licensee and contract:or personnel were identify'ng electrical separation deficiencies by tying whit:e strips of plastic flagging at each location. Documentation of flagged area'as not maintained. The inspector questioned that thi.

method provides assurance that flagged areas have been properly corrected.

The licensee stated at the e>."it meeting on 5/30/75, that a means for documenting flagged areas would be provided to assure that corrective action has been completed.

(2)'ire Sto~s The inspector questioned the pack of specific contractor.

inspection requirements to assure that repaired fire stops are properly inspected following the installation of new cable or conduit. Such worl: is performed under a contractor h'ork Authorization.

The licensee stated at the e>:it meeting of 5/30/75, that inspection requirement:s would be included as a part of the QA Inspector Checkli t performed by contractor QA personnel.

PCRV Coolin b.T (

Reference:

IE Inspection Report 50-267/74-04)

The licensee stated that a modification in the Control Pod Drives (CRD) penetration rea is being considered based on the results of B Series Testing (Sequence 1-7). The licensee stated that an apparent reverse flow of Helium up the CRD is occurring.

Post:ulated concrete temperatures in e>tcess of 250 F for power levels above 9% have been calculated. The installation of seals in th" CRQ's is currently being evaluat;ed.

IE:IV will continue to follow the statu" of this item.

"*'" """c "

The inspector reviewed test data (tests performed 5/22/75), which demonstrated that all four Helium Circulators can b transferred from normal bearing water to bacl:up bcarinp water without a trip of circulators occurring. In order for a successful transfer to occur, (continued)

a sw<<l <<,<<, o4 w<<<<<<<<IW, w' however, the emergency fcedwatcr heacier wah maintained at 2950-psig. The emergency feedwater headc:r supplies the bacl:up bearing water system. Xn elie past, the dip in beariug water pre. sure nor>rally resulted in a circulator trip due to ehe 475 psig bearing water low pressure trip. (The lowe.st pressure recorded during current testing was 590 psig.) This ineurn normally resulted- in the trip of additional circulators due,to the. apparent interplay in the 'buffer/helium syseem (buffer/mid-buffer trip).

'It is the licensee's intent (for present operation) that the feedwater header pressure will be maintained at 2950 psig 'mergency or greater by use of thc 8 n.otor oper ted feed pump. St ndard

..Operating Procedure (SOP) 21-01 anci. 31 have been temporarily changed to include thc 2950 psig emergency fecdwater header pres,ure require-ment for reactor, operation through Sequence tep 16 of the 3 Scrie" Testing. It i" the licensee's intent eo reappraise this situation prior to going beyond S% power (Sequence step 16).

7 ~ Items of Noncong>liance (

Reference:

IE Inspection Report 50-267/75-02)

Plant'0 erations Review Coma.it'.tee Hembershi A plant memo of 4/3/75 formally designates the alternate chairman and specifies that the ecretary and chairran are responsible to verify proper quorum.

IE IV c'oii-"'iders ehi., item closed.

b. Nuclear=lacilitv Safety Corznietee (NFSC) henber hi A company letter of 4/9/75 formally designaees NFSC r..cmbership.

Resumes of membership qualifications have been provided.

IE:IV considers this item closed.

C~ 'Semiannual Re ort/Pecord of Scrams A suppl.ement to the January 1975 Semiannual Report was forwarded to N!<C'n 3/14/75. The licensee stated that future Semiannual Reports will contain the proper information regarding scrars.

IE:IV considers this item closed.

. d. Late Abnorr:,al Occurrence Rc orts The licensee has stated that where a final report cannot bc:

made wi.thin 10 day., a prelir..i.nary report wi.ll be r:,ade. Recent reports have been timely.

IE:IV considers thi.s item closed.

(continued)

Status of h0 7S-03ll "!failure of !!o3 "turo Hoiiitors t~oTri st Safely S stem Sottin " (Reforonco: IF. Inspection Report 50-267/75<<04) ~

s.

~NLinas'ollowing.further review, the licensee is relocating the N2 lines in the moisture monitor penetration B-l through B-G.

This"m'odification is being performed to isolate liquid i%2 lines from the Ho sample lines. This work is being performed under Vork huthorization (hh) 11E1868 and is complete with exception of penetration B-3.

b. 'G&G 440 ? fois ture k!onitors Have not been installed.

Ce Heat Trace of Sam le'Line Installation and testing of the heat trace system for the Sample Lines is complete.

d. 'Technical Specification Chan:e Request for revision is under review by the Division of Fieactor Licensing. Additional testing by the licensee is being performed to sub"tantiate the chango request.

e. Procedure Comnlotion The overall plant administrative procedure specifying responsi-bilities and detail actions in the event of moi ture ingress had been drafted and is currently under review.

IE:IU will continuo to follow 'the status of this item.

Status o'f AO 75-02/7A ""Y!oisture Ingress and Reactivit ~ Anomal "

(

Reference:

IE Inspection Report 50-267/75-,04)

a. Remote Set Poin" Control for the Hi .h Pressure Separator Flow Controller Llork Authorization the E1810 and E1810-1 have been is"ued. The material required is on-site: All prefabrication has b cn om-plete. Installati.on is pending PCPV deprossurization.

b. PCRV/Sur to Tank'h" Indication 4'ork huthorization 4'h F1809 has been issued. The status is the same ss >>a>> above.

(continued)

Modification and Procedure Chan"c/Drain Valve pclton Covet" The material required is on-site. A Revised Field Change Notice has not yet been issued. It is still thc licensee's plan to modify the pelton cavity, outlet isolation control circuitry vice the drain valve control circuitry.

IE:IV will continue to follow the status of this item.

t UNITED - STATES NUCLEAR REGULATORY COMhllSSlON REGION III

/'-,%(~ip;;( ~'i ~<.

789 ROOSEVELT'ROAO GLEN KLLVN,ILLINOIS 60137 JUL.;~,8 i9VS Commonwealth Edison Company Docket %%,'o.. 50-284 ATTNt,1h. Byron Lee, Jr. Docket Ho. 50-265 Vice President Po 0. Box 767 Chicago, X11inois 60690 I'entlemen t

This letter is in response to ."r. Abel'sletter, to our office ~ ~

relating to our inspection of the Quad-Cities Station dated'uly 2, 1975,

'an 'April '30 "a'nd 'Ymy 1, 1975..

>M;th,respect to your. corIm!ents,on.Section%, Paragraph a. (1),,we <<ave reviewed .the text and have found. the,irnpection,results were appropriately documented.

Pith respect to your comments on Section 4, Paragraphs b.(l) and (2) we ackno!~ledge your cour..ent that the report only restates t'.!e specifications.

Se paragraphs shoula 'have included the follcwirgt '(1) 'Secondary contain-. ent penetrations through the tI:rbine buildin". reactor building wall are sealed with foamed concrete. R:V, and DUC seal. (2) SO.Ie spare conduit are not capped ao reau"red by specifications." Informatfon in the Public Document Room will be upgraded to reflect this change.

Lith respect to your counts on Section 4, Paragraph c., ~m find the desciiption accurate as stated.

Ve expect that you have completed vour inspection of electrical penetrations and that you have Implemented corrective actions if. required.

Should you have any additional questions corcern~mg -these matters, we will be glad to discuss tne"..I with you.

Sincerely yours, Caoton. riorelli, Chief Reactor Operations Branch bcc w/ltr dtd 7/2/75t PDR Local PDR NSIC TIC  %

Anthony Roisman, Esq.

gO~Ioe@

7776 g91+

a g u;~!Tro svF!mrs NUC LLAI! 0 t. (! t U 'h'f(il!Y CO'1I" l S~!0'0 nr Oln.'!

l 6 I I'AIIK A V I. W O C KIIIG OI'IIU bIA, I'I'tIIi!.YlVAIII* la Ot,

'UG 7 875 Roche'ster Gas and })3,ectric Corporation License  ?:o. DPR-18 .

Attention: 1}r. Leon D. l.'hite, Jr. Inspection Zo. 75-10 Vice President Docket t'o. 50-244 Electric and Stca~ Production 89 East Avenue

,Rochester, Ãcw York 14649 Gentlemen'.

This refers to thc inspection con(!ucted by }lr. J. Hannon of this of"ice on J01; 15-18, l)75 a" t}Ie, Ginna Facili.ty, Ontario, Nc:~ .'o'k,'rrl tlic Corporate }1or..e Office in Rochester, llew York of activities aut'horized by

?'RC l,iccnse Iio. }F:n-18 and to the discu"sions of our findin.."s he3d b;

}lr. llannon vith llr. Lang '".nd oth r. ne,.bars of your st,.ff at the conclu-'ion of th( insp..ction, and to a su})sequ<<nt te3.epho! e discussion bet..=e.:

}ir. 11-nnon and !!r. Platt of your staff on July 23, 1975.

Are s Qz ~ 'l nell dul in'h'!'!Sliectio!1 are (1c cribed in tile Of f .c ' i Inspection an: En orrr:Ie! lns,.cctio;1 Report which is enc3.os:1 with this letter. 4'it}lin til(". o area'he i'lspcction cor. istcd of sele 'ive cxaainations o~ procedures and representative records, int(livic!)s with personnel, an< obscrvati.ons by the inspector.

Our inspector al o verified th( steps'you 1!ave taken to correct thc Xt(:;.!s of. l'.otlco-.::,ili nc br;!I",ht tc your attention zn a letter dated February 14, 1975. Ve h vc no 'urtl!er questions regarding your action at this ti.".;c.

Ea"cd on the result" of this inspection,

~ ~ ~ I it appearswiththat

~

certain of your activities !;ere not conducted -'n full co!.".p3.iance l'IRC rcruire:".cnl s, as .,et forti! in the llotice of Vio ation, enclo'cd hercwi.th as Ap}len:!i.;:

. A. These ite~s of nonco1pliance h ve. bec;1 catcF orized into the love's as described in our correspond<<ncc to you dated Dece;!ber 31, 1974. ~ 1!is notice is sent to you Pursuant to the provisio!I., of Section 2.201 of the XI'PCIs "Rules of .Practice", Part .2, Ti"le 10, Corlc of FeF1eral Rcgulatinrs.

Section 2.201 rcruircs you to sub;"..it tn thi.s office, within twenty (20) days of y<. r receipt o 'his notice, a ! ri tten statement or e>:planation in reply inc.l.udin": (1) corrective steps ~.'i!ich have been ta!:en l)y y(u t

I and thc r; ult achieved; (2) .co ccctive step which vill bc tal;cn i.o avo1d furt!Icr it<<."..!s of nF neo:".pliance; an'd (3) thc date when full co"..

I ~

pli;Ince wi!1 be achieved. In addition to the need for corrective action

. o<<"oi~

1P), I 1()

4 regar.'.<ng thc e p<<cifi items n nonco::". Iiancc ve a> <<concerned about th<:"it::. erne:.tatioi> of ~'.<'- quali>.y assurar:;.e progrmn that "err!ittcd th<<n to occur. Consequentl>, in your reply, you should desc"i! e in part:i.cular, those actions t:;l;cn or.>>lanned to ir>prove tl!e effectivi,:>.!ss of your.

quality assurance l>ro;:.am. As sho!:n in tl><< llotice of Viol.tinn, enclo ed with this letter, lti No. D is a recurrent or uncorrected item. In your respo:>'e pl<<ase give this matter your particular attention.

I Another acti '>y appears to bc.a.devia!:.on from an appropriate code, standard, or guide, as set forth in the l'otice.of Devi: !ion, enclosed herewi.ti> as Al>p::ndi:.:3. tlith respect to this,de; iation, .plea.. include in your response yo:: comments concernin:- thi.s 1tem, a de..cri;:, ion of any steps that have been or will be tak~. t'o correct of any steps th.".t have been or vill it, a description be t:..:en to prevent recur ...>ce, and the date <!11 c.:rective actions or prev>>: ive mea'ures are or will b~:

complete'a> ~

.In a<<corda.".ce >.'.h Se""ion 2.790 of the hRC's "Rules of Practice", Part 2 .Title 10, Co.'f Federal Regulations, a copy of this let:ter and ti>e enclosure's vil> he pl:::-.d r! the t;":,C's Public Doc!!ment Room. If t:his report contains any i:..nr." ion that you (or your contractor) belie':e to be propriet:cry, it is necessary that: you mal:e a written; p>>lication within 20 d-.s to :i>is office to w1'.'. old such in; nr.:ati.r from public disclosure. An> 'such apl>licat.i .> r.u:: include a full stat.et'.~ nt o.'ne, rc"sons on the basis <,'. which i.t i'.'.ir:d tl>at t!>.. i>> for>:.ation s proprietary, and should be pr:"..ared . that proprieta' 'information identified in the application is co! 'ned in a eparat:e p..rt of th" document. If >'e do not hea" fror> y<<". in this re! ard t:it! '.n the period, the report vill be pl;,:. d in the Publ" c Document Ro: "..

speci-'ied I

Should you have any qu- tio".s co>

~

.. ning this inspection; ve will be pleased to discuss t! .:. with you.

• Sincerely, (g Q((l D rector

Enclosures:

l. Appen>>'ix A, Notice of V;olation.".

2.. Append.lx 8, lloticc of DeviaLion

3. .IE:I Inspection Rcport Ko. 50-244/75-10 cc'. C. Platt, Plant Superintendent A. E. Upton, Esquire T. R. Scl>uler, gC Engine e hcc:

IE !iie'f FSl."..B

~

Il:,:lip (4 cys ltr. 5 cys xepor')

IE Files Central Hail 6 Fil>>:

Director" !-. nf Lier. -in@ (~: 13 c y" 1.>>,io'>>

Rculatory .:>>:: .Jar>>l. f3 cy i tv, cys r>>; or".)

PDR Lo>>. 1 .I ..'.

~~

TI>>'F(. " il>> ~: - ~ ~ ~

Re>>".

El.>.

Dii ':";. ' 'I, 1XI, l'! (! , art 0;".ly)

St;.:: ~ '.

Liccn.,e No. DiR-'38 APP1'!DDT>i A rOTICB 0:: VXOLATln S Based on the results of an NRC inspection conducted on July 15-18, 1975; it appears that certain of your activitic;:: were not conducted in full Pacility License compliance with conditions of your 1"RC 1:-o. DPR-18 as indic.".ted belo;;:

A; Contrary to 10 CFR 50.59 th; plant was operated without f1=..e

,...barrier. m~tcrial installed s-stated on page 8;2-GC of "the Ginna Station PDSA and no evaluation oi this desi:- change was made.

