ML20113A180

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Special Rept:On 960521,declared Detectors A01 for Zone 69 & A04 for Zone 60 Inoperable Because Detectors Effectively Isolated from Area in Intended Protection.Detectors Relocated,Tested & Declared Operable on 960524
ML20113A180
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 06/17/1996
From: Mccollum W
DUKE POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9606240155
Download: ML20113A180 (10)


Text

.

. Dukeiburr Company H?tussR AkCOLUM.)R Cataa ha Nuclear Generation Department Vice hnident

, 4M(IConcordhbad (M3)S314.M10fnce

)brk, SC29745 (M3JS1140iFla DUKEPOWER

@ June 17,1996 ,

I U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555

Subject:

Catawba Nuclear Station Docket No. 50-413 and 50-414 Special Report l

Gentlemen:

Attached is a Special Report conceming a SELECTIVE LICENSEE COMMITMENT FOR OPERABILITY OF FIRE DETECTION INSTRUMENTATION NOT MAINTAINED.

This event is considered to be of no significance with respect to the health and safety of the public.  ;

l Very truly yours, S.

l W. R. McCollum, Jr.  !

Attachment cc: Mr. S.D. Ebneter INPO Records Center Administrator, Region 11 700 Galleria Place U.S. Nuclear Regulatory Commission Atlanta, GA 30339-5957 101 Marietta St., NW, Suite 2900  ;

Atlanta, GA 30323 Mr. P. S. Tam Marsh & McLennan Nuclear U.S. Nuclear Regulatory Commission 1166 Avenue of the Americas Office of Nuclear Reactor Regulation New York, NY 10036-2774 Washington, D.C. 20555 Mr. R. J. Freudenberger NRC Resident inspector gg Catawba Nuclear Station 9606240155 960617 0 PDR g$'

8 ADOCK 05000413 PDR na a w a m

DUKE POWER COMPANY CATAWBA NUCLEAR STATION DOCKET NUMBERS 50-413 and 50-414 SPECIAL REPORT SELECTIVE LICENSE COMMITMENT FOR OPERABILITY OF FIRE DETECTION INSTRUMENTATION NOT MAINTAINED ABSTRACT This Special Report is being submitted to document non compliance with operability requirements of Fire Detection Instrumentation per Selected Licensee Commitment (SLC) 16.9-6. This SLC is part of the Catawba Fire Protection Program and therefore subject to the provisions of the Catawba Facility Operating License Conditions C.(8) for NPF-35 (Unit 1) and C. (6) for NPF-52 (Unit 2). On May 21, 1996, at approximately 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, with Units 1 and 2 in Mode 1, Power Operations, at 100% power, Engineering recommended that detectors A01 for Zone 69 and A04 for Zone 60, located in rooms 480A and 490A respectively, be declared inoperable because the detectors were effectively isolated from the area of intended protection as specified in SLC 16.9-6 and SER 9.5.1.7. These detectors were declared inoperable by the Operations Shift Manager at 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br />. An hourly fire watch was initiated, as a conservative measure, and work requests initiated to relocate the detectors. On May 24, 1996, the detectors were relocated, tested, declared operable, and the hourly fire watch was suspended.

Review of plant documentation, which included drawings, procedures, Work Management System history files, and interviews with numerous plant and General Office personnel , indicate that the cause for the inoperability of Zones 69 and 60 is due to lack of programmatic controls between the Fire Detection Program and the Fire Stop Installation Program. Expertise within Civil and Electrical Engineering was utilized during the design and construction phase as programmatic control for the installation of fire detectors and fire stops. Due to inadequate interface requirements between these two programs, it is most probable that the detectors were installed prior to fire stop installation which resulted in the separation of the cable shafts from the detectors. Since turnover from the design and construction phase

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DUKE POWER COMPANY / CATAWBA NUCLEAR STATION PIP 2-C96-1167/SPECIAL REPORT PAGE 2 )

to operational phase, the Nuclear Station Modification process is utilized to review and implement changes to systems, structures, and components. The NSM process is designed to review any changes and to verify that those changes do not violate station commitments. Therefore, no programmatic corrective actions are necessary. Subsequent corrective actions taken and completed included reviewing all Fire Detection System (EFA) Test Procedures (IPs) and EFA System drawings required for safety i related equipment to ensure simi3 ar situations did not exist with I other required detectors. IP/0/A/3350/10 and IP/0/A3350/11, EFA System Detector Test Procedures, have been revised to reflect the location and access to the detectors in question.

