U-600349, Final Deficiency Rept 55-85-07 Re Omission of Lateral Supports on American Sprinkler Co Fire Protection Sys in Seismic Category I Bldgs.Initially Reported on 850813. Installation of Addl Supports Will Be Completed by 851215

Final Deficiency Rept 55-85-07 Re Omission of Lateral Supports on American Sprinkler Co Fire Protection Sys in Seismic Category I Bldgs.Initially Reported on 850813. Installation of Addl Supports Will Be Completed by 851215

ML20138K792
Person / Time
Site:	Clinton
Issue date:	12/09/1985
From:	Spangenberg F ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
55-85-07, 55-85-7, U-600349, NUDOCS 8512190072
Download: ML20138K792 (4)

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• U-600349 L14-85 (12 - 09 ) -L 1A.120 ILLINOIS POWER COMPANY CLINTON POWER STATION, P.O. box 678. CLINTON. ILLINOIS 61727 Docket No. 50-461 December 9, 1985 Mr. James G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

Reportable 10CFR50.55(e) Deficiency 55-85-07: Seismic Design and Construe ton of ASC0A'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) 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 (ASCOA'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). This initial notification was followed by one (1) interim report (Ref: .IP Letter U-600259, D. P. Hall to J. G. Keppler, dated September 13, 1985).

Illinois Power's investigation of this matter is complete.

Our investigation into thic matter has determined that this issue represents a reportable deficiency under the provision of 10CFR50.55(e). This letter is submitted as a final report in accordance with the requirements of 10CFR50.55(e).

Attachment A provides the details of our investigation.

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

Sincerely yours,

- l~l F. A. Spangenberg Manager - Licensing and Safety g 21{@@$ $ hN61 Attachment g cc: NRC Resident Office 3 Director, Office of I&E, USNRC, Washington, DC 20555 9g Illinois Department of Nuclear Safety INPO Records Center DEC 11 W B. L. Siegel, NRC Clinton Licensing Project Manager cr5c27

e. k L ATTACHMENT A 4 Illinois Power Company Clinton Power Station '

p Docket No. 50-461 h Reportable 10CFR50.55(e) Deficiency 55-85-07:

Seismic Design and Construction of ASCOA's Fire Protection System Final Report Statement of Reportable Deficiency q

E-Automatic Sprinkler Company of America's (ASCOA's) e 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-p 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 was performed to deteI nine the extent

" of this deficiency'and its potential impact on the safety of operations of the Clinton Power Station (CPS).

t

. Background

! A condition was identified.where a sprinkler pipe

(OFP52AA6) could fail'during an SSE event and potentially strike a fuel oil safety-related. level transmitter-and ,

! isolation valve 1D0009C, causing 1D0009C to become  !

inoperable. As a'part of our initial review and evaluation

of this matter, IP determined that all fire protection

! system piping designed and installed by'ASCOA was.in t- nonconformance with the provisions of' contract

! Specifications K-2856 and K-2857, with regards to lateral i support of piping to prevent collapsefduring a SSE event in ~

l Seismic Category I Buildings. j L

[ . Technical-Requirements

- Contract Specification K-2856, . Technical- Requirements

. Division 3, Section'301 6, paragraphs e.6, through~

'e.ll,~and,in particular paragraph'e.7, requires the;

-contractor to-install vertical and horizontal =(lateral) supports at maximum spans indicated in Tables 301.6'-1

.through 301.6-3.

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. Contract Specification K-2857, Technical Requirements.

Division 3, Section 304.8, paragraph a.1'through'a.11.,

and-in particular paragraph a.7, requires the F . contractor to' install vertical ~and. horizontal supports 1 at the maximum spans indicated Tables 304.8-1 through L 304.8-3.

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a IPage: 1- of 3 .

ATTACHMENT A Investigation Results/ Corrective Action Illinois Power has prepared and implemented an investigation plan to determine the extent of this deficiency at CPS. The investigation plan included the following actions:

1. An engineering review and assessment program on all ASCOA's piping systems in Seismic Category I Buildings was performed to determine the extent of this deficiency.

2. A review was performed to identify similar concerns associated with other subcontractors installing Class "D" piping in Seismic Category I Buildings.

As a result of our review performed by item 2 above, two (2) 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.

Our review determined that Sargent & Lundy (S&L) has assumed responsibility for all dynamic analyses for this Class "D" piping installed by RCI under Sp'ecification K-2887. S&L has stated that the Class "D piping systems installed by RCI could sustain an SSE without failure and collapse (ref: S&L letter SLMI-17113 dated September 6, 1985). Since all RCI Class D piping systems are completely installed and no related deficiencies were identified, no further action regarding RCI was 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 further action regarding MCC Class "D" piping installations was required.

Sargent & Lundy reviewed all ASCOA's drawings for fire protection piping installed in Category I Buildings and identified on these drawings the location and direction of additional supports that would be required to bring the ASCOA piping systems into compliance with specifications K-2856 and K-2857. These drawings were sent to ASC0A's engineers for design selection of the type of supports to be installed. Where supports could not be installed due to interference from other plant equipment or components, ASCOA resubmitted those support locations to S&L for evaluation and resolution. ASCOA has revised their Class "D" piping drawings for all Seismic Category I Buildings to incorporate the additional supports required to meet specification ,

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ATTACHMENT A requirements. It is anticipated that the installation of the additional supports will be completed by December 15, 1985, at which time the ASCOA fire protection piping systems in Category I Buildings will be in compliance with contract specifications.

Root Cause Our investigation and evaluation has determined that the root cause associated with this issue was the misinterpretation of the contract specifications K-2856 and K-2857 by ASC0A.

SAFETY IMPLICATION / SIGNIFICANCE Our investigation of this matter is complete. Illinois Power Company has reviewed and evaluated the findings associated with this investigation and has determined that an extensive engineering evaluation and analysis would be required to establish the adequacy of the fire ~ protection piping to perform its intended design function if uncorrected. However, it can be postulated that under a seismic event the large sized fire protection piping without lateral restraints could have impacted safety-related equipment and components located in close proximity, resulting in a condition adverse to the safety of operations of the Clinton Power Station. On this basis the issue is considered to be reportable under the provision of 10CFR50.55(e).

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