This Infractii .I >>:id the potcritial for causing or contr'butin~ to an occurrence rclat.cd to health arid ...".fcty.

The inspcctc. vcr::"ied corrcctiv;: actions to bring the cable pe>>etra-tion install "ion i>> c":.-.Pliance with the PDSA and additional action" taken to up radc the ala.ae barrier material to current "t.".ndards.

~

Based on this rcvic~:, no further action is required at this ti B. Contrary to Tech >ical Specification 3.3.l.lc, the "C" safety injection pump was inc; ;:.hie from iiay 27 throu h June ll, 1975.

This Infract'i n had ti ~ p tc.nti, 1 f'r causing or contribut.'.ng to n occurrence related to health an safety.

Uhile this item was identified and reported proper'ly by the licensee, the corrective action to preclude reci':rcnce was ju.!ged to be inadequate. Additional ..ction anid a response to this item is required.

C. Contrary to 10 CPR 50, Appendix B, Criterion UI, Ginn". Station Quality Assurance )hnual, Section 6, Revision 1, DOCL";i's.".T CO:lTROL dated 10/2/74, and QC 602, Revi ion 8, PLA T PRO'.DURE DOCl,";=-NT CONTROL date<'. 4/12/75, adninistrativ procedures governin" safety related activities were reviewed and approved for use by person other than the PORC, QC, and Plant Superin','.:ndent.

,This item is a Deficiency.

D. Contrary to Technical "pec.':ication 6.4.1. the plant was being operated with unapproved pr ..Lures, in that:

0 t<.u (2) unapproved procedure: were found posted in the au.:iliar" build:i.i.;;; an

2. unap1."ovcd Standing Orders were found to amplify, modify, and direct plant operations.

The abo:e con..'.itutcs a repeat item of noncompliance. Failure wi(.h thc .:arne basic requirement: was brought to your atten- to'omply tion in a'1!otic":. of Violation following inspection 74-08 date" Septr:.'>er 27, 197~i.

This item is a Deficiency.

E. Contrary to 10 CFR 50, Append:i 3, Criterion >XII an;1 Quality Assurance 1hnual Chapter XVII, operating logs wit.h the c.".ception Shift Foreman Log and Official Pecord, were found to have no of'he admiri:"tr"itive control for review and, retention.

Thss item is:. Dc~.i.ci: ncy.

F. Contre.ry to '0 CPR 50, Append;:" 3, Crit:",ion II and Quality P~ ur-a;.'. '":.au;:1 ~ection 1.3., th,. vain steam i olation val." 'solcn '

air ~, ply valv-s are not considercr'ai':.ty related "nd are not inclu ..;d in th~ Qual'ty A::suran"e Progr';.i.

This item is a Deficic.:.cy.

~ ~

License ll . DPR-.3.':

0 APPEliflXX NOTICE 0!'

!'VIATIOl'.

Eased on the rc"ults of an NRC inspection conduct'ed on July 15-18, 1975, it,appears that on'. of your activities having: afety significance was not conducted in 'ci nformance with general'ly .accepted industry practice, as indicated below:

Contrary to ICRU Rcport 20 RADIATI!".! PROTECTION INSVRl~ilEl; 'i.TZ~Z; AM)

XTS-JZPLlCATXON, 'Section "IV Calibrd:."on"of'ns:.:ruzentation, issued October 1, 1'971, there i as no evidbi'.c that th<<portal rionitc:.". in use at the p3...>>t had be.;.i calibrated within a period of time th:.t would reasonably be expected, to verify proper operation.

Tl. = iteiii is a Deviation.

P

I Fon,i 12 n 75) (Rcv) 9, S. liUCLEt& REGULATORY CO:.OMISSION OFFICE OF INSPECTION 4ND ENFORCE.'1E!6' REGION I Inspec tion Repo'rt No: 50-244/75-3.0 Docket No: 244

.Rochester,'Gas .and Electri,c,Corporatio>> License No: .DPR-18 89 East Avenue Priority:

Rochester, New York Category:

Safeguards Group.'

ation'. Ont,.rio, Nev 'York

-of Licensee::PlP, 1520 Ifl'e (l.')

of Inspection.

~

.'outine Unannounced

. es of Inspcc tion ~

Julv .35-18, 3.975 es of Previous Inspection. June 19-20, 1975 orting Inspector:

'.ompa nying Inspectors:

o;",~Key'ctor Inspector ATE DATE

'er Accompanying Personnel:

DATE red By: J ~tl~/ ~ rP ~ <<1 ~~7 A. B.~ 6avis, Senior Reactor 1nspector

~ DATE Reactor Operations Branch

SUMMARY

OF FlNDIt:CS A. Items of Noncom 1iance

l. Violations None

2. Infractions

a. Contrary to 10 CFR 50.59 the plant was operated without flame barrier material installed as stated on page 8.2-6c of the Ginna Station FDSA and no evaluation of thi design change was made. (Detail 4.f)

3. Deficiencies

,.a. Contrary to QC 602, Revision 8, "Plant Procedure Document Control," dated April 12, 1975, administrative procedures governing safety-related activities were reviewed and p-proved for use by persons other than the PORC, QC and Plant Superintendent. (Detail 4.c)

b. Contrary to Technical Specification 6.4.1 the plant was being operated with unapproved procedures. This is a repeat Iten of Noncompliance reference Report 50-244/

74-08. (Details 9.a(3) and 9;d)

~

-c. Contrary to 10 CFR 50, Appendix B, Criterion XVII and the QA kfanual, Cnapter XVII, operating logs with the exception of the Shift Foreman's log and the Official Record, were found to have no administrative requirements for review and retention. (Detail 9.c)

d. Contrary to 10 CFR 50, Appendix B, Criterion II and the

~

Qh Hanual, Chapter 1.3, the Hain Steam Isolation Valve solenoid air supply valves are not covered by the QA Program. (Detail 5. c)

B. Deviations (These are areas which do not conform to licensee commitmcnts to the NRC or to provisions of guides, codes, standards and acceptable practices which have safety significance, but are not Items of Noncompliance.)

Contrary to accepted industry practice, there was no evidence that the portal monitors'in use at the plant had been calibrated within a .period of. time that would reasonably be* expected to"verify proper operation. ,(Detail 9.e)

Licensee Action on Previousl Identified Enforcement Items A. Corrective actions taken in response to remaining Items of Noncom-pliance identified in IE:I Report 50-244/75-01 were reviewed. ~

(Detail 3)

A. Installation of Penetration Seals with BISCO Silicone foam. (Detail 4.,f).

Unusual Occurrences A. Failure. of 1C Safety Injection Pump to start manually from Bus 16.-

(Licensee report to Directorate of Regulatory Operations dated February 14 and 26, 1975, AO's 75-2, 75-3, and 75-5) (Detail 5 b(l))

B. Failure .of "A" hfSIV solenoid air supply valves during surveillance test. (Licensee report to Directorate of Regulatory Operations dated February 21, 1975, AO 75-04) (Detail 5.b(2))

C. Inadvertent insertion of greater than .5% hKlK with the reactor subcritical. (Licensee report to Directorate of Regulatory Operations dated Harch 25, 1975, AO 75-06) (Detail 5.b(3))

D. Abnormal dcgradaH.on of steam generator tubes. (Licensee reports to Directorate of Regulatory Operations dated April 7, and Hay 8, 1975, AO 75-07) (Detail 5.b(4))

E. Degradation of charcoal filter iodine removal efficiency. (Li-censee report to Directorate of Regulatory Operations dated April 17, 1975, AO 75-08) (Detail 5.b(5))

F. Pinhole leak in CRDN housing. (Licensee rcport to Dirccroratc of Regulatory Operations dated April 22, 1975, AO 75-09) (Detail 5.b(6))

Q. Improper SI System Valve Lineup. (Licensee report to Directorate of Regulatory Operations dated June '25, 1975, AO 75-10) (Detail 5.b(7))

H, Improper reactor coolant sampling frequency. (Licensee report to Direct:orate of 'Regulatory Operations dated June 30, 1975, AO '75-11)

(Detail 5.b(8))

Inadvertent drop oi two control rods. (Licensee report to Dircctor-at'e of Regulatory Operations dated Harch 17, 1975, Unusual Event:

75-01) (Detail 6.b)

J. Leak at letdown line drain reducer weld. (Licensee report to Di'rectorate of Regulatory .Operations dated Hay 8, 1975, Unu ual Event 75-02) (Detail 6.b)

Other Significant Findint,s A. Current Findings

1. Accc table Areas (These are area. which were inspected on a sampling basis and findings did not in.olve an It:em of Noncompliance, Deviation, or Unresolved Item.)

a. Review of Previous Items of Noncompliance. (Detail 3).

b, Review of Unusual Event Reports. (Det:ail 6)

c. Review of Startup Testing. (Detail 7)

d. Review of Refueling Outage Operations. (Detail 8)

c. Review of fuel integrity indications. (Detail 10)

2. Unresolved Items

'(These 'are items for which, more information is required in order to determine t"hether item" are acceptable or Items of Noncompliance.)

Hone identified

3. Licensee Idcntifi:cd .Items of Noncom liance

a. Infractions Contrary to Technical Specification 3.3.l.l.c the "C",

Sa'fety Injection pump was inoperable "from May -27 through June 11, 1975. Corrective action to 'preclude recurrence

hs judged t'o b'6 inade'quate. Additional action and a to this item is required. (Detail 5.d) 'esponse Contrary to Technical Specification 4.1.b, Table 4.1-2, Note (1), reactor coolant sampling frequency was not in-creased to once per day as required. (Detail 5.e)

B. Status of Previou lv Unresolved 'Items<

1. The following items h ve been resolved:

a. Modified time delay circuit board in the 81-1/llB under-frequency relay. circuit for- the 4160 volt bus 113..

(Detail,4.d)

b. Training program for Maintenance Department (including

, I&C) personnel. (Detail 4.b)

c. Usage of Chemistry Procedures.'Detail 4.e) d, Prerequisite signoff blocks for certain r'efuelirg proce-dures.'Detail 4.g)

e. RG&E interface with Gilber;t Associates for design activ-ities. (De'tail 4.h)

f. Interface between corporate and plant personnel for design changes and modifications. (Detail 4.i)

2. 'ore information is required to resolve the following items:

a. Facility Requirements for Fire Stops on Electrical Safcty-Related Cables and Penetration Seals in Maintenance and Modification procedures. (Reference Report 50-244/75-07)

(Not 'addressed in this report)

• Items identified in previous inspection reports as Open Items, have been reclassified as Unresolved Items.

b. Evaluation of feedwatcr line vibration report. (ReEerence Report 50-244/75-09) (Detail 4.a)

c. 'Conflicting license requirements for containment leaL rate testing. (Reference Report 50-244/75-05) (Not ad-dressed in this report)

Mana ement Intervihw

-A .management interview -was held -at 'the=site =-on-July 18, 1975.

Personnel Attendin Mr. F. Aman, Office Supervisor, Security Supervisor Mr. C. R. Anderson, Quality Assurance Coordinator Mr. Yl. Bacchus, Shift Foreman Mr. L. S. Lang, Assistant Plant Superintendent Mr. J. C. 1loon, !!aintenance Engineer Mr. G. H. Paris, Instrument Foreman Mr. B. R. Quinn, Health Physicist Mr. T. R. Schuler, Quality Control Engineer The following suxrrari,z'c..s the items discussed'.

Purpose of the Inspection. (Detail 2)

B. Review of Previous Ite..s of Noncompliance. (Detail 3}

C. Review oE Pr'eviou Unresolved Items. (Detail 4)

D. Review-of Abnormal Occurrence Reports. (Detail 5)

E. Review of Unu ual Event Reports. (Detail 6)

F. Review of Startup Testing. (Detail 7)

G. Review of Refueling Outage Operations. (Detail 8)

H. Review of Plant Operations. (Detail 9)

I. Review of Fuel Integrity Indications. (Detail 10)

DETAILS

1. Persons Contacted Mr. Aman, Office .Supervisor, Security Supervisor C. R. Anderson, QA Coordinator F.'r.

Mr. M. Backus, Shift Foreman Mr. E. J. Beatty, Shift Foreman, Procedures Coordinator Mr. *S. V. -Bullock, QC Technician Mr. E. L. DeHerrit, Supervisor, Chemistry, and Health Physics Mr. E. C. Edgar, 16C Technician Hr. R. Eliasz, Nuclear Engineer (telephone) ~

Mr. C. V. Hartlieb, Results and Test Coordinator Hr. R. Juno t, Shi ft Foreman Mr. R. 11. Latz, Electrical Foreman Hr. R. C. MeCredy, Manager, Nuclear Engineering Mr. T. Heyer, Cadet Nuclear Engineer Hr. R. M. Morrill, Training Coordinator Mr. J. C. Noon, Maintenance Engineer Hr. G. H. Paris, Instrument Foreman Hr. C. H. Peck, Nuclear Engineer Hr. B. R. Q inn, H..alth Physicist Mr. J. Scheetz, Manager, Electrical Engineering Hr. T. R. Schuler, Quality Control Engineer Hr. R. E. Smith, Assistant Chief Engineer Hr. S. H. Spector, A sistant Maintenance Engineer

2. Ins ection Pur ose The inspector stated that the purpose of the inspection was to:

a. review certain items identified in previous inspections;

b. review se3 cted Abnormal Occurrence and Unusual Event Reports;

c. review startup testinc and refueling outage operations;

d. review plant operations; and

e. examine fuel integrity indications.

The licensee acknowledged this i'nformation.

3. Corrective Action Review (Reference Licensee letter to Chief, Reactor Operations Branch, Region I, dated March 21, 1975)

a. The inspector's review of corrective actions in response to Rcport 50-244/75-01 included: P

(1) record reviews, observations and discussions with licensee personnel to verify that corrective measures taken were as described in the response letter; (2) verification that appropriate management controls were invoked to avoid further occurrences; and (3) observation of posted copies of enforcement correspondence as required by 10 CFR 19.11.

b. The following documents (by iten number) were examined for each item discussed in the licensee's response letter:

(1) A 37.0, Revision 2, "Conduct of Operations for Safety Evaluations as Related to Facility "Modifications, Special Tests or Experiments," dated March 13, 1975; (2) gC 401, Revision 5, "Control of Procurement Documents for Purchased Materials, Parts, Components and Services,"

dated March 20, 1975; (3) Audit Finding Corrective Action Report dated March 10, 1975; (4) QC 801, Revision 4, "Control of Accepted Material, Parts and Components," dated March 14, 1975; (5) (This item previously resolved in Report 50-244/75-05);

and (6) New Procedure for Removal of Ori:ginal Drawings from the File Room dated January 24, 1975.

