U-600686, Deficiency Rept 55-86-05 Re Unsealed Gaps in 3-h Rated Fire Wall.Initially Reported on 860717.Investigation Continuing. Addl Fire Watches Established.Final Rept Will Be Submitted in Approx 30 Days

Deficiency Rept 55-86-05 Re Unsealed Gaps in 3-h Rated Fire Wall.Initially Reported on 860717.Investigation Continuing. Addl Fire Watches Established.Final Rept Will Be Submitted in Approx 30 Days

ML20212L014
Person / Time
Site:	Clinton
Issue date:	08/18/1986
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
55-86-05, 55-86-5, L14-86(08-18)-L, L14-86(8-18)-L, U-600686, NUDOCS 8608250164
Download: ML20212L014 (6)

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U-600686 L14-86 (os - 18)-L .

1A.120 ILLIN0/8 POWER COMPANY OO l1P l CLINTON POWER STATION. P.O. B AUG 1.81986 Docket No. 50-461 Mr.' James G.'Keppler fo Nb Regional Administrator Region III U. S. Nuclear Regulatory Commission '

799 Roosevelt Road

. Glen Ellyn, Illinois 60137

Subject:

Reportable 10CFR50.55(e) Deficiency 55-86-05:

Unsealed Gaps (Openings) in 3Hr. Rated Fire Wall

Dear Mr. Keppler:

On July 17, 1986, Illinois Power Company (IP) notified Mr. F. Jablonski, NRC Region III (Ref: IP Record of 2

Coordination Y-202812, dated July 17, 1986) of a potentially repoetable deficiency concerning gaps (openings) and unsealed penetrations in a 3-hour rated fire wall. Our

1. investigation of this matter is continuing. Illinois Power i has reviewed and evaluated the findings associated with this investigation to date, and has determined that if these deficiencies had remained uncorrected, several fire walls in the. plant would not have provided the fire barrier ,

separation, required by design, in the event of a fire.

Extensive engineering evaluations would be required to establish the adequacy of the affected fire walls to perform their intended design function, had these deficiencies gone uncorrected. On this basis, the matter is evaluated to be reportable under the. provisions of 10CFR50.55(e). It is anticipated that approximately 30 additional days will be

o. required to complete the corrective action associated with

,y this issue and. submit a final report on the matter. All actions regarding this issue will be completed prior to 5%

4 power. Attachment A provides the details of our investi-gation to date.

Compensatory measures (additional fire watches) are being established by IP to allow fuel load to proceed until final; actions are complete. These compensatory measures will be established in accordance with IP Procedure CPS 1893.01, and will remain in effect until fire barriere are i in compliance with design requirements.

FAUG 2 01986 8608290164 860G18 g PDn S

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, . U-600686 L14-86(os - 18)-L 1A.120 We trust that this interim 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.

S cerely yours,

. . all Vice President RLC/jky Attachment cc: NRC Resident Office Illinois Department of Nuclear Scfety INPO Records Center 1

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. - U-600686 L14-86 (os - 18)-L 1A.120 ATTACHMENT A ILLINOIS POWER COMPANY CLINTON POWER STATION-DOCKET NO. 50-461 Reportable 10CFR50.55(e) Deficiency 55-86-05:

Unsealed Gaps (Openings) in 3-Hour Rated Fire Walls Interim Report Statement of Reportable Deficiency / Background Illinois Power Quality Assurance (IPQA) identified four (4) gaps (openings) and two (2) unsealed penetrations in a 3-hour rated fire wall on the 800' elevation of the Control Building. The gaps (openings) were found between the concrete wall and the structural steel at approximately the 824' elevation. The unsealed penetrations were found in the same general location at approximately the 820' elevation.

These gaps and unsealed penetrations were discovered during the inspection of air leakage paths while performing the Control Room Pressurization Test (PTP-VC-02).

On July 17, 1986, Illinois Power Company (IP) verbally notified Mr. F. Jablonski, NRC Region III (Ref: IP Record of Coordination Y-202812, dated July 17, 1986) of a potentially reportable deficiency under the provisions of 10CFR50.55(e) concerning gaps and unsealed penetrations in a 3-hour rated fire wall.