BACKGROUND The Fire Detection System (EFA) monitors unattended areas of the plant for smoke or fire and alerts plant personnel of the existence and location of a fire. Safety Evaluation Report (SER), Section 9.5.1.7, Fire Detection, requires that "with the exception of rooms listed, fire detection systems will be installed in all areas of the station containing safety-related i

system components and cables."

Selected Licensee Commitment (SLC) 16.9-6 is a part of the Catawba Fire Protection Program and therefore subject to the provision of the Catawba Facility Operating License Conditions C.(8) for NPF-35 (Unit 1) and C. (6) for NPF-52 (Unit 2).

SLC 16.9-6, Fire Detection Instrumentation, states that "as a minimum, the fire detection instrumentation for each fire detection zone shown in Table 16.9-3 shall be OPERABLE." The remedial action to be taken "with any, but not more than one-half the total in any fire zone", becomes inoperable states to

" restore the inoperable instruments (s) to OPERABLE status within 14 days or within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> establish a fire watch patrol to inspect the zone (s) with the inoperable instruments (s) at least once per hour..." This requirement is applicable "whenever equipment protected by the fire detection instrument is required to be OPERABLE."

DUKE POWER COMPANY / CATAWBA NUCLEAR STATION PIP 2-C96-1167/SPECIAL REPORT 4 PAGE 3 SLC 16.9-6, Testing Requirements, Section (a), states that each flame detection instrument required in Table 16.9-3, "shall be demonstrated operable at least once per 6 months by the performance of a VISUAL INSPECTION and at least once per year by performance of a TRIP ACTUATING DEVICE OPERATIONAL TEST",

(TADOT).

IP/0/A/3350/10 , EFA System Detector Test Procedure (s) , is utilized to perform the yearly TADOT per SLC 16.9-6 which includes Zone 60, detector A04. IP/0/A/3350/11, EFA System Detector Test Procedure, is utilized to perform the yearly TADOT per SLC 16.9-6 which includes Zone 69, detector A01.

Zone 60 consisted of 18 detectors, one being A04, which is for fire detection of the Unit 1 Cable Shaft. The Unit 1 Cable Shaft is a vertical shaft running from elevation 543 to 593 which houses B Train cable. Seventeen of the eighteen required detectors for this zone can be accessed frcm elevation 574 of the Auxiliary Building. Detector A04 had to be accessed from elevation 594 of the Auxiliary Building.

Zone 69 consisted of 18 detectors, one being A01, which is for fire detection of the Unit 2 Cable Shaft. The Unit 2 Cable Shaft is a vertical shaft running from elevation 543 to 593 which houses B Train cables. Seventeen of the eighteen required detectors for this zone can be accessed from elevation 574 of the Auxiliary Building. Detector A01 had to be accessed frem elevation 594 of the Auxiliary Building.

EVENT DESCRIPTION 1981 Original installation of detectors, A04 for Zone 60 and A01 for Zone 69, on the ceiling (approximately elevation 609) of the Controlled Area Chiller Water (YC) Room directly above each cable shaft.

1984 Fire stop material was added to the opening at the top of the cable shaft at elevation 593 which closed off the shaft from the 594 elevation.

DUKE POWER COMPANY / CATAWBA NUCLEAR STATION PIP 2-C96-1167/SPECIAL REPORT PAGE 4 May 16, 1996 Trip Actuating Device Operational Test (TADOT) was (Thursday) being performed per yearly requirements of SLC 16.9-6 and IP/0/A/3350/10.