The inspector had no further questions on the licen ee's resolution of the above items. Findings were acceptable.

4. Previous3 Identified Unresolved Items

a. Feedline Vibration (Reference IE:I Report 50-244/75-09)

(1) The inspector observed readout instrumentation from LVDT's located on the feedwater piping inside contain-ment. The instrumei tation indicated pipe motion of less than 0.1 inch while the plant was at 100/ power.

The "B" feedwater pipe appeared to exhibit the most

steady -state vibration. The following criteria had been established:

(a) movement > O.l inch notify duty engineer; and (b) .movement > 0.25. inch change load.

(2) ST-75-4, Revision 1, "Turbine Plant Start-up Program Following Plant Trip of 0956 Hours on 6-1I-75," dated June 26, 1975 was completed on June 27, 1975. This pro-cedure provided for controlled power escalation above 25%, and had been successfully employed to achieve'full power operation.

(3) June 1975 Hain Steam and Feedwater Uelds Examination Final Report was reviewed. This package included liquid penetrant examination records, visual examination records, and instrument calibration records pertaining to NDE in-spections conducted in accordance with cor ~itments to the NRC documented in Report 75-09.

(4) The licensee stated that a,r'eport to the NRC including an evaluation of the vibration transient would be suo-

.mitted by July 18, 1975. dphil>>'he licensee's actions appear to be appropriate, the inspector stated that this item will remain unresolved pending a revie~ .of the li-censee's report.

The licen'see acknowledged this. information.

b. Haintenance De ar'tment Trainin (Reference IE:I Report 50-244/75-01)

A-50.7 {Draft) "Haintenance Training Program," was reviewed.

The licensee stated that this procedure covered all Hainte-nance Department Personnel, including Instrument and Control

. technicians. The licensee stated that the draft procedure had received a PORC approval on July 14, 1975, and was'ur-rently being process d for issuance. The inspector had questions on this item. This item is resolved. no'urther C~ Chemistr and H~.alth Ph sics Procedures

{Reference IE:I Report 50-244/75-01)

(1) The inspector reviewed the following items wi'th respect to the licensee's program for upgrading the subject procedures:

(a) QC-602, Revision 8, "Plant Procedure Document Control,"

Figure 1, dated April 12, 1975; (b) Memorandum from G. Hoyt Whipple (University of Mi.chigan) dated March 1, 1975 containing comments and suggestions on .selected HP Procedures; (c) Health Physics and Chemistry Procedures; (d) Radioactivity Discharge Procedures; (e) Primary Chemistry Procedures; (f) Water Chemistry Procedures; and (g) Environmental Sampling- Procedures.

(2) The following are examples of those procedures that ap-peared to be primarily administrative in content:

(a) HP-O, "Format for Health"Physics .and Chemistry Pro'cedures," dated January 9, 1975; and (b) PC-0/WC-O, "Chemistry Procedure Usage, dated July 1, 1975.

(3) The inspector noted that contrary to the requirements of QC 602, Revision 8, dated April 12, 1975, certain ad in-istrative procedures governing safety-related activities conducted by the Chemistry and Health Physics Department appeared to have been approved for use by persons other than the PORC, QC, and Plant Superintendent.

This item is a deficiency.

(4) The inspector identified other examples of the above deficiency during a review of plant operations. Specifi-cally, Operations Standing Order A-73-1 dated February 3, 1975 describes the policy for Operations Standing Orders; although an administrative document affecting safety-related activities, it was issued for use without the required review and approval.

Inter. Office Correspondence entitled "Visitor Instructions" dated February 5, 1975 issued by the Office Supervisor to Security Force Personnel required persons to remain in the

portal'onitor for five seconds upon egress from the plant.

'his'dministrative document had not received the required review and approval. In addition, the inspector noted that several persons observe'd at random remained in the porta3 monitor for a period considerably less than five seconds upon egress from the plant. Apparently the docu-ment.was ineffective in achieving 'the desired 'result.

The licensee acknowledged these additional examples of the above .deficiency.-

(5) The licensee prcvidcd.the following status with respect to procedure updating:

Procedures Completed as of Planned JU'1 ~

18 3,9 75 Health Physics 35 32 Primary Chemistry 22 20 Vater Chemistry 31 31 Radioactive Discharg" Environ:-::nta3.

ll

.10 1

)U.th the exception of the Environmental area, the licensee plans to complete the remaining procedure by Octob r 1, 1975. The remaining environmental procedures are expected to be available by December 31, 1975, although this may change when new Environmental'echnical Specifications are issued.

UP Rcla Hodification (Reference IE:I Report 50-244/75-'1)

(1) The inspector reviewed the following documents with re-spect to the licensee's intended action to upgrade the 4160.volt bus relay installation:

(a) S~f 75-30 Replace existing 4 kv UF Relays with new relays on Buses llA and llB dated July 14, 1975'nd (b) the safety analysis for EDR 10GS, Revision 1, dated July 7, 1975.

(2) The licensee stated that five new replacement relays had been tested satisfactorily, four of which would be used in the installation, with the renainder placed into spares.

The inspector had no further questions in this area at this time.

This item is resolved.

e. Chemistr Procedure Usa e The chemistry department prepared a list of complex or infre-quently accomplished analyses that will be conducted by pro-cedure. This list was included in PC-0/VC-O, Chemistry Procedure U'age," dated July 1, 1975. The inspector had no further questions on this item at this time.

I This item is resolved.

f. Flame .Barrier In tallatio>>

(Reference Report 50-244/75-07)

(1) The licensee stated that the lack of flame barrier mate-rial in penetrations as committed in the'FDSA was not a result of modifications in which flame barrier material had been deemed not to be 'afety-related, but rather an apparent omission during construction.

Maintenance Procedure No. H-56.1, Revision 0, "Removal and Placement of Penetration Seals," dated Hay 5, 1975 provided for the placement of ceramic fiber material in accordance with the license application, as described in Engineering Specification EDR Ho. 1070, which invoked the requirements of page 8.2-6c of the Ginna Station FDSA. This maintenance activity was conpleted on May 10, 1975.

SH 75-32~ Revision 0, "Installation of Penetration Seals with BlSCO Silico>> Foam," dated Hay 5, 1975, was com-pleted on June 5, 1975. The inspector noted that the existing fire barrier material was removed prior to the installation of silicone foam in each case where the foam was installed.

(2) The inspector stated that contrary to the requirements of 10 CFR 50.59:

(a) ~ thc plant had been operated without flame barriers installed as described in the safety analysis'rcport; (b) 'prior Commission approval had not been obtained to so operate the plant; and (c) no written safety evaluation was available to indi-cate that the omission of these barriers did not constitute an unreviewed safety question.

This infraction had the potential for causing or contribut-ing to an occurrence with safety significance.

The inspector stated that the licensee's corrective actions appeared to be appropriate and no further response is con-sidered necessary at this time.

The'licensee acknowledged this information.

(3) The inspecto: stated that based on the corrective action taken in H-'..i.l and S';f 75-32, it appeared that no further action wouln be necessary as a result of this infraction.

The liccnsci acknowledged .this information.

(Reference Report 50-244/75-05)

The inspector observed that Procedures RP-42.0, 43.0, 44.0, and 45.0, Revision 1, dated June 12, 1975 in each case pro-vided for signoff verification of initial conditions.

This item is resolved.

h. interface Controls with Desi n Contractor The inspector determined that the following procedure had been prepared to define the interface:

Review of Architect Engineer Design Docu, cnts Ginna Station dated Harch 8, 1975.

This item is resolved.

.- .13 Cor orate and Plant Desi n/Modification Interface The inspector determined that the following procedure had been

.revised to define the interface:

Design 'Modification Control, Revision 3, dated March 26, 1975.

This itom is resolved.

• 5. Review of Abnormal Occurrence Renorts

a. Selected Abnormal Occurrences were reviewed to verify that:

(1) The cause was identified and that details were clearly reported to the NRC and facility management; (2) Corrective action described in the licensee's report was taken to prevent recurrence; (3) Each event was reviewed and evaluated as required by the Technical Specifications; and

/

(4) Safety limits, limiting afety system settings, and limit-ing conditions for operation vere riot exceeded.

This review included inspection of PORC minutes, Maintenance Requests, Maintenance Procedures and Maintenance Records, Surveillance Procedures, Procurement Documentation, and dis-cussions with various staff. personnel.

b. The following Abnormal Occurrences were reviewed:

(1) AO 75-2, AO 75-3, and AO 75-5, Failure of 1C Safety Injection Pump to start manually from Bus 1G; (2) AO 75-4, Failure of solenoid test valves to operate on

~

"A" Main Steam Isolation Valve during surveillance test; (3) AO 75-6, Unplanned insertion of greater than 0.5% AK/I:

with the reactor subcritical; (4) AO 75-7, Abnormal degradation of Steam Generator Tubes; (5) AO 75-8, Degradation of Charco'al Filter iodine Removal Efficiency;

-14<<

(6) AO 75-.9, Pinhole leak in cap attached to Magnetic Control Rod Drive Travel Housing K-7; (7) AO 75-10, Personnel error which could prevent the fulfill-ment of the functional requirements of systems required to cope with accidents analyzed in the SAR; and (8) AO 75-11, Failure to increase reactor coolant sample test for gross radioactivity concentration to a minimum of

.,once.per.day when .gross radioactivity..concentration ex-ceeds lOZ of the limit specified in Technical Specifica-tion 3.1.4.1.a.

Co During the review of AO 75-04 it was noted that the Hain Steam "Isolation Solenoid Test Valves are not treated as safety-related and their spare parts are not included in the Quality Assurance Program.

This is contrary to 10 CFR 50, Appendix B, Criterion II, and the Quality '".:.:urance Manual, Section 1.3.1.1, which states, in part:

"The quality assurance program shall apply to all activities affecting ti e safety-related functions of all existing Seismic Class I structures, systems, and components, including their foundations and supports, that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health. and safety of the public."

This item is considered to be a deficiency.

As another example, the inspector inquired about replacement parts for the Incore Flux Monitoring System to determine if they were being purchased under the QA program. PO No.

5-ZZZ-57554 dated March 19, 1975 for a drive wheel and hub assembly was observed by the inspector to meet the QA pro-gram requirements.

d~ AO 75-10. The .isolation of the "C" Safety Injection pump from May 27 to June ll, 1975 is a violation of Technical Specification Paragraph 3.3.1.l.c.

The licensee s corrective action was judged to be unacceptable in that no method for the verification of status lights on safeguards equipment when assuming 'control board duties has

I

~

~

been promulgated. The licensee agreed to e tablish and imple-.

ment a mechani ".". for safeguards equipment status light verifi-cation. The in:;pector stated that this item was considered to be an infraction and will require a response from the li-censee. The licensee acknowledged this information.

e. AO 75-11. This occurrence was in noncomplj.ance with Technical Specifi'cation paragraph 4.l.b, Table 4.1-2, bote (1). The li-censee's corrective action appears adequate and nn response

~,.required to -this deficiency.

f. Except ad described above, findings vere acceptable.

ge The circumstances associated vith the maintenance of two safety-related pieces of equipment were reviewed relative to Technical Specification reporting requirements. This in-c1uded the Pressurizer Power Operated Relief Valve and the Pressurizer Relief Guard Valve. Findings were acc'eptable.

6. Unusual Events

a. Selected Unusual Events were reviewed to verify that:

(1) The cause vas fdentified and that details vere clearly reported to the NRC and facility management; (2) Corrective action described in the licensee's report was taken 'to prevent recurrence; (3) Each event was reviewed and evaluated as required by the Technical Specifications; and (4) Safety limits, limiting safety system settings, and limit-ing conditions for operation were not exceeded.

This review included inspection of PORC minutes, '.faintenance procedures, Station Hodification Documentation, Quality Assur-ance Records and discussion with various staff personnel.

b. The following Unusual Events were reviewed:

(1) UE 75-1, Drop of two control rods; and 4

(2) UE 75-,2, Small leak at letdown line drain weld.

c. Findings were acceptable.

16 .

7. Startu i. Tcstin a~ The inspector reviewed the following items to determine that selected pre-critical and post-critical checks were performed in accordance, with Regulatory requirements:

(1) ,S-15.'2, Revision '2, "Flux Happing Emergency and Calibra-tion'Procedure," dated hp'ril 16, 1973, completed on July 2, 1975; (2) Startup Physics Data, (Preliminary) dated Hay 14, 1975; (3) Flux Haps V-9 through V-12 dated July 9, 1975; (4) S-15.1, 'Flux Hap V-12 dated July 1, 1975; (5) Ini'tial Design Target Hand 'with -3.6% Axial Off et dated Hay 7., 1975; and (6) Target Band with -4.5%'xial Offset issued after Flux lfap V-12 dated July 8, 1975.

b. The'nspec'tor'oted terat the all rod out predicted boron concentration at criticality vas 1392 ~;pm and measured was 1402 ppm. Similarly, the predicted .isothermal te-,peratu e coefficient was -7.4 pcm/oF and the measured was -3.9 pcm/oF.

The inspector had no further questions in this area.

Findings vere acceptable.

a. The inspector reviewed the following i.tems to deter'mine that selected systems disturbed or tested during the refueling outage were returned .to an operating status prior to plant startup:

(1) RSSP-ll, Revision 2, "Pressurizer Safety Valve Test 434," dated March 5, 3.975, completed April 9, 1975; (2) RSSP-7.0, Revision 3, "Control Rod Drop Test," dated September 24, 1974, completed 'fay 9, 1975; (3) CP-209, Revision 0; "Calibration of Area Honitors-Th-62 Detectors (R-l-R-9),".dated June 3, 1975, com-pleted July 9, 1975; and

(4) CP 46l, Revisf on 0, "Calibration and /or Haintenance of Steam Generator Level Channel '461'," dated January 18, 1974~. completed hpril 6, 1975.

Findings ~ere acceptable.

9. Review. oi Plant 0 erations

a. Shift Lo s and 0 eratin Records The inspector reviewed the records listed below. The review was governed by the licensee's administrative'rocedure A-20.

(1) Shift Foreman and Official Record: Entries vade for the period June 1-July 15, 1975 were reviewed. Documentation involving abnormal occurrences met the requirements of A-20.

(2) Log Book Reviews: The Official,Record and the Shift Foreman's Logs were observed to have been reviewed at least, once per week by the Operations Engineer for the period of June 1-July 15, 1975.

