IR 05000295/1987011

Insp Repts 50-295/87-11 & 50-304/87-14 on 870421-0521. Violations Noted:Failure to Comply W/Tech Specs Re Aircraft Fire Dampers

ML20214S783
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	06/01/1987
From:	Gardner R, Holmes J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214S775	List: IR 05000295/1987011 ML20214S773 ML20214S778
References
50-295-87-11, 50-304-87-14, NUDOCS 8706090416
Download: ML20214S783 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-295/87011(DRS); 50-304/87014(DRS)

Docket Nos. 50-295; 50-304 Licenses No. DPR-39; No. DPR-48 Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name: Zion Nuclear Power Station, Units 1 and 2 Inspection At: Zion, Illinois Inspection Conducted: April 21 through May 21, 1987 Inspector:

W Jeff Holmes 0/1//987 Date'

Approved By:

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Ron Gardner, Chief G!/c /

Reactor Projects Section 3A Date Inspection Summary l Inspection on April 21 through May 21, 1987 (Reports No. 50-295/87011(DRS);

No. 50-304/87014(DRS))

Areas Inspected: Routine announced inspection of licensee action on previous inspection findings and Licensee Event Reports. This inspection was conducted according to inspection modules 62704 and 9270 Results: Of the areas inspected, one violation was identified (Paragraph 3 -

failure to comply with Technical Specifications for the aircraft fire dampers).

8706090416 870602 PDR ADOCK 05000295 G PDR

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DETAILS Persons Contacted

• G. Plim1, Station Manager

• S. Berczywski, Technical Staff Engineer

• T. Boyce, Fire Marshall

• R. BuDowle, Assistant Station Superintendent, Technical Services

• B. Kurth, Assistant Superintendent, Operations

• J. Rappeport, Quality Assurance Engineer

• C. Schults, Regulatory Assurance Administrator

• • D. Wozniak, Senior Engineer SNED USNRC

• M. Holzmer, Senior Resident Inspector

• N. Williamson, Region III Inspector

• Denotes those attending the April 23, 1987 exit meetin ** Denotes individual involved with telephone exit on May 21, 1987 and also exit meeting on April 23, 1987. Licensee Actions on Previous Inspection Findings (Closed) Open Item (295/86019-05): The Licensee Event Reports (LER)

entitled "Two Cribbouse Aircraft Crash Dampers Positioned Open and Inoperable" (LER No. 295/86005) ard "0B Auxiliary Building Supply for Aircraft Damper Failed " Open (LER No. 295/86014) were ,

reviewe The events and actions taken by the licensee regarding these two LERs and LER No. 295/86010 and 295/86010-01 entitled " Removed Aircraft Fire Damper on OAS" are discussed in Section 3 of this repor Based on the information provided to the inspector this item is considered close (Closed) Unresolved Item (295/86019-01; 304/86018-01): The licensee identified that one inch width gaps at the top of several (non-bearing) fire walls were filled with styrofoam. In Licensee Event Report (LER No. 295/86030-00) " Degraded Fire Barriers," the licensee indicates that the event was caused by inadequate design revie The licensee indicated that the styrofoam was removed and replaced with an approved fire rated materia Based on the licensee's identification and corrective actions this unresolved item is considered close *

. (Closed) LER 295/86031: On September 29, 1986, due to an oversight by a foreman, two hourly fire watches were not performed as required per Technical Specification 3.21. The fire watches were required due to inoperable fire barriers in the cable spreading rooms for both units. The corrective action taken by the licensee consisted of personally discussing the incident with the foreman responsible for the oversight. In addition, other foreman involved in making job assignments to station men have reviewed this inciden Based on the licensees actions this LER is considered close . Review of Licensee Event Report Regarding the Aircraft Fire Dampers During the inspection conducted on April 21-23, 1987, the inspector reviewed three Licensee Event Reports (LERs) and one followup Licensec Event Report regarding aircraft fire damper The LERs regarding aircraft fire dampers which were reviewed are summarized below: LER 295/86005: On April 10, 1986, it was identified by the

licensee that two service water pump aircraft fire dampers were failed open and inoperable. Operating and mechanical maintenance personnel removed both fans out of service as a safety precaution