1400 Ionization Detector A01 in fire zone 69 could not be located .

Engineering recommended that an hourly fire watch be performed. J l

1647 Fire Panel Console Operator (FPCO) initiated an '

hourly fire watch, as a conservative measure.

I Engineering initiated Work Request 96020969 to l install a detector and PIP 2-C96-1167 was I generated.

1750 During work being performed under Work Request  ;

96020969, Maintenance located detector A01 in Zone 69 on 594 elevation in the YC Chiller Room.

Per guidance from Engineering, detector A01 for Zone 69 was successfully tested using Work Request 96020969.

Engineering contacted the FPCO and stated that the !

detector had been located and successfully tested.

(It was not recognized at this point that the detector was located in an area that would not provide detection capability for the cable shaft.)

1815 FPCO terminated fire watch.

May 17, 1996 Maintenance technician working on yearly TADOTs (Friday) sent an electronic note to Engineering stating concern that detector A01 in Zone 69 may not be located as needed to provide fire detection capability for the cable shaft.

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DUKE POWER COMPANY / CATAWBA NUCLEAR STATION PIP 2-C96-1167/SPECIAL REPORT PAGE 5 May 21, 1996 Upon receipt of the note, Engineering (Monday) determined that the detector should be located below the fire stop in the ceiling of elevation 574 (at elevation 593). Unit 1 corresponding detector (A04 in Zone 60) was checked and also found to be in the wrong location.

1100 Engineering initiated an Operability Notification Form recommending that' Zone 69 and Zone 60 be declared inoperable.

1400 Operations declared Zone 69 and Zone 60 inoperable.

1515 FPCO initiated an hourly fire watch, as a conservative measure.

Engineering initiated Work Requests to have the detector A01 for Zone 69 and detector A04 for Zone 60 relocated.

May 24, 1996 Fire detector A01 in Zone 69 and A04 in Zone 60 (Friday) were relocated and successfully tested.

1300 Zones 69 and 60 were declared operable.

1400 Hourly fire watch for Zones 69 and 60 was terminated.

DUKE POWER COMPANY / CATAWBA NUCLEAR STATION PIP 2-C96-1167/SPECIAL REPORT PAGE 6 CONCLUSION This event is attributed to less than adequate interface requirements between the Fire Detection Installation Program and the Fire Stop Installation Program utilized during the design and construction phase of Catawba. Expertise within Civil and Electrical Engineering was utilized during the construction phase as programmatic control for the installation of fire detectors l and fire stops. Due to inadequate interface requirements between I these two programs, it is most probable that the detectors were  ;

installed prior to fire stop installation which resulted in the I separation of the cable shafts from the detectors.

Since turnover from the construction phase to operational phase, the Nuclear Station Modification process is utilized to review and implement. changes to systems, structures, and components.

The NSM process is designed to review any changes and to verify that those changes do not violate station commitments.  ;

Therefore, no programmatic corrective actions are necessary. The NSM process currently in place would prevent this event from recurring.

Subsequent corrective actions taken and completed included reviewing all Fire Detection System (EFA) Test Procedures (IPs) and EFA System drawings required for safety related equipment to ensure similar situations did not exist with other required detectors. IP/0/A/3350/10 and IP/0/A3350/11, EFA System Detector Test Procedures, have been revised to reflect the location and access to the detectors in question.

A review of the operating experience database, including Problem Investigation Program reports, for the twenty four months preceding this event did not identify any events in which SLC 16.9-6 had been violated. Additionally, this review did not identify any similar events with the same cause. This event is not considered to be recurring.

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i DUKE POWER COMPANY / CATAWBA NUCLEAR STATION PIP 2-C96-1167/SPECIAL REPORT  !