~

(3) Operating Orders: The Operations Engineer Standing Orders were reviewed.

It was noted that several of these orders appeared to amplify, modify and direct plant operation.

This is contrary to Technical Specification 6.4.1 which states, in part: "The plant shall be operated and main-tained in accord:.nce with approved procedures."

The inspector noted that this practice was also incon-sistent with h'!SI N18.7-1972, which allows for standing

'orders for "dissemination to the plant staff of instruc-tions of general and continuing applicability. to the conduct of business." Exa-.ples given included defini-tion of duties and 'filing of charts, as opposed to the actual operation of the plant. This item is a deficiency.

(4) Review of PORC Yieetinp ~itinutes The following minutes were reviewed:

(a) Meeting No. 90-75 through 98-75 from June 17 to July 3, 1975.

The inspector noted that no as-built print revisions were found necessary as a result of SM 75-35, "Modification t:o Hain Steam Isolation Valves," com-pleted June 25, 1975'.. Further review revealed that a vendor drawing used for erection had been marked up to reflect the modification and included in t: he equipment history fil The inspector noted that Step 3.6.4 of QC 303, Revision 0, Modification Control Activi.ties," dated July 1, 1975 referred to "revisions to applicable plant drawings and flow prints" as per QC 603, Revision 5, "Control of Drawings," dated March 7, 1975. The licensee pointed out that QC 603 was only applicable to system flow and circuit drawings.

The inspector noted that QC 1701, Revision 4, "Control of Quality Assurance Records," dated January 24, 1975 requires retention of records and drawing revisions t:o 'safety-related systems and components. The licensee stated that this requirement was met by QC 1704, Revision 1, "System and Equipment Hist.ories," dated December 4, 1974.

The insp. "tor had no further questions on this item at t:his t ime.

(5) Jumper (Bypass Log): Documentation for June 1-July 15, 1975, relative to the use of jumpers and lifted leads was reviewed and no bypassing discrepancies with Technical Specification requirements were observed.

b. Tour of Accessible Areas The inspector observed operations in the Control Room and made a tour of the Auxiliary and Intermediate Buildings on July 15, 1975. The following observations. were made and these were discussed with the Shift Foreman:

(1) Honitoring Instrumentation: Hain Control Board readings were compared with local. indications for selected param-eters. No discrepancies were noted.

(2) Annunciator Alarms: The inspector observed various alarm .

indications that were received and acknowledged by the Control Room Operator on duty. These conditions vere discussed vith the Control Room Operator and the Control Room Operator was knowledgeable on the alarms and the actions required.

Shift Staffing: The inspector observed that the operating.

shift was staffed above the minimum requirements of Technical Specification Figure 6.1-2.

(4) Radiation Controls: Radiation control areas in the Auxiliary Building vere reviewed for proper posting, condition of step off pads, and disposal of Sii'P clothing.

Findings wore acceptable.

(5) Plant Housekecpin" Conditions: Storage of material and components vas observed with respect to prevention of safety and fire hazards, and no adverse conditions werc identified.

(6) Existence o Fluid Leaks: The inspector observed a leak on fcedwatc valve 4012. 'This leak was reported to the Shift Foreman. A trouble report for appropriate mainte-nance action had been initiated. The inspector had no further questions on thi" matter, at this time.

(7) Existence of Piping Vibrations: No noticeable piping vibrations 'were observed during this inspection.

ipe Hanger/Sei mic Restraints: Several pipe hangers and seismic restraints (snubbers) on safety-related systems were observed. Findings were acceptable.

(9) Valve Positions/Equipment Start Positions: The suction and discharge valves of the high pressure safety injec-tion pumps and their start switches were observed to be in accordance with Technical Specification requirements.

(10) Equipmcn'aution/Lockout Tag Information: The tag log was reviewed and thc inspec: )r that eq'uipmcnt under tag was consistent with the log << ~d entries on tagging forms (selective review) appeared'to be proper.

(ll) Plant Tour: The inspector was informed that the last tour made by the Shift Foreman occurred prier to assuming duty.

20-During th~ inspection of operating logs it was noted that administrative controls for operating logs, with the excep-tion of the Shift Foreman Log and Official Record, do not exist.

This is contrary to 10 CFR 50, Appendix B, Criterion XVII, which states, in part: "Sufficient records shall be main-tained to furnish'evidence of activities affecting quality.

The records shall includi at least the following: Operating

logs and the results of reviews."

This item is a deficiency.

During the inspecto s tour of the facility a schematic dra~m on masking tape was noted to be posted at the ion exchanger operating station in the au..ili'ary building. Additionally, a handwritten procedure for the operation of the boric acid batching syst: em was posted in the auxiliary building.

The use of these unapproved procedures for pl..nt operation is anoth;r example of the deficiency discussed in 9.a(3) above.

The licensee removed the above noted schematic and procedure during the inspection. The inspector stated that other areas of the plant not covered on his tour should be addressed in the cor) ctiv>> action for this deficiency.

The licensee acknowledged this information.

The inspector observed an out-of-date calibration sticker on the external security building portal monitor (PP"f-8). The sticker indicated that the portal monitor had been calibrated in February 1974 and wa's .due for calibration in February 1975.

Upon questioning, the licensee could produce no evidence to indicate that the monitor had been calibrated. The licensee indicated that no special calibration was required; that the unit served only as a go-no go instrument, and was not criti-cal to control of radiation exposure or contamination, since another portal monitor (PifC-4) at the control point was used for this purpose.

The technical manual (P't) for. both units was reviewed. The test and calibration procedure for Hodel PPH-8 outlined volt-age tests, rate meter calibrations, and post-calibration back-ground settings. The PHC-4 TH also provided for calibrat" on of the unit.

. 21-The inspector could not locate any calibration procedures for

'hese units and was thus un:ble to 'ascertain that they were calibrated within a period of time that would reasonably be expected to verify proper operation, including meter response time and alarm setpoint.

The inspector stated'that 'failure to calibrate the portal moni-

-tors appeared to deviate. from'enerally accepted =practice in the industry, as described in ICRU Report 20, "Radiation Pro-

-tection 'Instrumentation and its Application," issued, October 1, 1971.

The licen ee acknowledged this information.

10. Fuel Iutee~rie The inspector discussed with the licensee the measures taken to ensure that increasing coolant activity caused by leaking fuel would not .result in violation of Technical Specifications. Areas discussed were the licensee's previous experience with Making fuel, monitoring of trends with respect to Technical Specification Limits and the possibility of further failure causing, an early refueling.

e The inspector had no further questions in this area at thi.". time.

UI!ITED STATES f/ .

/ ~KUQ t NUCLEAR REGULATORY COIVIMISSION REGION III 799 ROOSEVELT ROAD GLEN ELLYN, ILLINOIS 60197 AUG 2 0 2975 northern States Power Cnc.pany Docket Vio. 50-282 ATL?4: Hr. Leo l"achter, Vice President Docket i'o. 50-306 Power Production and System Operation 414 lUcollct P~LL Einncapo1is, Mnnesota 55401 Gentlemen:

ThiII refers to thc inspection conducted by Hr:. Thorn!m of. tide office on July 21 23 19/5 of activ ti s at Prairie Island i"!!clear 6'encratinp Plant Units 1 and 2 authorised by  ?'RC Operatinp Licenses '.io. DPR-42 and Nn. D!1li-i10 and to the discussion of our finding,s with l!r. Haring and.

o&ers of your staff at the conclusion of the inspection.

A copy of our rcport of tl!is incpcction is enclosed and identifies the areas I.rarfxed durQ:I., the increction. within these areas, the inspection consisted of. a selective e7.ardnTItion oC proccdureo and representative records, interviews with plant personnel, and observations by the inspector, No items of nonconplianc with I'IRC requirements werc identified within thc scope of this insp"ction. I ~

In accordance!~th Section 2.790 of tl.e EiRC'G "Rules of ractice," Part ~

2, Title 10, Cede of Fci!eral Regulations. a copy of this letter and thc enclosed. inspection rel ort will be placed in the '.BI"s Public Document .

PocL;. If this rcport contains any in..omntion that you or your contractors believe to be pro".rioter:-, i" is necessary tt'.at iou Tiake n !zitten application to this f fice, ~<tl!9~~ t!~enty days. of 'your receip! of this c

letter to ~~.thhcld sucl! iI!formation from public discloI!ure. Any such application ra!st inc I!I!c n C>>LL stt.te!9c'nt of. thr reasons for x;hich it is

'lai;.I.d that tbc inI:nrI',".tion ."... proorietary, and sho!!Ld bc prepared so the proprict.".ry in.".or."~tion i<lcntifieil in thc application in contained in a I'cparatn pa"t of 'I!c doric"cnt. Unless wc receive an application to withhold ~ufo>-.;..ation or arc ot!!Grwise contacted within the specified time period, the written I!atcrial identified in this paragraph will be placed in the Public!)ocumcnt From.

<OLUT!Oy e~ o r m

+M~J'~re-!e<~

. AUG 2 0 1975 Rlorthern States Power'ompany

0 No reply to t.his letter is necessary; however,'hould you Iuve any quest5.ons concernin'g this inspection, we wQ.1 be glad to discuss them with you. '

Sincerely yours, Gaston. Piorelli;" Chief Reactor OperaH.ono cranch Enclooure'-

XH Xnspection Reports 7Ão. 050-282/75-10

.'and Ho. 050-306/75-07 cc w/encl:

P. P. Tierney Plant Hanager bcc w/encl:

PDR Local PDR NSXC TIC C

e UNITFD STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEHENT REGION III-Report of Operations Inspection 1

IE Inspection Report-No. 050-282/75-10 IE Inspection Report No. 050-306/75-07 Licensee: Northern States Power Company 41'4 Nicollet Nail Hinneapolis, Hinnesota '5401 Prairie Island Nuclear Generation 'icense No. DPR-42 Units 1 and 2 License No. DPR-60 Red. Hing, >1innesota Category: C Category: B Type of Licensee: (H) PHR 506 Kie Type of Inspection: Special, Unannounced Dates of Inspection: July 21 23, 1975

.n Ir Principal Inspector: ...~"~C. Brown (Date)

Accompanying Inspectors: None Other Accompanying Personnel: None

/~e l~++~),zZC4)

Reviewed By: H. Little Senior Inspector (Date)

Nuclear Support

.Reactor Operations Branch

SlBQfARY OF FINDTNGS Ins ection Summar Inspection on July 21-32, (75-10,"75-07) Review of compartment boundary seals for electrical penetrations per:SAR,commitments, construction

. specifications, field standards, IEB 75-04 and 75-04A response corrmit-ments.. Approximately one-half of the pqnetrations were inspected on a" least one side, in the control room, relay room, turbine building, auxiliary building, diesel generator rooms and bus rooms. Deviations

'per field standards noted; two penetrations had Flamemastic only on one side, cracks or incomplete coverage in Flamemastic coating on approximately 1/3 of penetrations in'spected. Duct seal used as sealant on temporary cables was the only flammable material noted in the bou'ndary seals. Major areas to be addressed by facility procedure revisions have been defined .or commitments stated in response to IEB 75-04A.

Enforcement Items

.None.

Licensee Action on Previousl Identified Enforcement Items I

A. Systems and Components None.

Facility Items (Plans and Procedures),

'I None.

C. Managerial Items None.

D. Noncompliance Identified 'and 'Corrected by Licensee None.

E. Deviations None.

F. Status of Previously Reported Unresolved Items Not inspected.

Hang ement Interview A management interview was condu ted with Hessrs. Goering, Superintendent; Plant Engineering; Hunstad, Staff Zr>gineer;, and Albrecht, Electrical Engineer, at the conclusion of the inspection'n July 23, 1975. The following matters were discussed.

A, The inspector inquired into the facility's plans for a periodic testing of the fire protection system equipment and alarm. The licensee stated that this area'ould be evaluated. by September 1; 1975.

.B. The iaspector stated that the diagram of normal and alternate shutdown, cool down, boration, and =water sources, did not reference.

any procedures. 'hc licensee replied that the appropriate procedure numbers would be added to the diagram.'Paragraph 5, Report Details)

C. The present status of commitments made in response to XEB'5-04A was discussed and the licensee considexed i;t no problem to meet the stated dates.

The inspector stated that he had noted during his inspection that no repairs had boon performed on any of the boundary seals noted in the !fay 13, 1975 inspection. The licensee stated this was due to a misinterpretation and the penetration seals would be inspected, evaluated, and repaired by September. 1, 1975. (Paragraph 3, Report Details)

E. The in pector stated that in his review of thc Task Foxce recommenda-tions, an evaluation of presently ava'ilable respiratory equipment as fire fighting equipment was missing. 'The licensee stated that this evaluation would be made. He also stated that the, Task Force had not been di banded. (Paragraph 5, Report Details)

REPORT DETAILS Persons Contacted F. P. Tierney, Plant Hanager H. A. Hunstad, Staff Engineer K. Albrecht, Electrical Engineex'.

'D. Brown, 'Engineer G. T. Goering, Superintendent Plant Engineering E. L. 'Uatzl, Radiation Protection Supervisor J., A. Gonyeau,.Training Supervisor 2., 'FSAR Commitments Prairie Island's FSAR- Section 8.3-7 states: Cable entrances into the control, room, x'clay room, an'd Class I areas are sealed to prevent the entrance of smoke and fire from outside sources.

3~ Boundar Seals A .total of approximately one-half of the boundary .seals in the "control room, relay room, diesel generator rooms, bus ry~ms and applicable areas of the tur'bine and auxiliary buildings were inspected. No open penetrations were noted in the 'isually inspections. Hinor discrepancies and flamemastic seal degradation were noted as compared to the field standar'ds (procedures developed from Construction Specifications). The present condition of some seals may. allow smoke to pass but appear to .be a fire barrier.

Due to a misinterpretation of IEB-75'-04 and 75-04A the licensee had not performed any repairs on the boundary seals at the 'time of the inspection. The licensee stated that an evaluation would be made and the seals repaired as necessaxy by September 1, 1975.

The licensee representative=stated. that any changes resulting from the evaluation to the field standards (procedures used during construction) would be reported as a supplemental response to IEB-74-04A.

The licensee had initiated a work request to remove all duct seal material used on temporary cable pulls and replace with fiber glass packing and RTV or Flamemastic.

4~ Status of Commitments to IEB-75-04A- 2/

The NSP task force set up to review areas stated in IEB-75-04A had completed the evaluation of the facility's equipment and procedures.

