U-600259, Part 21 & Interim Potentially Reportable Deficiency Rept 55-85-07 Re Seismic Design & Const of Automatic Sprinkler Corp of America,Inc Fire Protection Sys.Initially Reported on 850813.Investigation Continuing

Part 21 & Interim Potentially Reportable Deficiency Rept 55-85-07 Re Seismic Design & Const of Automatic Sprinkler Corp of America,Inc Fire Protection Sys.Initially Reported on 850813.Investigation Continuing

ML20135H732
Person / Time
Site:	Clinton
Issue date:	09/13/1985
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
REF-PT21-85, REF-PT21-85-421-000 55-85-07, 55-85-7, PT21-85-421, PT21-85-421-000, U-600259, NUDOCS 8509240175
Download: ML20135H732 (4)

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U- 600259 1 A.12 0 L14-85 ( 09-13 )-L

/LL/NOIS POWER 00MPANY CUNTON POWER STATION, P.O. BOi 678. CLINTON, ILLINOIS 61727 September 13, 1985 Docket No. 50-461 Mr. James G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road .

Glen Ellyn, Illinois 60137 Subj ect: Potentially Reportable 10CFR50.55 (t. Deficiency 55-85-07: Seismic Design and Construction of ASCOA's Fire Protection System

Dear Mr. Keppler:

On August 13, 1985, Illinois Power Company notified Mr. F.

Jablonski, NRC Region III (Ref: IP Memorandum Y-36415 dated August 13, 1985) of a potentially reportable deficiency under the provision of 10CFR50.55(e) concerning the seismic design and construction of Automatic Sprinkler Company of America s (ASC0A's) sprinkler system in Seismic-Category I Buildings.

Contract Specifications K-2856 and K-2857 were misinterpreted by ASC0A's engineers, such that no lateral supports were installed on sprinkler piping at the Clinton Power Station (CPS) . Our investigation of this matter is continuing, and this letter represents an interim report in accordance with the requirements of 10CFR50.55(e)(3) . Attachment A provides the details of our investigation to date.

We trust that this report provides you sufficient background information to perform a general assessment of this.potentially reportable deficiency and adequately describes our overall approach to resolve this issue.

S erelv yours,

' . . Hall

• Vice President 8509240175 050913 RLC/cp ADOCK O 1

$DR Attachment cc: NRC Resident Office Director, Office of I&E, USNRC, Washington, DC 20555 Illinois Department of Nuclear Safety INPO Records Center B. L. Siegel, NRC Clinton Licensing Project Manager i I WPiR d

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ATTACHMENT A Illinois Power Company Clinton Power Station Docket No. 50-461 Potential 10CFR50.55(e) Deficiency 55-85-07:

l Seismic Design and Construction of ASCOA's Fire Protection System Interim Report Statement of Potentially Reportable Deficiency Automatic Sprinkler Company of America's (ASC0A's) misinterpretation of the applicable contract Specifications K-2856 and K-2857 resulted in the omission of lateral supports on fire protection system piping in Seismic Category I Buildings.

This deficiency potentially could result in the failure and collapse of fire protection piping which could cause damage to nearby safety-related equipment / components during a Safe Shutdown Earthquake'(SSE) event. An evaluation is being performad to determine the extent of this deficiency and its potential impact on the safety of operations of the Clinton Power Station (CPS).

Background

A condition was identified where a sprinkler aipe (OFP52AA6) could fail during a SSE event and potentially striie a fuel oil safety-related level transmitter and isolation valve 1D0009C, causing 1D00090 to become inoperable. As a part of our initial review and evaluation of this matter, IP determined that all fire protection system aiping designed and installed by ASC0A was in nonconformance wit 2 the provisions of contract Specifications K-2856 and K-2857, with regards to support of piping to prevent collapse during a SSE event in Seismic Category I Buildings.

Technical Requirements Contract Specification K-2856, Technical Requirements Division 3, Section 301.6, paragraphs e.6 through e.11, and in particular paragraph e.7, require the contractor to install vertical and horizontal (lateral) supports at maximum spans indicated in Tables 301.6-1 through 301.6-3.

Contract Specification K-2857, Technical Requirements Division 3, Section 304.8, paragraph 1, a.1 through a.ll, and in particular paragraph 1.7, requires the contractor to install vertical and horizontal supports at the maximum spans indicated in Tables 304.8-1 through 304.8-3.

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3 ATTACHMENT A (continued) i Investigation Results/ Corrective Action  :

Illinois Power has prepared and is implementing an investigation plan to determine the extent of this deficiency at CPS. The investigation plan includes:

1. A review will be performed to determine the extent of this deficiency by an engineering review and assessment

, program on all ASC0A's piping systems in Seismic Category I Buildings.

2. A review was performed to identify similar concerns l

. associated with other subcontractors installing Class j "D" piping in Seismic Category I Buildings, t

LAs a result of our review performed by item 2 above, two (2) 4 additional subcontractors, Reactor Controls Incorporated (RCI)  ;

and Mark Control Corporation (MCC), were identified as having  !

installed non-safety related (Class D) piping in Seismic Category I Buildings.

l Our review determined that for RCI, the applicable contract Specification K-2887 did not specify special design requirements for Class "D" piping in Seismic Category I Buildings, but Sargent

& Lundy (S&L) assumed responsibility for all dynamic analysis for i this Class "D" piping. S&L has stated that the Class "D" piping i

, systems installed by RCI could sustain an SSE without failure and j ' collapse (Ref: S&L letter SLMI-17113 dated September 6, 1985).

l Since all RCI Class D piping systems are completely installed and

, no related' deficiencies were' identified, no further action regarding RCI is required.

Our review determined:that all Class'"D" piping installed by ,

MCC'was in accordance with the. applicable contract Specification  !

K-2911,: Amendment 6, paragraph 306.12, subparagraph a.9.- No further1 action regarding.MCC Classi"D"~ piping installations is required.

Illinois Power has requested'ASCOA to revise their Class "D"

! piping drawings in all Seismic Category I Buildings to incorporate the horizontal supports required by Specifications K-2856 and 2867. . Following completion of this. action,,S&L will

' review these' drawings to verify' compliance-with design requirements.

Root Cause.

. . Our investigation and evaluation has determined:that the

root .cause . associated with this- issue was- the misinterpretation Lof the contract specifications.K-2856 and K-2867-by'ASCOA.

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ATTACHMENT A (continued)

Safety Implications / Significance Illinois Power's investigation of this potentially report-able deficiency is continuing. The safety implications and significance will be assessed after further background informa-tion has been-evaluated. It is anticipated that approximately forty-five (45) days will be required to complete our investiga-tion,-determine reportability and file a final report on the issue..

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