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and were not aware that de-energized fans failed the aircraft dampers. The inoperable aircraft fire dampers were identified within 15 minutes after de-energizing the fans. The compensatory measures taken by the licensee consisted of posting a fire watc Approximately three hours later it was identified that the fire watch was an inadequate compensatory measure to comply with the Technical Specification. The fans were then put back in service and outlet dampers verified close LER 295/8610: On March 3, 1986, while performing PT-210 " Aircraft Fire Detection System Test", it was identified by the licensee that

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one service aircraft fire damper was removed. The aircraft fire damper was removed as a result of maintenance on the fan. At the time the LER was written, it was not known why a fire seal was not installed. A temporary fire seal made of the same sheet metal gauge as that of the fire damper was installed. A fire watch was present until the seal was installe LER 295/8610-01: This followup on the previous LER (LER 295/8610),

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indicated that mechanical maintenance personnel who removed the fan and damper in 1982 were not aware that this was an aircraft fire '

damper and required a fire seal in its plac l LER 295/8614: On April 8, 1986, it was identified that the OB Auxiliary Building aircraft fire damper had failed open. The licensee attributed this event to operating and mechanical personnel who were performing repairs on a Vortex Damper and who failed to recognize that they de-energized the 08 damper control loop. The compensatory action consisted of posting a fire watch until the damper was closed

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on April 9,1986. On April 10, 1986, it was recognized that the Technical Specifications do not allow fire watches as compensatory measures for a failed open aircraft fire dampe ,

e. Corrective Action Corrective action taken by the licensee to prevent future reoccurrences included the following:

The Zion Electrical Distribution (ZED) procedure has been revised to indicate what motor control centers power aircraft crash fans and dampers and to include a caution to

. pneumatically jumper the dampers closed prior to taking the fans out of service, otherwise the dampers will fail open

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resulting in a violation of Technical Specification (3.17.2.1).

Maintenance will attach a job sheet to all future aircraft crash damper work requests indicating specific instruction's on how to take the fans out of service while maintaining the dampers closed and how to seal up any duct openings created by the fan or damper remova Permanent placards were installed on applicable motor control centers for fans having aircraft crash dampers warning personnel to pneumatically jumper the dampers closed prior to taking the fans out of service, f. Conclusion In review of the Licensee Event Reports regarding aircraft fire dampers it was identified that:

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It took approximately three years to identify that the aircraft fire damper for the service water pump area had been removed (LER86-10-01). The licensee identified that the outlet damper was removed while performing semiannual Periodic Test PT-210 entitled " Aircraft Fire Detection System Test." The licensee Wds required by TOChniCdl Specification surveillance to test the aircraft fire detection system by simulating a signal equivalent to a fire condition and verify closure of the aircraft fire damper. However, for approximately three years with the aircraft fire damper removed, adequate compensatory measures had not been in plac Operating and mechanical personnel who were performing maintenance and/or repair work on damper equipment were not aware that during these activities aircraf t fire i dampers tailed open requiring Technical Specification action.

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Inappropriate compensatory measures consisting of fire watchers were taken after identifying that the aircraf t fire dampers failed in the open positio The findings identified above concerning the lack of aircraft fire dampers in the proper position (or the installation of a temporary fire seal) and the lack of adequate compensatory measures are considered a violation (295/87011-01; 304/87014-01). No response is necessary at this time based on the licensee's corrective action . Review of Licensee Event Report Regarding Degraded Fire Barriers During the inspection conducted on April 21 through May 21, 1987, the inspector reviewed Licensee Event Reports (LERs).