The evaluation results outline the areas to be addressed by the 1/ Including areas reviewed in IE Inspection Rpts No. 050-282/75-04 and No. 050-306/75-06.

2/ NSP Ltr (Wachtcr to Keppler) dtd 6/30/75.

site, The site had'ompleted some perliminary work on. the pro-

'edure revisions and personnel training; The licensee stated that no problem in meeting the letter commitments was apparent;at the time of the inspection.

.The current control of classifyjyg any, work request that includes cable pulling as safety related-.. will continue to be used until the ap'plicable ACD's are revised.

4 NSP Task Force.

The NSP Force eval'uations and recommendations were reviewed during the inspection. The Task Force's recommendations were essentially covered in the letter commitments made in response to IEB-75-04A.

The inspector indicated to the licensee "seve'ral areas that had not been included in the Task Force report: The use of currently available respiratory equipment for fire fighting has not been evaluated; The diagram for normal and alternate core cooling should contain the applicable procedure numbers; The training, program to include priorities in a realistic time frame for operator actions during losses of n>ajor components as in the

'Browns Ferry Cable Fire. The licensee acknowledged the comments and and agreed to review the items.

I ~

~ ~

3/ IE Inspection Rpts No. 050-282/75-06 and No.'50-306/75-04.

a ~

l Public }"n:-~c~ CG"i }"-v of Color"do DGCt'"t tao ~ 50-c.G7 AT'i"La.'lr. C. ai.:.'illcn License 'o Dll-ze S(.nior 'Jic(L President P.O. )'a(al'. 840 BC33v x, Colorado 80201 Goatlmc(L:

T.!is letter refers to tILO i3;s}ection coaductect by Ysssra. T. F. IT" tc"33 "n S(Ld J. E. Gagli-rdo O+ .tAC Regina TV Office ia Ar~.=:n",tpa e,(ao. '(}LLXi.",~

t<<c p".rio(L taz .1 17-2+, 197 } o:. scti~itics cathori"cC by:;;~ Opt!rat ta~ a aaiCCL>SC aO ~ '.i-3 1 ma t:O tb ir di"CU- Sin O' 3(! f~adit><S .}ita! ar.hC 0 Gf yoar.st~5 ..t tt!o c".;nclLU io~ of t."," ias}}cctiou. L!is lett".-r (LLO Ze..(.rS tO t.'n~ <'iocunoicn hcl.,!.-it!> yora S!!Pa 3",.~ J}erS OX yO'V 0<-sf< l>y a.'233ZS ~ .a"l.'Cr(l 'yQCQCLL> Q7L(t L,"O'Qterl;.. a Of tlat a gQ LCPipn 5 GQlc(: i 1 yoUZ office" on a:~y 15, 1975. Tb inspect.-.on ca April 17-"4 c(n1sistL 3 of. selective o;"".,uiantion of Pzoce(.llrcs) CP es .'Lta!t:"ve )lent ~~coz(Lsp iatc Vie'T3 %?ith Dorso ancl (a."8 ObSC~CtiOaaS by tho inSpcetora. P..".Sed Oa tlu'OSUlt: Of t:1C inSDCCtiO:3 ia. c:.aa}cars tla .t Q5 or(L3. G>> '>(}Ur Qctiv~9.t3.AQ '0~3. ('3ot co.l(L(lct81 1 " 1 co~pliaLLLCQ  !'tn 'a C Pic'-~>vl((tic'.1s cna(a thQ ZL(cL3Uizc'~c. ts of i

                                                                                                                                                'v(,tlz 03}crc3t9;Aa~a lg,ccllsc ~                ~

g', QsQ P.'ct!>>Q '3 t A ' '!il~ a

                                                                                             'L,      L 1
                                                                                                        @~iso(i~so((             ! .t.a 13
                                                                                                                                    ~

x!clip} zs GL QQQZ Bl ai, i IN ~ + f tall+ ~ ~

                                                   ~ )  ~ aa   ~   aa(   + ++  )    1 a>>'%'9     a   t i vtt se        h AE ~ It}il>>v>>>>MAL t   >>>>           6:+>>t' j %Aa4      4} ol      aal ',

i;

          ~    a         a
                                            ~      ~                                                        ~                                                  a yoUZ P" 'a.i!'~                  U  ':ll r 'fetfsaz( }

2 ~ l.g cn '.ay 5-} t:.75 (. 'L'if"."L

          \

thC a!Otic(L Of (io. 'L10.3 Q CEO ': %i ~ Ala".}sad'a! "A b VGLL %.'Q G Saafoi~e(L 8L a.ia.p ~a -.C (L>>SCLlSGLG.ao) t.!C 3i3ona"Ct'ac'3 i'!C3.".L"S Zal' CC6~93(!CZCa)iG qLLCS .i0 cont Gl 1 ln tQ3.aaao 31nia L1 pL} Of Qx'o

                                                       -  t:LQ       QQQ(aUQC 11 v j       Of    spar leaI to th itea..(L of T~LL);          CZB    Lt    a  .O:~r HGPcA'll"ale.Q'Acc A   CL3(a pro
                                                                                                                                                              ~
                                                                                                                                                                           '-aUZAl Ii7  letter to                   yoU (tate(a                    ..CQ="3Dcr         31, .I-.}jl>,            title(- "Cr>>te-ic fo-                         Det,.z~ing",

Rl f'OZCC!(3. nt .'.Ctip! ~ 5 GQ X.QZC iL!a",Gxta.'ae(l tf';:lt ta!f- Ca~a.o'a:.3C. t CCtinla aaV(L 1;;at}1Q to th(; CG $ Jis"ion in t.K'. cFGzcise 0}. its .~/UL,,tery r.";,spo... it} litics ~UC U:"aQ cdniai tz-ti; aetio!!s ia the }:cra o(}3; ittva notices cf viol'"tion civil rnoactozy p:.nsltics, al.d Grdce.rs pert""aiag t:o t'.-:c tee(>ific(Ltion, stlsaeasioa, or r<<vocation of a lair(.33as. $ .'o consider ti!o a(ttero 931 Ap-.cadiz A t:o ba sigaif9.C>>3!t it;.~ of 33oncoL(;pli"3!cc (a}LiciL(;:.Lrrant tiL.fly corrective actions. Yl'18$ Q Gctiol!9 shoal(l be (.lr(". 'tea~ ci tll 1'ic c .L'.sc Qf KQilUZQ to co ioly ivith .'.Cpl atcry rcquirmonta ed sh(}ale prov&le sdcqUstc u-aspect !3< coa'ro1 to QssUz( fUtQXG cc3(LpliQQce ~

Public Se"vice Co 1~any cf Colorado -?- )-g 8/5

                                                                                                      \

Ve plan to contislue folio-"s!i inspections to determine the cffcctiv'en ss of thc steps you have tal:cn ~~th rc"pcct to tl.i"., .."ttcr, and our fin.. ng.s GG v "ll s ) vur r 'o asonsc to 'this letters Mill be 't 'e basi ~ for ca decision concernJna thc nc d or add=tional enforce-.'cnt action. Sincerely, s-s anEL a+5 ,i Jolm. G. Davis, a'cputy Director for. Field Op=ration Office of Xllspcction and I'.nforce:cnt Qlclo"ure hs tatcd Distr ibu tion i i/encl ~ J Tints ~ i p ibss~A

                                                        ~

B. li. G ie', I;.:D'RIP L. X. Cobb, h!Ds XE (3) . H. Gilbert, l'J. J. P. 'surrey, Chief, HLD:REC .

                    " Central             Piles XE Reading Files XE Piles EDO Reading Piles DDPO          .eading     "iles PDR LPDR HSING
                                  'IC State of Colorado L. H. Under>;ood, AO.,                         IH:DDPO M. P.          Ellio,      IE:FCE T. I'I. Brocl:etta XE:FCE XE:HQ         Coordinator:              G. li. Smith gL                                                                 wng   as~. asi OFFICF.W                                                             I;%>i iii~4a g       SURNAME~p       a
                               .Q Jl                       (~                          Iga" ki ~~

S~ r I>/q~ oAT~~ 8-1S-75 S- ~ 75 0-P 0-75 S-24-'75 Q -75 pF aaas +.C 3a8(Rcv. 9 53) AilCM 0"40 . ~ ~ - s.'M.si covar~i:rNa rniaasi~o orrrc:.siss~as aa ~ -- ~ --- --- -

                                                                                                                                     ~        ~ ~ ~ ~ ~ .

AUG 27 1975 APPENDIX A NOTICE OF VIOLATION 'icense No. DPR-34 Based on the results of an NRC inspection conducted during the period April 17-24, 1975, it appears that certain of your activities were not

. conducted in full compliance with hRC regulations and the conditions of your NRC Operating License No. DPR 34 as indicated below:

INFRACTIONS

1. 10 CFR Part 50, Appendix B, Criterion V, INSTRUCTIONS, PROCEDURES, AND DRAHItNGS, states, in part, that: "Activities affecting quality shall be prescribed by documented instructions, procedures, or draw-ings, of a type appropriate to the circumstances and shall be accom-plished in accordance with these instructions, procedures, or drawing The Final Safety Analysis Report, Appendix C.3, under 'Crit'erion 3:

FIRE PROTEC ION (C"tcgory A>> staths that 1lle reacror facility shall be designed (1) to minimize the probability of events such as fires and explosions and (2) to minimize the potent'.al effects of such events on safety. Noncombustible and fire gesisrant .materials shall be used whenever practical through-out the facility, particularly in areas contajning critical

         ,portions of the facility such as containment, control room, and components of engineered safety features."

Plant Specification No. 1-N-2, "Electrical Installation Vork Part 2, tt specifies certain requirements relative to cable tray

      ~

and cable installation by reference to detail construction drawings, e.g., drawings No. E-41, E-42, E-43, and Sargent and Lundy standard, Standard STD-EA-176. V 4 Contrary to the collective requirements identified above: a.. Vertical cable tray fire stops between floors were not installed.

b. Fire stops in the Reactor Confinement Building and Diesel Generator Room vertical cable risers were not installed

C~ The fire stops for horizontal cable tray were not installed as specified, in that, none of the fire stops were found'o be completed units.

d. Ventilation openings in which the vent duct'asses into the battery room were "not sealed.

e. The fiber through the fill has not been installed in conduits auxiliary electrical equi'pment passing and switchgear room walls.

f. .The fire barrier installed in the bottom of the penetration into the auxiliary electrical equipment panel floor was not consistent with Specification 1-N-2 in that the n~aterial requirements were not maintained.

g. Separation of test cables in the cable spreading room has not been maintained.

h. Material of flammable potential was found to be located in the cable spreading room.

i. \

The battery room door into the 480 volt vital switchgear room was found to be open.

2. Technical Specifications,'dministrative Controls (AC), Nos. AC 7.3 and. AC 7.'6, collectively require "corrective action" and "reporting"

  .in tl:e event of abnormal occurrences.

Technical Specification No. 2.1 defines situations, circumstances, or incidents which are considered to be abnormal occurrences. Contrary to the above, following failure of the lA Diesel Generator on October 18, 1974, which constituted an abnormal occurrence, per TS No. 2.1(f), neither the required action nor reporting was accomplished.

    \

3. 10 CFR Part 50, Appendix B, Criterion V, INSTRUCTIONS, PROCEDURES, AND DRAHINGS, states, in part, that: "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings."

i The Fort St. Vrain Administrative Procedure No. AD."f-12 requires that administrative approval be given prior to performance of maintenance activities.. Section 6.1 of the Fort St. Vrain Quality Assurance Procedure No. 1200 states that: "A General Procedure (IP) shall be prepared to cover all types or routine maintenance and repair activities." Technical Specification No. 7.5.(b) requires that maintenance procedures shall be developed prior to implementation of safety related maintenance activities. Contrary to the above requ'rements:

'I Procedures had not been developed, and administrative approval had not been given, for 13 of 18 maintenance activities reviewed

'y the inspector during this inspection. These maintenance activities are identified in Table 1, attache. 10 CFR Part 50, Appendix B, Criterion XVI, CORRECTIVE ACTION, states, in part, that: "Measures shall be established to assure that condi ions adverse to quality, such as failures, mal-functions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected." Contrary to the above, plant personnel have not responded to, or taken corrective steps, relative to deficiencies -in implementation of plant administration and maintenance requiz'ements, called to th'eir attention following a quality, assurance audit performed on May 22-24, 1974. Te'chnical Specification No. 7.5(e) states that temporary changes may be made in standard operating and surveillance test procedures with the concurrence of the shift supervisor and one other person holding a senior operator license, and that such changes be documented, and subsequently approved by the Plant Operations Revie~ Committee. Final approval or disapproval will be by the Superintendent-Operations. 'ontrary to the above requirements:

a. Standard Operating Procedure (SOP) No. 42, was changed on April 16, 1975, without the concurrence of a shift super-visor and a licensed s nior reactor .operator, and without review by the Plant Operations Review Committee and final approval or disapproval by the Superintendent-Operations.

b. Surveillance Test Procedure No. 5.2.2.A-X, was changed on December 13, 1973, without. the concurrence of a shift supervisor and a licensed -senior reactor operator, and without review by the Plant Operations Review. Committee and final approval or disapproval by the Superintendent-Operations.

6; . Technical Specification No. 7.1.3.d.6 requires that the Nuclear Facility Review Committee: "Inv stigate all reported instances of alleged violations of Technical Specifications, AEC Regulations, License requirements, internal procedures or instructions, and abnormal occurrences'r performance of plant equipment anomalies."

    'Contrary to the above, .the violations .of requirements, listed below, identified by the licensee's QA organiaation, were not investigated by the Nuclear Facility Review Committee.

a. Violation .of security and access control requirements (Quality Assurance Deficiency Report No. QADR-113).

b. Violatinns of Internal cwork Procedure Ho. ), Material. Control (Quality Assurance Deficiency. Report No. QADR-116 and 117).

c. Violations of QA Procedure No.'100, and Administrative Procedure No. ADH-14, involving failure to develop calibration procedures for three of 16 Class I instruments..

7. ,Technica'1 Specification No. AC 7.1.3.d.'4 requires that the Nuclear Facility Safety Committee conduct audits no less than semi-annually of facility operations for compliance '~vith internal rules, pro-cedures,. regulations,. and,license requirements, including Technical Specifications.

Contrary to the above requirement, semi-annual audits were not performed between December 1973 and April 1975.

8. Technical Specification No. AC .7.1.3.d.12 requires, that the Nuclear Facility Safety Committee review proposed tests,and experiments, and. their results.