PAGE 7 l

I CORRECTIVE ACTIONS i

SUBSEQUENT ACTIONS

1) TSAIL entry was initiated declaring Zones 69 and 60 inoperable.
2) Jul hourly fire watch was established as a conservative

! measure. The Remedial action required by.SLC 16.9-6 is to restore the inoperable instrument (s) to OPERABLE status within 14 days or within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> establish a fire watch patrol at least once per hour.

3) Detector (s) A01 in Zone 69 and A04 in Zone 60 were relocated and successfully tested to comply with requirements of SLC 16.9-6.
4) .IP/0/A/3350/10 and IP/0/A/3350/11 were revised to

! reflect new location of A01 in Zone 69 and A04 in Zone 60.

l 5) A review of all EFA System Detector Test Procedures (IPs) required for safety related equipment was performed to ensure similar situations did not exist l

with other required detectors.

6) A review of all EFA System drawings required for safety related equipment was performed to ensure similar situations did not exist with other required detectors. j PLANNED None l

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l DUKE POWER COMPANY / CATAWBA NUCLEAR STATION PIP 2-C96-1167/SPECIAL REPORT l PAGE 8 ,

l SAFETY ANALYSIS ,

1 Detectors are required at the top of the unit 1 and 2 B train i cable shafts (rooms 480A and 490A) in accordance with SER and SLC commitments, and design drawings (EFA system). These detectors were found to be located incorrectly and this was documented in station Problem Investigation Process (PIP) report 2-C96-1167.

For the reasons summarized below, the overall impact of the detectors being missing from the cable shafts would have been minimal.

  • These cable shafts would not normally house any combustible materials. Therefore, any fire in these shafts would have been due to transient materials. These shafts are enclosed by three hour rated fire barriers except for the 574+0 elevation. The 574+0 elevation is open to an area that includes 17 other detectors. The shafts have no intermediate floor levels from elevation 543+0 (bottom of shafts) to elevation 593+0 (top of shafts). Therefore, the most likely location of the initiation of a fire would be at elevation 543+0. There are no normal or typical station activities that would result in transient combustible materials at the bottom of the shaft (elevation-543,0). Additionally, both cable shafts have detectors at approximately elevation 554+0. These devices at 554+0 would provide adequate detection for a fire initiated at elevation 543+0. It should be noted that a small amount of scaffolding boards and wooden form work were discovered near the top of the unit 2 cable shaft. The scaffold and form material was subsequently removed. This wood was required to be fire retardant per site directives on " Control of Combustible Materials". Additionally, the scaffold and form material were located in close proximity to the sprinkler heads. Had these materials become a source of ignition the sprinkler system would have actuated within a short time frame (see discussion below regarding the sprinkler system).

, , 4 g DUKE POWER COMPANY / CATAWBA NUCLEAR STATION PIP 2-C96-1167/9PECIAL REPORT PAGE 9 The shafts contain only cables and their associated cable trays.

The cables are all an armored interlocked cable that are also shielded and grounded. Therefore, the cables themselves would not create a source of fire and they do not have exposed combustible insulation. The cables will self extinguish when a fire source is removed. Additionally, only one train of safe shutdown cables (train "B") is housed in each shaft. Therefore, a fire in one shaft could only affect one train of safe shutdown equipment. The Safe Shutdown Facility (SSF) would not be affected by a fire in either shaft.

  • Both shafts are equipped with an automatic sprinkler system (RF system) which would actuate at 165 degrees Fahrenheit. The damage threshold for the armored interlocked cables is 700 degrees Fahrenheit. Thus the sprinkler system would actuate prior to cable damage threshold temperatures being reached.

Also, the sprinkler systems would transmit a flow alarm to the Control Room. The sprinkler alarms would have served as a delayed detection system.

1 In conclusion, the net effect of having the detectors located improperly would be delayed detection. However, the transmission of the flow alarm and sprinkler system actuation are expected to occur before any cable damage.

This event was considered to be of no significance with respect to the health and safety of the public. No damage to safety related systems or components resulted from this event.

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