IR 05000440/1985090

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Insp Rept 50-440/85-90 on 851219-20.No Violations Noted. Major Areas Inspected:Outstanding Fire Protection Issues, Including Continuing Assessment of Fire Protection Program
ML20137A226
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 01/09/1986
From: Guldemond W, Holmes J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137A206 List:
References
50-440-85-90, NUDOCS 8601140245
Download: ML20137A226 (8)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-440/85090(DRS)

Docket No. 50-440 License No. CPPR-148 Licensee:

Cleveland Electric Illuminating Company Post Office Box 5000 Cleveland, Ohio 44101 Facility Name:

Perry Nuclear Power Plant, Unit 1 Inspection At:

Perry Site, Perry, Ohio Inspection Conducted:

D cember 19-20, 1985

/-fM Inspector:

Je f m

Date Approved By:

W.

d C

/-944 Operational Programs Section Date Inspection Summary Inspection on December 19-20, 1985 (Report No. 50-440/85090(DRS))

Areas Inspected:

Routine, announced inspection of outstanding fire protection issues including a continuing assessment af the licensee's fire protection program.

The inspection involved a total of 16 inspector-hours onsite by one NRC inspector including five inspector-hours onsite during off-shifts.

Results:

In the areas inspected, no violations were identified.

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9601140245 860109 PDR ADOCK 05000440 G

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DETAILS 1.

Persons Contacted Cleveland Electric Illuminating Company

  • C. Bangerter, Associate Engineer Technician
  • R. Evans, Fire Protection Coordinator
  • M. Hayner, Licensing Engineer
  • T. Heatherly, Compliance Engineer
  • k. Kanda, General Supervising Engineer
  • P. Kiel, Fire Protection Specialist
  • M. Lyster, "anager
  • M. Makar, Fn e Protection Engineer
  • J. Pelcic, aad Staticn Quality Engineer
  • N. Peters, Responsible Engineer
  • P. Russ, Compliance Engineer
  • R. Slakiewig, Construction Engineer
  • C. Shuster, Manager
  • F. Stead, Manager
  • R. Stratman, General Supervising Engineer
  • J. Waldron, Manager
  • B. Waldath, General Supervising Engineer NRC
  • Kevin Counaughton, Resident Inspector
  • Jack Grobe, Resident Inspector
  • Denotes persons attending the exit rieeting of December 20, 1985.

2.

Action on Previous Inspection Findings (Closed) 10 CFR 50.55(e) Item (440/85002-EE): This item documented fire dampers failing to close under normal duct pressure.

Licensee internal memorandum dated ~ August 20, 1985 from H. Reppert/

J. Cichello to H. Dieckmann stated in part that "... fire dampers shall be tested under air flow conditions to ensure acceptable closure." An attachment to that memorandum identifies fire dampers (130) which shall be tested under air flow conditions.

The " Unit 1 and Common Fire Dampers Evaluation" (Revision 2) and " Unit 1 and Common Fire Damper Test Size Sort (In Order of Decending Velocity)"

indicate the damper identification numbers, actual damper sizes, number of damper sections, smallest section of given damper, design velocity (air velocity in feet per minute (FPM) through smallest section of damper assuming total duct air flow through that smallest damper section), the Ruskin test velocity, and other parameters used during the test. The

" Summary of Unit 1 and Common Fire Damper Evaluation" (Revision 2),

indicates whether dampers passed or failed.

In all cases where a damper failed, corrective comments were noted, consisting of such items as installation of oversized springs, new dampers and fan trips.

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The licensee was requested to provide a summary of the test results for those dampers which failed their tests after the corrective actions were implemented.

The licensee provided the inspector with " Status Report /

DAR 221 (NRC Item (85002-EE)/ Fire Damper Unit 1 & Common Areas." This report listed the damper, the type of modification, and whether testing for the modification was completed.

The status report indicated that all modifications to the dampers were completed and tested satisfactorily.