Contrary to the above, a test identified as Gulf Atomic RT 320, dated December 20, 1974, was conducted without prior review by the Nuclear Facility Safety Committee.

9. 10 CFR Part 50, Appendix 8, Criterion III, DESIGN CONTROL, states, in part, that: ""measures shall be established to assure that applicable regulatory requirements and the design basis, as de-fined in Part 50.2 and as specified in the license application

0

                                                               ~97 AUG gP for those structures, systems, and components to which, this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. The design control measures shall provide for verifying or checking the adequacy of design, such as the performance of design reviews by the use of alternate or simplified calculation methods, or, by the performance of a suitable testing program."

The-Final Safety Analysis Report, Appendix C, Table 1.4'-1 and Section 1.4.5, collectively require that the plant Reserve Shutdown System be designed and constructed in accordance with specified seismic criteria. Contrary to the above, the helium bottles used to operate the plant Reserve Shutdown System, were not subjected to seismic criteria design review. In addition, the helium bott'es were not re-st'rained to maintain seismic integrity in the event of seismic disturbances.

10. Technical Specification No. AC 7.5.d requires that the Plant Operations Review Committee shall review surveillance testing procedures.

Contrary to the above,rwouirement, although a number of the personnel assigned to the Plant Operations Review .Committee reviewed surveillance testing procedures on an individual basis during the period of December 21, 1973, to December 10, 1974, none of the procedures, which were issued for use, received review by the required Plant Operations Review Committee Quorum. Moreover, reviews were performed on an individual basis as opposed to a meeting quorum activity. DEFICIENCIES 10 CFR Part 50, Appendix B, Criterion XVII, QUALITY ASSURANCE RECORDS, states, in part, that: "Sufficient records shall be maintained to furnish evidence of activities affecting quality.

   ~ The record shall include at least the. following: Operating logs and the results of reviews, inspections, tests,. audits, monitoring-o'f .work performance, and materials analyses."

The Fort St. "iain Quality Assurance Procedure No. QAP-1200, Sectinn 7.0, requires that records exist to doc ..vent the fact that required inspections of nuclear Class 1 maintenance activities have been performed by inspection personnel.

PgG,27 1975 The Fort St. Vrain Administrative Policy No. OP-06 states .that:

   ",When  any system or portion of a system i's in operation, the log sheets provided shall be 'filled out in their entirety. For those data blocks provided for equipment not in operation, a "No" shall be recorded."

Contrary to the above requirements:

a. Records did not exist to demonstrate performance of required inspection of 13 of 18 safet'y related maintenance activities reviewed by the inspector.

b. Entries in the Plant Protection System logs 1 and 2 were not completed as required for the dates of April 10 and 12, 1975, and the Reactor Building Log No. 1 contained incomplete'ntries for the dates of April 1, 11 through 18, and 21, 1975.

2. 10 CFR Part 50, Appendix B, Criterion XI, TEST CONTROL; states, in part, that: "Test results shall be documented and evaluated to assure that test requirements have been s'atisfied."

The Fort SL. Vr.ain Administrative procedure No. imari-12 and Quality Assurance Plan No. QAP-1200, collectively require post maintenance testing, or test operations, prior to returning a safety related component or system to service. Quality Assurance Plan No. QAP-1200 also requires documentation of such tests. Contrary to the above requirements, records were not available relative to functional tests performed prior to returning a system/ component to normal service, following six of 18 safety related maintenance activities reviewed by the inspector.

3. Technical Specification No. AC 7.6(c) specifies the scope and applicability of safety related maintenance activities required to be reported to the Director, Division of Reactor Licensing, on a semi-annual basis and identifies six specific areas of

  .required information.

Contrary to the above requirements, the Fort St. Vrain semi-annual report, dated January 1975, did not contain information relative to safety welated maintenance performed during the last six months of 1974.

4. 10 CFR Part 50, Appendix B, Criterion XVII, QUALITY ASSURANCE RECORDS, states, in part, that: "Sufficient records shall be maintained to furnish evidence of activities affecting quality.

AUG 2V 1975 The record shall 'include at least the following: Operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses." The Fort St. Urain Quality Assurance Plan QAP-1200, and Quality Assurance instruction No. QAI-ll, establish requirements for the inspection of safety related maintenance activities. Contrary to the above requirements, 18 safety related maintenance activities, identified in Table 1, attached, were performed between June of 1974 and April of 1975, and in all 18 cases one, or more, of'he required quality assurance records'were missing.

5. 10 CFR Part 50, Appendix B, Criterion III, DESIGN CONTROL, requires in part that: "The design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews... Design changes including field changes, shall be subject to design control measures commensurate with those applied to the orignial design..."

10 CFR Part 50.59, CHANGES, TESTS AND. EXPERIMENTS, states in Section (a)(1), that: "The holder of a license ... may make changes in thc f"cility. as described..." Section (b) of part 50.59 states, in part, that:

  "The licensee shall maintain records of changes in the facility...

These 'records shall include a written evaluation which provides the basis for the determination that the change...does not involve an unreviewed safety question." Contrary to the collective requirements above, records were not available to establish that: (1) a change design review or (2) a safety analysis, had been performed relative to:

a. Modification of exhaust air damper pneumatic controls on January 21, 1975 (temporary Change Request No. TCR-1-48)

b. Modification of the PPS on March 15, "1975, (Temporary Change Request No. TCR-3-40)

c. The addition of fillonlines to the'constant leg of the Pelton Cavity level alarms Maich 23,.1974 (Temporary Change Request No. TCR-3-54).

This notice is sent to you pursuant to the provisions of Section 2.201 of .the, NRC's Rules of Practices, Part 2, Title 10, Code of Federal Regulations. Section 2.201 requires you to submit to'this office, within twenty (20) days of th'e date of this notice, a written statement of the explanation in reply, 'including,, 1) corrective actions which have been taken by you and the results achieved, 2) corrective actions which will be taken to avoid further items of noncomp3iance, and 3) the date when full compliance will be achieved. Mith regard 'to the above, Item No. 10 in the enclosed Appendix A, dealing with activities of the Plant Operating Review Committee, the inspector determined prior to the conclusion of the April 17-24 inspection that you had taken the necessary corrective action. Consequently, in your reply to this Notice, comment relative to Item No. 10 is. not required. In addition to the statement of explanation required by Section 2.201, in your reply you are requested to comment in terms of steps you have taken, or pla'n to.'ake, to resolve questions raised by the inspector during the April 17-24 inspection, which are discussed as follows: r 1, Follbwing instal'lation of the knock-oui pot for he Duffer/Helium I driers,,the level switch .alarm was not calibrated. This level alarm switch appears to -be Nuclear Class I, and should have been to assure reliability following installation. 'alibrated

2. Technical Specification No. 5.0 SURVEILLANCE REQUIREfENTS, designed to,assure the capability to control, the reactiv'ty and temperature of the reactor core, requires, in Specifi'cation No. SR-5.1.2.d, that operable reserve shutdown hoppers shall have an actuating bottle pressure equal to, or greater than, 1500 psig. Inconsistent with the intent of this requirement, you have approved and issued a surveillance procedure (No. SP 5.1.2.b.d) which permits actuating bottle low pressure alarm switches to be set as low as 1470 psig.

FOR THE NUCLEAR REGULATORY COi91ISSION J.gG. Davis, Deputy Director for Field Operations

                                     ~

Office of Inspection and Enforcement

AUG 27 >>i~ TABLE I MAINTENANCE ACTIVITY PCRV ru ture disc re laced with MAINTENANCE ACTl:VITIES REVIEWED dumm ADMIN APPROVAL No APPROVED PROCEDURE No (1) INSPECTED Yes TEST NO

                                                                                               'A FUNCTIONAL (2)

RECORDS No Repaired wiring error in accumulator circuit No No No Yes No Cleaned orifice valve and seals in CRD's Yes Yes Yes Yes No Replaced CRD Penetration Connector No No (1 No 2) Yes No Fuel Block Paint Removal No No No (2) NA No Replaced valve PCV 11258 in reserve ~SD s stem No No No'2 Yes 'No Rewired Electromatic Relief Valve 22168 Yes NA No (2 No (2) No Adjusted Trip Point of Power Rah e Channels /f3 and 88 No No No 2) Yes No Replaced Coil and Relay in 1A PHC Purification Com ressor No No No 2 No (2) No Replacement of Porcelain Insulators in Connectors Yes Yes Yes No (3) Re aired Al Bus in LC lA Yes Yes Yes Yes No

                                                                                                   ~UG g p tg75 ADMIN            APPROVED                         FUNCTIONAL     QA MAINTENANCE ACTIVITY                            APP.'iOVAL       PROCEDURE        INSPECTED     'EST             RECORDS
                                   'es D/G Trip Mechanism    Inspector and Re air                                        No                 No               No   2         No   2)       No Inspection of    480 V Breaker in   Emer enc  'Power Distribution                                   Yes              No  (2)        No   2)       No Replaced Contractor    for  D/G Hotstarts                                                            No               No  (2)        No  (2)       No  (3 Re   laced  HEPA Filters                                                              Yes            Yes Modified Emergency Feedwater Control Lo   ic                                           No                 No   1           No (2          Yes           No Replaced Logic. Board    for Loop Shutdown Lo    ic-                                No                 No  (1)          No   2         Yes           No (3 Replaced Logic Board     for Circulator Shutdown Lo    ic                                 No                 No   1)        ~

No 2) Yes No- (3-

                                                                                                                        ~ 0 I

(1) Procedure used, but.not approved by Plant Superintendent (now called Superintendent, Nuclear Production) as t per ADl&12. (2) Licensee representatives indicated that these activities were inspected and tested, but not documentation exists to verify same. (3) Only an equipment history card entry was made.

0 I ~

                                               . UNITED, STATES NUCLEAR REGULATOR Y COMMISSION Q*                                                   REGION I 601 PARK AVENUE KING OF PRUSSIA, PENNSYLVANIA 15456'UG 3 S  t975 Maine Yankee Atomic Power Company                             License No. DPR-36 Attention: lfr. G. Carl Andognini                             inspection. No. 75-14 Assistant to Vice President                   Docket No. 50-309 20  Turnpike    Road Mestborou h, Massachusetts            01581 Gentlemen:

This refers to the inspection conducted by Mr. J. Streeter of this office on August 21-22, 1975 at the >~wine Yankee Nuclear Power Plant, VU.scasset, Maine of activities authorized by NRC License No. DPR-36 and to the discussions of our. findings held by Mr. Streeter with fr. Frizzle of your staff at the conclusion of .the inspection, and to a 'subsequent telephone dis'"ussion between Mr. Streeter and Mr. Moody on August 25, 1975. Areas examined during this inspection are descr'bed in the Office of Xnspection and Fnforcement Inspection Report which is enclosed with this letter. Vithin these areas, the inspection consisted of selective exa-in-ations of procedures and representative records, interviews with personnel,

                        )

and observations by the inspector.

                                         )

Eased on .the re ults of this inspection,.it appears that one of your activities was not.conducted in full compliance with hRC reruirements, as set forth in the Notice of Violation, enclosed herewith as Appendix

       . A. This item of noncompliance has been categorized into. the levels as described in our correspondence to you dated December 3l, 1974. This no'tice  is   sent to you pursuant to the .provisions of Section 2.201 of the MRC's "Rules     of Practice", Part', Title 10, Code of Federal Regulations.

Section 2.201 reeuires you 'to submit to this office, within twenty (20) ( )

          , da  s of  your   receipt  of   this. notice,    a written statement   or. explanation in reply including: (1). corrective steps wnich have been taken by you and the results achieved; (2) corrective steps which will be taken to avoid .further items of noncompliance; and (3) the date when full com-pliance will be achieved.

Zn accordance with Section 2.790 of -the hRC's "Rules or Practice", Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures vill be placed in the NRC's Public Document Room. if this report contains any information.,that you (or vour contractor) believe to OI.UTlpy PPp6 )g6

I be proprierary, it is necessary that you make a written application within 20 days'to this office to withhold such information from public disclosure. Any such application must include a full statement of the reasons on the basis of which it is claimed that the information is proprietary and should be prepared so that proprietary information identified in the application is contained in a separate part of the document. If'e do not hear from you in this regard within the speci-fied period, the report will be placed in the Public Document Room. Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, Robert T. Carlson, Chief

                                                             ~
                                                                              ~

Facility Construction

                                                      ~  ~                ~

and Engineering Support Branch

Enclosures:

1. Appendix A, Notice of Violation

2. IE:I Inspection Report No. 75-14 cc: D. Hoody, Plant Superintendent E. W. Thurlow, President

.bcc: IE Chief, FS6EB .IE:EIQ (4 cys IE Files ltr, 5 cys report) Central Hail & Files Directorate of Licensing (4 cys Regulatory Standards (1 cy lt ltrr, 3 r,cys 13report) cys report) PDP. Local PDR NSIC TIC REG:I Reading Room Region Directors ELD (II, III, IV)(Report Only ) State of Haine

                                            ~     ~ .,  >+~,~ ~ ~, u p p ngt Y t'l
                                                                         ~          ~ '<  ~

0 License No. DPR-36 APPENDIX A NOTICE OF VIOLATIOH Based on the results of an NRC inspection conducted on August 21-22, 1975, it appears that certa-'n of your activities were not, conducted in full compliance with condit"ons of your NRC Faci5.ity License No. DPR-36 as indicated below. Contrary to 10 CFR 50.59, firestops.were'not installed as described in FSAR Section 8.3.7.7 and safety evaluations of these changes were not made and documented. This Infraction had the potential for causing or contributing to an occurrence related to health and safety.

Cl E:I Form 12 San 75) (Rev) ~ 3 Ue S ~ NUCLEAR REGULATORY CO.MISSION OFFICE OF INSPECTION AND Wi'FORC&fENT REGION I Inspection Report No: 50-30 -14 Docket No: licensee: Haine Yankee Atomic Power Comoanv License No: DPR-36 20 Turnpike Road Priority: Westborough, Hassachusetts 01581 Category: Safeguards Group:

~ation:      Wiscasset. Haine     04578 ype of Licensee:     PWR,  2440  hJt  (CE)
   !   f  Inspection:   Soecial, Announced tes of Inspec tion.. August 21-22, 1975 mtes of Previous Inspection-          ~uly 7-8, 1975
                                                                       ~ ~

keporting Inspector: J. F. Streeter, Reachbr,Inspector DATE Lccompanying Inspectors: None DATE DATE DATE o~ R. C. Haynes, None Senide Reacto" nspector, Engineering Support Section, Facility Construction and Engineering f/n~ gJ Support Branch

0 e e'UGARY OF FINDINGS Enforcement Action A. Items of Noncom liance

1. Violations None

2. Infractions

a. Viresto Discrepancies and Safet Evaluation Contrary to 10 CFR 50.59, firestops were not installed as described in FSAR Section 8.3.7.7 and safety evaluations

                    , of these changes were not made and documented.