Investigation Results/ Corrective Action Nuclear Station Engineering Department (NSED) performed a review of the design requirements regarding sealing of gaps and penetrations. The requirements for sealing of gaps and penetrations were verified in design specifications K-2944 and K-2840 as follows:

Gaps K-2944 - Baldwin Associates' (BA's) Concrete and Grout Work Scope (in part)..... design, qualify, furnish and install specified materials as required to properly complete structural fire and ventilation seals in the horizontal and vertical gaps in concrete and masonry constructions. (K-2944 Amendment 23, Form CPS-1-MW, Rev. 10, Section 7.0).

Penetrations K-2840 - BISCO Penetration Seals Scope (in part)....... design, qualify, furnish, and install ventilation, fire, flood, and radiation seals in the pipe penetrations, core hole penetrations, for internal conduits and cable trays. (K-2840 Amendment 7, Section 301.1).

~.. . U-600686 L14-86 (os - 18 )-L 1A.120 '

ATTACHMENT A (continued)

Based on these. specifications, the work necessary to seal the gaps and penetrations should have been performed.

In addition to the seals discussed.above, IPQA Notification ~of Adverce Trend No. T-86-05-02 was issued on May 21, 1986. The trend identified that a large number of Nonconformance Reports (NCRs) had been written involving seals that had been initially installed and then subsequently removed or modified. These conditions were also included in this investigation.

Remedial Corrective Action NCMR 1-2458 was issued to document the initial deficiency. In addition, a report of this potentially i reportable deficiency was filed as noted above.

Generic Corrective Action / Investigation Plan In order to determine the scope of these deficiencies and their generic impact, the penetration seals were categorized as follows:

Category 1 - External Seals

These are seals which surround pipes, ducts, trays, and _

conduits which penetrate fire-rated floors and walls.

This category also includes seals which bridge gaps between walls, between walls and floors, and between walls and ceilings. For these seals, IP performed a general visual check of all fire-rated walls, floors, and ceilings in the plant identified in the Fire Protection Evaluation Report (FPER). This check was

performed on both sides of each barrier (other than

' those which are inaccessible, such as inside elevator

, shafts). Checks were made using lights and binoculars as necessary to verify wall integrity.

Prior to beginning this walkdown, training was conducted and documented for the participants.

. Category 2 - Internal Seals i

These are seals on the inside of conduits, which are accessible from junction boxes, pull boxes, and panels.

For these seals:

1) IP will perform a complete survey of all fire seals required in the Fire Protection Evaluation

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. - U-600686 L14-86(08 18)-L 1A.120 ATTACHMENT A (continued)

Report (FPER) which were not inspected by BISCO at commodity turnover. Some seals which are.not accessible without determinating/ reterminating cables as well as LOCA seals which'are hard epoxy materials will not be surveyed because these are not subject to the types of damage identified in the Adverse Trend noted above.

2) Until Item 1 is completed and identified problems resolved, additional fire watches will be implemented, in accordance with CPS Procedure (CPS 1893.01), effective at the time of fuel load, for those barriers which are being inspected and

. repaired. These watches will continue until barriers are repaired.

A maintenance standing order was issued to identify the mechanism for proper control of fire seals. This should minimize future seal violations. The need for additional program changes is being evaluated and further corrective action may be necessary.

Identified deficiencies will be documented and resolved in accordance with approved site procedures. All corrective action associated with this issue will be completed prior to 5% power.

Root Cause The root cause of the subject deficiency was determined to be threefold, and categorized as follows:

1) Failure to adecuately implement the construction controls regarc ing modification and alterations of installed seals.

2) Failure during construction to identify all openings requiring seals.

3) Inadequate controls of plant modification and maintenance process to ensure that seals are not violated.

Safety Implications / Significance Illinois Power has reviewed and evaluated the findings associated with this investigation to date, and has determined that if these deficiencies had remained uncorrected, several fire walls in the plant would not have provided the fire barrier separation required by design in the event of a fire. Extensive engineering evaluations

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-. U-600686 L14-86 (08 - 18 ) -L 1A.120 ATTACHMENT A (continued) would be required to establish the adequacy of the affected fire walls to perform their intended design function, had these deficiencies gone uncorrected. On this basis, the matter is evaluated to be reportable'under the provisions of 10CFR50.55(e).

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