The licensee also provided the inspector with letters dated Septenber 25, 1985, November 15, 1985 and December 12, 1985 from Underwriters Laboratories Incorporated to Ruskin Manufacturers Robert Irsay Company and Perry Nuclear Power Plant respectively, regarding field inspection of fire dampers at the Perry Nuclear Generating Station.

The letters indicated that the subject product did comply with Underwriters Laboratories requirements and that Classification Marks were allowed to be applied to the product.

The information provided to the inspector indicated that modifications performed to resolve this issue did not invalidate Underwriters Laboratories requirements and that dampers would close under normal duct air flow or be provided with a fan trip interlock which provided assurance that the damper would close.

This item is closed.

(Closed) Open Item (440/85015-02(DRS)):

The licensee provided a list of proposed hardware and procedure modifications for various fire areas which are necessary if the plant is to comply with the requirements of 10 CFR 50, Appendix R, Section III.G.2 in the following areas:

Steam Tunnel i

ESW Pumphouse Diesel Generator Building

Radwaste Building

Intermediate Building

Auxiliary Building

Control Complex

These modifications and actions consist of proceduralizing certain local operations, wrapping cable raceways, rerouting certain cables and conduits, installing / extending sprinkler systems, and installing heat shields.

In NRC Report 440/85074, dated December 20, 1985, Open Item 440/85015-03(DRS) regarding installation of radiation heat shields and Open Items 440/85015-08 and 09 regarding wrapping other cables, components, and devices for spurious operation and common enclosure l

were consolidated into Open Item 440/85015-02(DRS)).

As discussed in NRC Report 440/85074, the portion of the open item dealing with proceduralizing certain local operations was closed with Open Item (440/85015-01(DRS)).

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The inspectors verified (during the last inspection) cable and conduit reroutes had been performed and that sprinkler systems had been installed i

in the Intermediate Building and Control Complex over safety-related and i

certain safe shutdown components of one train.

In addition the areas

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inspected requiring caole wrap or radiant energy heat shields indicated no deficiencies although additional cable pulling work was ongoing.

The inspector was provided with a master list which was entitled " Cable

Wrap-TSI Thermo Lag." This list indicated all the areas that were to be

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provided with heat shields or cable wrap.

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The inspector verified that the following cables were provided with j

radiant energy heat shields inside containment as required by Appendix R,

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5ection III.G.2.

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b Cable Number Division

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a.

1R33R13068

b.

1R33R1019B

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c.

1R33R996C.

l d.

1R33R1231C

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1R33R1232D

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The inspector verified that the following cables were provided with cable l

wrap as required by Appendix R Section III.G.2:

(To achieve and maintain

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hot shutdown conditions or prevent spurious activation.)

Fire Zone / Area Cable No.

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a.

ICC-3a 1R33C54238 l

b.

1CC-4a 1R33C5421B

c.

ICC-4a 1R33C5423B

  • d.

ICC-4e 1M25C19X

  • e.

ICC-4e IR33C5459X i

  • f.

1CC-4e 1R33C5461X

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  • Cables wrapped to' prevent spurious operation.

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There are 14 circuits that require the installation of flex blanket elbow joint fire resistive material.

This is scheduled to be installed by l

January 21,'1986.

The licensee indicated that all required cable wrap has been installed except for the following areas because of new circuits added since

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October 1985.

Approximate

Fire Area / Zone Length of Cable

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l to be Wrapped i

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l a.

1CC-3C Switchgear Room (Unit 1 Division 1)

15 feet i

b.

ICC-6 Control Complex (Unit 1 Division 2)

15. feet c.

2CC-6 Control Complex (Unit 2 Division 1)

15 feet

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The wrapping material has been ordered and cable wrapping is scheduled to be completed by February.

Compensatory measures will be established should fuel load occur prior to completion of the cable wrapping and flex blanket installation.

The licensee also provided the inspector with the "CEI Complete NCD Construction Completion Tracking Report" which identified minor deficiencies in the cable wrapping such as improper banding, splits, cracks, and exposed conduits.

These deficiencies are scheduled to be completed by January 9, 1986.