The LERs regarding degraded fire barriers which were reviewed are suninarized below

LER 295/86015: On April 15, 1986, during an inspection by the l Quality Assurance Department, four open 1/2" bolt penetrations were identified in t1e unit one control room south wall, LER 295/86024: On May 29, 1986, during an inspection conducted i

by the Quality Assurance Department, an open penetration was l identified in the floor of the service water pump room along the west wall in the Cribhous LER 295/86027: On July 8, 1986, during an inspection conducted by the Quality Assurance Department, two open penetrations were identified in the service water pump room located in the Cribhous One penetration surrounded the diesel oil day tank vent pipe on

, the ceiling and another was a penetration surrounding the air line

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piping through the east wall.

I LER 295/86030: On August 25, 1986, several fire barriers were found to be non-functional due to the presence of a non-fire retardant (styrofoam) material filling the construction gaps at the top of the barriers (refers to Section 2.b of this report). Conclusion In review of the Licensee's Event Reports regarding degraded fire barriers, the license hos initiated renewed emphasis on the quality of fire barrier penetration surveillance. As a result of the licensee effort, three minor and one major LERs regarding degraded fire barriers were identified. Based on the licensee's efforts in identifying and correcting these deficiencies, no NRC action is required at this time. The licensee has demonstrated renewed

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emphasis on fire barrier inspections and should ensure that the root cause for any future deficiencies are identified and correcte _ _ . .

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5. Degraded / Functional Penetration Fire Barrier i In the Zion Administration Procedure (ZAP-04), " Station Housekeeping / Fire Protection," PT-207, Revision 1, Section C.4, " Definitions" it states:

"A degraded functional penetration fire barrier shall be considered as one that is not in accordance with approved installation details but is still considered to be functional in accordance with the Technical Specification design basis. As a minimum, a degraded penetration fire

barrier shall be defined as one whereby the free air penetration opening is filled throughout its length, width and height with a fire retardant inorganic insulating material such as "Kaowool", "Cerafiber" or other approved matorial."

the In regardsinformed inspector to degraded / functional the licensee thatpenetration fivedegraded the identified barriers,/ functional penetration fire barriers should be encompassed by tests conducted by recognized testing laboratories. The licensee was requested to provide the inspector with the recognized laboratory test utilized for determining if a barrier is functional even though it may have been degrade In addition, the inspector requested the insurance and consultant reports regarding the recommendations concerning the applicability

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of the recognized testing laboratories test to degraded / functional barrier The licensee also indicated to the inspector that consideration

will be given to change the procedure to include provisions when I

encountering seal configurations that are not flush with the wall to require a fire protection engineer to review the degraded fire

wall to determine its acceptabilit This is considered an open item (295/87011-02; 304/87014-02) pending

review of the requested material by Region III.

6. Fire Doors

The licensee procedure, " Inspection of Fire Doors", PT-232, requires I at least once every 18 months an inspection of the automatic closing j mechanisms, latches and overall integrity of the fire door.

I The present procedure does not distinguish between doors required to be maintained for Appendix "R"/ Branch Technical Position considerations and other fire doors. The licensee acknowledged the inspectors concern and is considering upgrading the procedure to consider identifying doors that are required by regulatory requirements to be functional at all times or which require compensatory measures.

f 7. Aircraft (Crash) Fire Detection System The aircraft crash fire detection system is composed of what appears to be a non-listed (not approved by recognized testing laboratory),

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fire damper installed in duct work. It is not clear how the installed

, damper will function and prevent the spread of fire in the event of an airplane crash. The licensee was requested to provide justification i and/or modifications to insure that the aircraft fire detection system will function as designed to provide a fire barrier from a fuel spill from an aircraft crash. The licensee was requested to maintain this analysis on-site for future revie This is considered an open item (295/87011-03; 304/87014-03) pending review by Region II . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involves some action on the part of the NRC or licensee or both. Open items are discussed in Paragraphs 5 and 7 of this repor . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviation . Exit Interview i The inspector met with the licensee representatives at the conclusion of j the inspection on April 23, 1987, and summarized the scope and findings

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of the inspection. The inspector discussed the likely content of this report and the licensee did not indicate that any information disclosed during the inspection could be considered proprietary in natur In addition, on May 21, 1987, a conference call was held with Dave Wozniak I to discuss the results of the in-office review of documents discussed in 1 this repor !

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