(Detail 3.a)

3. Deficiencies None B. Deviations None Licensee 'Action on Previousl Identified Enforcement Items Not inspected

  ~Desi n Changes Not inspected Unusual Occurrences None  identified
  .Other Si   nificant 'Findin  s A. Current Findings

l. Acceptable Areas Inservice Inspection Data Review. (Detail 4) e

2. .Unresolved Items

a. ,Firestop Change Notification in Semiannual Report.

(Detail 3.b)

b. Evaluation of Slots in Outer Penetration"Room Area.

(Detail 3.e)

                                                      /

3. Licensee Identified Items of Noncompliance None B. Status of Previously Identified Unresolved Items 0'.

       . 1. The     following items have been resolved:
              -a. Sealing of Protected Cable Tray     Room  wall Penetrations 11, 20, and 21. (Detail 3.a)

Sealing of Protected Cable Tray Room wall Penetration 1. (Detail 3.a)

c. Replacement of Lower MCC Room floor Penetration 186.

                   - *(Detail 3.a) d0    Sealing of Conduit Sleeves Carrying Power and Control Cables Between the.Switchgear and Protected Cable Tray Rooms.    (Detail 3.a)

2. More-information is required to resolve the following items:

               'a. Plant Surv'ey of Control   Room  and Cable  Vault and Associated Sealing. (Detail 3. c)

b. Invokement of Facility Requirements for'irestops. (Detail

3. d)

Mana ement Interview At the conclusion of the inspection, the inspector held a meeting at the site with Mr. C. D. Frizzle, Assistant to Plant Superintendent, to discuss the inspection findings. The inspection findings were discussed with . Mr. D. E. Moody, Plant Superintendent, prior to the exit meeting. Mr.. Moody and Mr. Wood, Assistant Plant Superintendent, were unable to attend the meetin'g because og their involvement in labor negotiations. ~z

yQ following summarizes the items discussed: The A. Purpose of the Inspection. (Detail 2.b) Review of Previous Unresolved Items as identified in "Status of Previously Identified Unresolved .Items" section of this report. C.. Item of Noncompliance Firestop Discrepancies. (Detail 3.a) D. New Unresolved Items. (Details 3.b and 3.e) E. Inservice Inspection Data Review. (Detail 4) P. Status of Licensee's Response to IE Bulletins 75-04 and 75-0%A. (Detail 3.f)

DETAILS

1. Persons Contacted Mr. W. G.'Bizarro, Lead Electrician Mr. W. M. Fournier, Training Coordinator Mr. C. D. Frizzle, Assistant to Plant Superintendent Mr. D. E. Moody, Plant Superintendent'.

Mr. L. Painter, Maintenance Foreman Mr. R. F. Prouty, Maintenance Supervisor Mr. B. A. Tuthill, Engineering Assistant Mr. R. Wilkinson, Electrician Mr. E. C. Wood, Assistant Plant Superintendent

2. General a.. Plant Status The plant eras operating at approximately 99.5% power during the inspection.

~ = ~ b. Ins ection Pur ose The was inspector stated that the primary purpose of the inspection to review the licensee's progress in resolving the items identified in Region I Inspection Report 50-309/75-07 and to

             'review other licensee, activities related to IE Bulletins 75-04 and 75-04A. The inspector stated that the secondary purpose of the inspection was to examine in-service*inspection records to determine     if  all records were signed by properly qualified individuals.

3. '~presto s

References:

(1) Region I Inspection Report 50-309/75-07 (2) IE Bulletins 75-04 and 75-04A (3) Maine Yankee FSAR, Section 8.3.7.7 (4) Licensee letters to Region I in response to

                             -Reference (2) dated April 24, 1975 (WHY 75-43),
                           ; May 28, 1975 (WiK 75-50), June 24, 1975 (KlY 75-65),

and August 6, 1975 (hWZ-84)

a. Firestop Discre ancies and Safet Evaluation As stated in the FSAR (Section 8.3.7.7), "Fire stops are '-

provided around trays and in sleeves. which penetrate areas

J where carbod dioxide protection i's used." Section 8.3.7.6 states that "Carbon dioxide discharges into and totally floods the cable vault, the penetration rooms, and the protected and unprotected'able tray rooms in the event of a fire in those areas." The penetration room area outside the reactor containment is defined by the licensee to include both outer penetration rooms and the two (upper and lower) 1fotor Control Center Rooms directly below the penetration rooms. This area description is consistent with construction drawings FE-35A, FE-32C, FE-46G, FE-373, and FSAR Figures 5.1-1 and 5.1-2 which show communication between the subareas via floor slots (12" x 18") and a'ircular stairway. The penetration room area as defined by the licensee was designed to simultaneously flood all subareas with C02 rather than'individually sealing off and ,flooding the subareas (i~fCC rooms and outer penetration rooms). The licensee requested guidance from his architect-engineer during plant construction in 1972'n what materials werd to be used as firestops. The A-E informed the licensee that Flame-mastic 71A was acceptable as firestop material out duct seal was not. (Duct seal was acceptable for barriers other than firestops.),, The inspector stated that several items identified by him as Unresolved Items during Region I Inspection 50-309/75-07 con-stituted changes to the facility described in 'the FSAR in that certain firestops were found not to meet the above criteria. The licensee stated that a safety evaluation in accordance 10 CFR 50.59 was not made prior to these changes. The 'ith discrepant items & additional items identified by the licen-see and the inspector subsequent to Report 50-309/75-07 are as follows: (1) The firestops for wall Pen'etrations Protected Cable Tray Room ll, 20, and 21 in the were composed of a combination of Flamemastic 71A and duct seal. (These items were identified in Report 50-309/75-07, Detail 4(l). The inspector verified that the licensee had corrected the items by removing the duct seal and replacing it with Flamemastic 71A.)

e" 1 in the Protected (2) The firestops for wall Penetration Cable Tray Room had only asbestos rope without Flame-mastic 71A applied. (This item was identified in Report 50-309/75-07, Detail 4(2). The inspector verified that the licensee had corrected this item by applying Flame-mastic 71A.) (3) The firestop for floor Penetration 186 had been removed. (This item was identified in Report 50-309/75-07, Detail 4(3). The inspector verified that the licensee had cor-rected this item by applying Flamemastic 71A.) (4) Firestops were never installed in sleeves carrying control and'ower, cables between the switchgear rooms and cable tray rooms and between the upper and lower Reactor Contain-ment HCC rooms. (This item was identified in Peport 50-309/ 75-07, Detail 4(5). The licensee perforried a safety evalua-

        ,tion 'per 10 .CFR 50.59 that included the lack of these fire-stops and concluded that they need not be installed.)

(5) Two conduits between the Cable Vault and the lower lev'el of the Primary Auxiliary Building were not sealed and other Cable Vault sleeves were sealed with duct seal. (This item was identified in Report 50-309/75'-07, Detail 4(6) and has been resolved by sealing the conduits with duct seal. The use of duct seal for. Cable Vault sleeves was reviewed in a PORC meeting on August 25 and it was determined that no unreviewed safety guestion exists due to:such use.) (6) A,hole (~ 4" OD). rec'ently 'drilled in the wall was unsealed in the Upper ".fCC room. (This was identified during a fire-stop tour'n August 21. The hole was sealed with Flamemas-tic 71 prior,to the completion of the inspection.) (7) A cable. tray between the Unprotected Cable Tray Room and the turbine area was not properly firestopped. (This item was resolved prior to the end of the inspection by applying Flamemastic 71A around an asbestos board.)

.iQ The inspector asked if a safety evaluation had, been made after

        . the discrepancies were identified to determine     if  they consti-tuted an unreviewed safety question as'defined in 10 CFR 50.59 (a)(2). The licensee stated that a 10 CFR 50.59 evaluation had been made for item 2.a(4) and provided the inspector with a copy of a memo containing the evaluate.on~    Th'e licensee stated that the remaining discrepancies had been reviewed by
          .plarit supervisory personnel with the conclusion that no un-reviewed safety question existed; however, the review and conclusion reached were not documented in facility records.
       'he      inspector discussed the discrepancies with the Plant Superintendent, Assistant Plant Superintendent, and Assistant to the Plant Superinendent and determined from the discussion that an undocumented safety evaluation had been made. The
      ;    licensee  stated .that a special Plant Operations Review Com-mittee meeting would be convened on Monday, August 25,, to document the evaluation. 'The inspector confirmed in a
     ~
       ..telephone conversation on August 25 that the PORC had per-formed a formal review per 10 CFR 50.59 and concluded that no unreviewed safety questions existed due to the firestop discrepancies.)                     P The  inspector stated that fhilure to change or. construct the firestops   as described in FSAR Section 8.3.7.7 .without having first made a safety evaluation is contrary to the provisions of 10 CFR 50.59. The inspector stated that failure to docu-ment the safety evaluation made after the firestop discrep-ancies were identified was also contr'ary to 10 CFR 50.59.

These findings constitute an Item of Noncompliance and are "considered to be an, Infraction. b, 'icensee and Architect-En ineer Inter retation of Fireston Criteria As was mentioned under Detail 2.a above, the licensee requested guidance on firestops from his A-E in 1972 during plant'onstruc-tion. Correspondence from the A-E to .the 1icensee appears to interpret the FSAR firestop criteria as follows:

           -  Flamemastic 71A should be used to seal sleeves as follows:

Walls of the Switchgear Rooms. Walls o'f the Control Room. Walls and Floors of the Cable Tray Rooms. Walls and Floors of the Reactor Containment MCC Rooms. Walls and Floors of the Reactor Containment Outer Penetration Rooms.

- Floors or walls bearing on or against earth are not fire barriers. - Sleeves carrying power and control cables between the switch-gear rooms and cable tray rooms are not required to be sealed since the'. switchgear cubicles act as a fire barrier. The power bus ducting entering the switchgear rooms is sealed by fiberglass plate inside and Transite outside. This guidance has since been endorsed by the plant and is being incorporated into procedure i~fYi~f-5-108, "Cable Penetration Sealing."* For barriers that are .equired to be installed for reasons other than fire, duct seal is recommended by the li-censee and 'his A-E. The interpretations described above are consistent wit/ FSAR firestop requirements except that: -'he above interpretations do not address the sleeves in the ceiling of the cable tray rooms, whereas the FSAR requires firestops in these sleeves. (The licensee has reviewed this practice per 10 CFR 50.59 and concluded it to besealed acceptable. with The licensee now requires these sleeves to be duct seal.) - The above interpretations do not address the Cable Vault"

 .boundaries, whereas t.he FSAR requires sleeves in these boundaries to have firestops.         (The licensee reviewed this practice per    10 CFR 50.59 in a PORC meeting on August 25 and considered    it  to be acceptable. The licensee now requires one end or the other of sleeves penetrating the Cable Vault to be sealed with 'either Flamemastic 71A or duct seal.}

The licensee stated that plant safety evaluations performed in accordance with 10 CFR 50.59 dealing with firestops would be discussed in the next semiannual report. The'icensee also stated that the firestop criteria for Maine Yankee will be delineated in that reoort. This is. an Unresolved Item I receipt of that report. ' pending'egion

c. Plant Sealin Surve s The'icensee is in the process of conducting surveys of the Control Room and Cable Vault to assure that all Control Room floor penetrations are sealed with duct seal and that all Cable Vaults penetrations are sealed at one end with either duct seal or Flamemastic 71A. The surveys and associated sealing will be complete by August 29. From the inspector's revie'w of the present sealing status, the inspector concluded that the haoitability of the Control Room or the CO2 protection of the Cable Vault are not adversely affected. '

These items, originally identified in Reference (1), Details 4(4) and 4.(6), remain Unresolved Items pending completion of the licensee's surveys and sealing.

d. Invokement of Facilit Re uirements for Firesto s

   ~

The inspector reviewed. a draft procedure, MYN-5-108, "Cable Penetration Sealing," that addresses the issue of restoring firestops and boundary seals disturbed during maintenance operations. The procedure will be =approved by September 30. The licensee has issued guidance in the form of an administra-tive directive to accomplish the* repairs necessary to m et the FSAR firestop criteria. The inspector verified by questioning of the personnel performing the repair that they were knowledge-able in the proper repair techniques. This item, originally identified in Reference (1), Detail 5, remains an Unresolved Item pending final licensee approval of the procedure.

e. 'valuation of Slots in Outer Penetration Room Area During a firestop survey on August 21, the inspector observed

 ~
        , some cables passing loosely through slots (12" x 18") between the subareas (Lower ifCC Room, the Upper HCC Room, and the Reactor Containment Outer Penetration Rooms) of the penetration room area. The cables were in trays up to the floors and after

~ they passed through the floors but were not supported by sleeves or trays as they passed through the floors.

The inspector verified by examining construction drawings that the slots were designed in the flo'or.'he licensee could not readily produce documentation to show -t:he cable loading'of the slots. The 1'icensee stated that the slots and their cable loadings would'e reviewed by an engineer next week. Thi's Xs an Unresolved Item pending receipt and review by the

          'inspector of additional information from the licensee.

f. Status of Licensee's Res onse to IE Bulletins 75-04 and 75-04A The 'inspector reviewed the reports listed in Reference (4).

The licensee has been sending monthly summary reports in accord-ance. with IE Bulletin 75-04A detailing plant progress in respond-ing to the issues.set forth in IE Bulletins 75-04 and 75-04A.

       . The final licensee response to the bulletins is projected-for September       30.

4. Inservice Ins ection Data Review A Region I inspector recently determined at another facility that an individual who was certified as a Level II UT technician was performing ultrasonic, ezaminations as a Level II (as described by SNT-TC-1A) when his,qualifications only justif-'ed him being certi-fied as a Level I.. It was determined by Region I that the same individual had performed ultrasonic ezaminations at.Haine Yankee during the recent inservice inspection program.