Based on the information from the licensee this item is considered closed.

(Closed) Open Item (440/85015-14(DRS)):

The licensee was requested to provide a complete diesel generator C02 fire protection test result package.

This was provided and the results appeared to be satisfactory except as discussed below.

During a previous inspection the inspectors requested a puff test for the Emergency Diesel Generator C02 system Unit 1, Division 1 (Room 5);

however, the licensee indicated to the inspectors that the HVAC for this system was tagged out in the control room.

The inspectors then requested that the Emergency Diesel Generator C02 system for Unit 1, Division 2 be tested. The licensee indicated that the ventilation system fan trip for the Emergency Diesel Generator CO2 system was miswired between the Unit 1, Division 2 (Room 7) CO2 system and Unit 1, Division 3 (Room 6)

CO2 system.

The inspectors requested that a puff test be conducted on Unit 1, Division 2 (Room 7) without the fan trip.

The inspectors observed the C0 system puff test in Room Number 7 and indicated to the

licensee that corrective action is needed in this area.

The inspectors requested the licensee to forward puff test results for the Emergency Diesel Generator CO system for Unit 1 Division 2 (Room 7) to Region III

when corrective actions were completed.

In addition, the licensee was requested to verify that the proper C02 nozzles were installed.

As requested by the inspector the licensee provided the test results for the Emergency Diesel Generator (EDG) CO2 system for Unit 1 Division 2 (Room 7).

In addition they provided the test results for EDG CO2 systems for Unit 1 Division 1 (Room 5) and Unit 1 Division 3 (Room 6).

It was noted by the licensee that when the bypass (or manual) activation was used the fans and louvers did not respond for all EDG rooms. A work request was written and the problem was corrected.

The licensee also provided the inspector with the C02 Nozzle Specification No. 68-4549-00 Sheet No. 20 entitled "Cardox Wide Angle Nozzle (Total Flood) Model No. C46000."

At the request of the inspector, the licensee performed a puff test for the manual and automatic activation for the EDG C02 system Unit 1 Division 2 (Room 7) and it was verified that the fans tripped, outside louvers closed, and that the alarm properly identified the fire area.

Based on the information provided, this item is considered closed.

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(Closed) Open Item 440/85015-26(DRS)):

Information was unavailable during a previous inspection to verify that the fire alarm system had been installed in accordance with NFPA 72D.

The licensee was requested to verify that the fire alarm system had been designed and installed in accordance with NFPA 720.

As discussed in Report 440/85074 the licensee provided the necessary information confirming that the system was installed in accordance with NFPA 720 with some acceptable deviations; however, it was noted that the licensee had not adequately addressed notification of the fire brigade upon receipt of a fire alarm.

During this inspection the licensee indicated that fire brigade members would be notified by callers and each brigade member would acknowledge the call.

Should the alarm be confirmed as a fire, the fire brigade members would then proceed to the fire station.

This item is considered closed.

(Closed) Open Item (440/85056-01(DRP)):

The inspector noted that gypsum board fire walls contained penetrations for mounting area temperature monitors, plant paging system hand sets, and other equipment.

These penetrations potentially violate the fire resistance rating of the wall and are not representative of the fire wall design contained in submittals to the Office of Nuclear Reactor Regulation (NRR) which described the walls as intact.

As discussed in Inspection Report 440/85074 the licensee provided information which they believed demonstrated the adequacy of existing walls.

This information was reviewed and found acceptable with the exception of the use of pyrocrete on unistruts.

The inspector requested that the licensee provide justification that the pyrocrete can be utilized in the configuration proposed.

The licensee provided the inspector with a letter dated December 16, 1985 from C. Magdalin, Carboline to N. Peters, PNPS which states "We do not have any test data to support this unique requirement; but it is my opinion that the Pyrocrete 241 will remain in place based on the following points.

1.

Pyrocrete 241 does not change state in a fire exposure, i.e.

intumesce, subline.

Rather it protects on the basis of water hydration.

2.

The unistrut edges are curled inward.