The,.inspector reviewed all of the raw data sheets to determine the individual in question had signed any UT examinations as a if Leve'1 II technician without having another Level II as a cosigner. The inspector found that, with the ezception of one weld examina-tion data she'et concerning five welds on No. 1 main feedwater line, the weld records signed by, the ind vidual in question were cosigned by a valid Level II technician. The one weld data sheet in question was signed only by the individ-ual not qualified as a Level II. Consequently, these results would not be acceptable in satisfying the licensee's inservice inspection program requirements. The licensee stated that these tests would be repeated by appro-priately qualified personnel during the next in-service inspect'on.

              \ ~ ~

0 ~ ~

                    !Qg  ~~         >'-\

UNITEO STATES NUCLEAR REGULATORY COMMISSION REGION lll 799 ROOSEVELT ROAD CLKN ELLVNI ILLINOIS 601 37 AUG 2 S 1975 Coazaa~ma1tn Zdi"on Co~any 'lo~at Ye. 50-237 3yroQ Tcey Jro ATQ'Is P

          'ica Pre" ident a'ii 0 'oa'67 o                                                     Dockot ho 50-249
                              '069D      "

Chicago, Xl&noia CenU.even: Th~'s rafara to the ~<mpection conducted by I.'r.'-T; L. Harpster'f thIs offica cn Ji!'Iy Zl end 22, 1975, o" act"vit a "t the L'rcsdan Station author",".cd 'by 1TRC L" cc.ares >0 DP'9 QQd io r)P";25, 'c "d to the diocus iona of cur fi"""n,".a xrl"': 1wsora Buttcrfiald and Ju aci~ at the co }clL~ ion 0 the i.~ipccc - one A M'et" ~gp a tcnced by I';re PG2zQr and other rw~hera of tha Cozxn:zea1th M.con Pro"uction ""d Zngh "aring ataff, .i:dI ifessra.'i~rplster, Little end >~~Op of cilia offic", was hald on Payr~t 14 1975, =t tha Co;=~r..;~~6,th L'.icon Co~any ofricca to diacusa tha fi d'.~.ll"o o$ : thin 'nape"tion; has'Gu"-tera Tha i-.apection vm conducted in conuectgon tr2,th our raving ~@+~ evaluation of tha finQ~n~s'f the twy 12, 1975, Dro"den insp ct'on ';

I A copy of our rcport of this inspec&on i" <<nolo ed and identifies the are+ c"H.n d. Uitim thus areas, the insp"..ation conai tm of '"'l-'rvieaa t>~var, certa'~ cctivl.tire identified durham t."~<" inap=ction appar to be a <<icviaticn fro.".I Cc"wwicalth Zd~aon Standlr:ds. Tha itca 'n idmtifiad under Ot';-.EIr Hi~ific"~t i'in~~- n the Su~ ry of Findils~a ..eel=".cn of tI:a c clo"A ~n"paction report. P3;cue .

advise us in ~. ~-i, vLthin.20 d"ys of thc cvrrectiw "ct'on you h"=ve talccn or ply~ to t~'; a, sho~inI, the c"~tcd d"tc of co~piction, vith ronsard to this dcviaticn. Xn accords'ox Section 2.790 of tha h~I:S'8 "Dulce ox P"actice," P~wt 2, Titkc 10, CoLa cf Pcdaral Pcvul"tie~,' copy of th"s notice, the ercloaca iz"pection rcport, cna you" r'"pomL to tea x'.otic AU.1 ba placed in t c il"-ZIa Public Boca""""t P~o= Xf this rcport contair~ ~r infomation that ycu or your c"nt=ato"c ba&va to ba prcpriatag, it

0 AUG 2 9 i8IG Coumonwealth Edison Company Sa rccc"sary that you no'm a written application to ties office, Mthint tl:cxlty cir.>o ox your receipt oZ tM nokico, tn zrit.dlold Gull iaforwticn

 'from public dfacla"ur.                       d~y such applic,".tioa I~~t incluia a 2'ull otckcr."at,

'og the reasons for;M.Q it ~.o aim~-i~ci dint the inCorrztioIl io proprietary, anII shoed.Q be pr .rarer So the propriet ry ildoresticn S.dcnNXeQ iIl the GppUcaLion S.G contMer foal a sop&ate p"rt oE the I'.acl~Htt uI}le38 v rocuib~ fw l pj)3.i.caL'i"n to %TiZL+93.d glori.nU.on or 8rQ ot?Qxc.LQc'. contacted

'within the specii'eci hm pcwod, tha lsrS.ttaa nateriai Scdentisic:6 La thf.s yarnraph ci3.l be placed in the Public Bocmmt Room.

ShoDIl you inc.any qu~~tio".e concerning't%8 insp=ctfon, ee vol 5Q QXGQ to'disCUSO the.Q1 fd.th you+

                                                      ":     ~
                                                                   'Sincerely yoUzs,.                                   I
             ~ \         ~  ~ ~
                                                                                      'll
                                                                                              ~          \                ~
                                                                                                                            ~
                                                                                                                              ~
                           ~  ~ ~ ~
                                          ~              ~ ~                                        ~   ~
                                              ~
   ~ ~   ~                                                                                               v i '          ~
                                                       ~       ~

1

                                                                             ~
                  'I
                     ~ I            ~ ~ *   ~
                                                             'eotoa &ozelU.,'d.ef
            ~  I                                                    hlctor GpercU.O".s '&ranch
                                                                 ~   ~   I ~              ~ g         ~
                                                                                                                 ~

Enclc@lrcl ZS Xr~pection i.c~orts Ho. 050-237 j7~-2I and i~o. 1

                                                                                          \            i
 'SO-ZCSl7S-'.S                                                                                 1 cc t./cacl:

So S tophet)60n Station Superintendent ~ ~ bcc w(encll PDR Local PDR 'I

                                                                                                              ~

NSXC TXC Anthony Roisman, Esq., Attorney

U. S. NUCLEAR REGULATORY CO~0'fISSION OFFICE OF INSPECTION AND ENFORCE'LENT e REGION III Report of Operations Inspection EE Inspection Report No. 050-237/75-21 IE Inspection Report Ho. 050-249/75-18 Licensee: Commonwealth Edison Company P.O. Box 767 Chicago, Illinois'0690 Dresden Nuclear Power Station, Licenses No. DPR-19 Units 2 and 3 and No. Morris, Illinois DPR-25'ate'gory: C Type of Licensee: GE W%, 809 1Ãe Type of Inspection: Special, Announced . Dates of Inspection: July,21-22 and August 14, 1975 Principal Xnapecrcr: T. L. Harperer s /=,/-: (.~.I.("j-:~ . Accompanying Inspec tor: None (Date)'ther Accompanying Personnel: None

                                                                                                  ~

g Reviewed By: giZC~ia. V. S. 5 Littie, Senior Inspector Nuclear Support Operations Branch (Da e)

ghee'

SUMMARY

OF FIX)INGS Ins ection Summa Inspection on July 21, 22, and August 14 (75-21) (75-IS): Followup inspection of actions taken with respect to IE Bulletins 75-04 and 75-04A; meeting with members of Commonwealth Edison Production and Engineering staff to discuss the schedule for installation and repair of fire deviation was identified concerning licensee commitments to seal stops.'ne electrical penetrations. i Enforcement Items None. Licensee Action on Previousl Identified Enforcement Items Not inspected. Other Si nificant Items A. Systems and Components None. B. Facility Items (Plans and Procedures) None. C. Managerial Items None D. None'ompliance Identified and Corrected by Licensee None.'. Deviations Penetrations were not properly sealed, and fire stops were. nat installed, contrary to the requirements of the following Commonwealth Edison standards:

e

1. Cable pan fire stop and air seal through wall (Sargent and Lundy STD-EA-175)

I

2. Fire stop in cabl.e riser (Sargent and Lundy STD-EA-176)

3. Control board cable entrance seal (Sargent and Lundy STD-EA-179)

4. Method of sealing ducts for all types of cable (C-5192) k F. Status of PrevioMly Reported Unresolved Items I

None. Mana ement Interview A. The following subjects were discussed at the conclusion of the inspection on July 22, 1975 with Messrs. Butterfield and Jurecki. The inspector summarized the findings of the visual inspection of penetrations. The inspector stated that several instances of failure to meet CE requirements regarding firestops and seals for electrical penetratxons had.been identified, and that this would be considered a deviation. P The licensee s tated that the Station Nuclear Engineering Department was developing a repair schedule in response to the initial firestop inspection and the actions requested in,XE Bulletins 75-04 and 75-04A. (Paragraph 2, Report Details.

2. The inspector stated the combustible material had been removed

          .from the Auxiliary Electric Room since the previous inspection, however combustible material was       still found at various locations in 'the plant. In addition, rags found in two secondary containment penetrations during the previous inspection had not been removed.

The licensee stated that they were inspecting the plant and removing combustible materials from fire hazard areas. (Paragraph 3, Report Details) 30 The inspector stated that the item regarding cable separation. will continue to remain unresolved pending further investigation. (Inspection'Report 50-)0/75-9, 50-237/75-12, 50-249/75-14)

Messrs. Harpster, Little and Knop met with Mr. Palmer and other members of the Commonwealth Edison Production and Engineering sta f on August 14, 1975, to discuss Commonwealth Edison's schedule 'for installation and repair of fire stops at the Dresden, Quad-Cities and Zion stAtions. Representatives of the, licensee stated that: 1; Sargent,and Lundy is presently preparing drawings to be used in. the repair of deficient penqtrations and installation of firestops for penetrations not covered by existing specifications.

2. Advance purchase orders have been issued for ceramic fiber and flamenastic. The vendors expect no problems in meeting the delivery dates.

30 The work package will be issued to the stations by September 2, 1975. . Materials are expected to be on site September 8, 1975. Estimated time for completion of the .work is three months.

4. The work'package will require a 100% audit of penetrations prior to completion of repairs to make certain that all foreign materials are removed. Repair priority will be given to the Control Room, Cable Spreading Room, etc., in accordance with the safety significance of these areas.

HRC representatives asked to be notified of any changes in this schedule and urged that this work be c'ompleted as expeditiously as possible.

0 REPORT DETAILS

l. Personnel Contacted'.

Stephenson, Plant Superintendent D. Butterfield, Administrative Assistant J. Jurecki, Staff Assistant to Maintenance Engineer J. Brunnex, General Engineer

2. Visual Examination The inspector toured the facility with repxesentatives of the licensee to determine the extent of conformance with SAR commitments and Commonwealth Edison standards relating to fixestops and seals for. electrical penetrations.

This selective audit identified four groups of nonconforming penetrations. These nonconforming penetxations are considered to be a deviation from the following Commonwealth Edison standards:

a. Cable pan fire stop and air seal through wall (Sargent and Lundy STO-EA-.l?5)

Fire stop in cable riser (Sargent and Lundy STD-EA-176) Co Control Board Cable Entrance Seal (Sargent and Lundy STD-EA-179)

d. Method of sealing ducts for all types of cable (C-5192)

Noncon'forming penetrations were identified in the following locations:

a. Control room b..Auxiliary electric room

c. Cable tunnel

d. Unit 2 b ttery room

e. Computer room

f. Switchgear room (Bussess 2)-24)

g. Turbine buildi~g ventilation switchgear room east (Below Unit 3 battery)

h. Turbine building

Combustible >faterials Rags were found by the inspector in two ducts in the cable tunnel and two penetrations in the secondary containment wall. The rags in the secondary containment penetrations had been identified in a ofay 12, 1975 inspection (XE Inspection Reports 50-10/75-9, 50-237/75-14, 50-249/75-12), and nad not been removed.

b. Wood or masonite boards covered nine horizontal cable tray

  ~

penetrations in the turbine building. The boards had been identified in the Hay 12, 1975 inspection, and not not been removed.

c. The licensee stated that they were inspecting the plant and removing combustible materials from, fire hazard areas.

0

                                       'i A~          gW   >cj~g -P~=8g-

a. The cause of each abnorrrzl occurrence was identified and the details were clearly reporte'd to facility management.

  .b.      The  corrective actions described in the reports to prevent recurrence of the events were implemented by the licensee..

Ci The abnormal occurrences had been reviewed by the Plant Review Committee. The surveillance requiremen> (Technical Specification Table 4.1-3) for quarterly sampling. of th'e k'aste Gas Decay Tank

        , D was not met for the first quarter o          1975 (item of non-compliance) as reported by the licensee in Abnormal Occur-
         .rence Report /to. 75-11. Surveillance procedure, SP 202.07 had been implemented to preclude recurrenca.

e. System and component failures have been reported to the plant staff for review and properly identified as abnormal occur-rences when applicable.

4. IE Bull etin Foll owuo a4 75-04A "'Cable Tra Fire - Browns Ferry" The in,ormation contained ir the licensee's final status repor t dated J~1 y 21, 1975 was veri fi ed. The fo1 1 o vina new procedure and'evisions to existing orocedvres have b en reviewed, approved and implemented by the licensee as ad-ministrative control modi"locations addressino fire prevention and the effects of fire on plant shutdown cooling systems.

(1) AP-29-Rev 0, "Use and Control of Combustible Materials and Igni,tion Sources." (2) AP-. 3-Rev 3, "cwork Request." (3) M-113-Rev 2, "General 'rlelding Procedure."

        '{4)    D-14-Rev 2, "Loss     of  Steam Generator   Feed."
      ~

(5) D-16-Rev 2, "Loss of Decay Heat Removal System." (6) B-4-Rev 2, "Plant Shutdown and Cooldown."

UNITED STATES NUCLEAR REGULATORY COMMtSSION REGION I PARK AVENUE

                                                       '51 KINC OF PRUSSIA~ PENNSYLVANIA 1 940 C SFP 8 Attention: Mr. Leon D. White, Jr.

Vice'President

                                       'icense Rochester Gas and Electric Corporation Electric and Steam Production No. DPR-18 Inspection No. 75-10 Docket Ho. 50;244 89  East Avenue Rochester, New York '14649

Reference:

Your letter dated. August 29, 1975 In response to our letter dated August 7, 1975 Gentlemen: Thank you for informing us of the corrective and'reventive actions you documented in response to our correspondence. These actions will be examined during a subseauent inspection of your licensed program. Your cooperation with us is appreciated. Sincerely', ames P. O'Reilly ~ D rector cc:

   'bcc:

C.

          ,.T.

TE Chief, Platt, Plant Superintendent A. E. Upton, Esauire R. Schuler. FSGEB 0C Roc gnat c~ .... ,.;~,;):;, ~ ~

                                                                                          .'1P IEIHq (4)

ZE Piles Central ~fail 6 Files Directorate of Licensing (4) RS PDR Local PDR BASIC TZC REG I Reading Room ELD State of New York iUTlO I

  ~"J    g~

ty \}}