Pyrocrete 241 when applied should fill in behind the edges. When cured, Pyrocrete 241 will form a monolithic film that will be locked into place by the unistrut.

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3.

Large scale beam fire tests with Pyrocrete 241, were conducted at (!nderwriters Laboratories, Inc. Lath was attached on the lower flange only. Lath was not used in the web areas. Post burn analysis showed that Pyrocrete 241 did not delaminate from the web, even when the beam was deflected. The web areas of the beam tested, had larger spans that the unistrut, and therefore would represent a more severe condition."

The inspector finds this analysis acceptable and this item is closed.

(0 pen)Openitem(440/85074-01(DRS)):

During the inspector's plant walkdown, four of fifty two fire doors were found inoperable in that they did not latch. These doors were numbered as CC-521, CC-517; IB 218, and IB 217.

The licensee provided the inspector with a document entitled " General Area Fire Protection" which is a suninary of conditions found during walkdowns. This document included a section on fire doors and addressed such parameters as examination for damage, holes, closed door, and type of signs on door etc.

In addition, the licensee provided the inspector with the document entitled " Areas From READINESS CHECKLIST Which Affect Safety-Related Areas."

The licensee indicated that all safety-related areas have been walked down. Any deficiencies noted, such as inoperable fire doors, will be corrected. This item remains open pending inspection of the corrective actions on the doors that were fcund inoperable (during the NRC inspection) by the Resident Inspector staff.

(Closed)OpenItem(440/85074-02(DRS)): During a walkdown by the inspectors, two observations were made in the Cable Spreading Rocm, as follows:

(1) several unsealed penetrations were observed in the fire rated barrien s, and (2) a sprinkler head was observed to have been covered with pyrocrete material which could cause a delayed activation of the sprinkler head.

The inspector verified that the previously identified unsealed penetrations were sealed and the sprinkler head with pyrocrete material was replaced with a new sprinkler head. This item is considered closed.

(Closed) Open Item (440/85074-03(DRS)):

Each fire brigade member receives 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> of both classroom instruction and hands-on firefighting training.

Fire brigade leaders receive an additional 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of special training on organization and use of pre-fire plans.

In addition, certain security personnel receive two 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> training programs on plant systems.

NRC guidelines indicate that all members of the fire brigade should have the opportunity to train as a team in the major areas of the plant. The licensee did not address this guideline in their comparison review of

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Appendix A to the Branch Technical Position 9.5-1.

The inspector learned during a previous inspection that no actual fire drills having demonstrated that the fire brigade applied their classroom and hands-on fire training had occurred in safety-related areas of the plant.

As discussed with the licensee, fire brigade drilling in areas containing safe shutdown equipment is necessary.

During this inspection the licensee provided the inspector fire brigade drill records showing that in excess of twenty fire brigade drills had been conducted in safety-related areas of the plant, demonstrating the fire brigade's continuing preparation and ability in controlling a real fire condition.

In addition, a fire brigade drill was conducted in the Electrical Switchgear Room, Division 1 (Elevation 620') and was found to be satisfactory. Based on the information provided to the inspector, this item is considered closed.

3.

Partially Protected Cable Tray Supports In several areas of the plant cable trays are wrapped with a fire resistive material to ensure one train of equipment necessary to achieve hot shutdown remains free of fire damage. Many of the cable tray supports for the wrapped cable trays are only partially protected with a fire resistive material.

The licensee has been requested to provide an evaluation of the cable tray supports for fire exposure. This will be tracked as an Open Item (440/85090-01(DRS)) and is to be resolved prior to exceeding 5% power.

4.

Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. An open item disclosed during the inspection is discussed in Paragraph 3.

5.

Exit Interview

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The inspector met with licensee representatives (denoted in Paragraph 1)

at the conclusion of the onsite inspection on December 20, 1985 and sunmarized the scope and findings of the inspection. The licensee acknowledged the statements made by the inspector. The inspector also discussed the likely informational content of the inspection report with regard to documents reviewed by the inspector during the inspection. The licensee did not identify the documents as proprietary.

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