View source for U-600825, Amended Final Deficiency Rept 55-86-06 Re Watertight Seals & Openings in Vital Area Boundaries.Initially Reported on 860828.Deficiencies Identified During Verification Activities Corrected

{{Adams
| number = ML20209J507
| issue date = 01/26/1987
| title = Amended Final Deficiency Rept 55-86-06 Re Watertight Seals & Openings in Vital Area Boundaries.Initially Reported on 860828.Deficiencies Identified During Verification Activities Corrected
| author name = Hall D
| author affiliation = ILLINOIS POWER CO.
| addressee name = Keppler J
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION III)
| docket = 05000461
| license number = 
| contact person = 
| document report number = 55-86-06, 55-86-6, U-600825, NUDOCS 8702060337
| document type = DEFICIENCY REPORTS (PER 10CFR50.55E &amp; PART 21), TEXT-SAFETY REPORT
| page count = 10
}}

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  ..  .                                                                       U 600825 L14-87 (01 26)-L 1A.120
        /LLINDIS POWER COMPANY CLINTON POWER STATION. P.O. BOX 678. CLINTON. ILLINOIS 61727 JAN 201987 Docket No. 50-461 Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois     A0137

==Subject:==
Reportable 10CFR50.55(e) Deficiency 55-86-06:
Watertight Seals and Openings in Vital Area Boundaries

==Dear Mr. Keppler:==

On August 28, 1986, Illinois Power Company (IP) notified Mr. F. Jablonski, NRC Region III (Ref: IP Record of Coordination Y-203105, dated September 2, 1986) of a potentially reportable deficiency concerning flood protection of the Circulating Water Screenhouse (CWSH), and openings in the vital area boundaries that exceeded personnel access criteria. Subsequent to submittal of our final report (Ref: IP Letter U-600765, D. P. Hall to J. G.
Keppler dated November 24, 1986) on the subject deficiency, additional findings / deficiencies were identified which are
;              within the scope of this issue.      This letter is being l              submitted as an amended final report to provide this I
additional information. The details of this additional information are contained in Attachment A.
l l                    Our investigation of this matter determined that the subject deficiency represented a violation of the requirements specified in 10CFR50, App. A, Criterion 2 -
l              " Design Bases for Protection Against Natural Phenomena."
l              This criterion in part states, " Structures, systems, and l              components important to safety shall be designed to l
withstand the effects of natural phenomena such as                                                  l earthquakes, tornadoes, hurricanes, floods, tsunami .v.nd
                                                                                                                   ~
l
(              seiches without loss of capability to perform their safety l              functions . . . .
JAN 2 81987 8702060337 B70126 PDR    ADOCK 05000461                                                                                \\
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U-600825 Ll4-87 ( 01 -26 )-L 1A.120 Illinois Power has reviewed and evaluated the findings associated with this investigation and has concluded that the identified floodproofing deficiencies meet the reportability criteria specified in 10CFR50.55(e) section (1)(11) which states, "A significant deficiency in final design as approved and released for construction such that the design does not conform to the criteria and bases stated in the safety analysis report or construction permit."            On this basis, the subject deficiency was evaluated to be reportable under the provisions of 10CFR50.55(e).
We trust that this amended 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, s
t
                                                                               .   . Hall Vice President RLC/bsa                          o t
Attachment cc:       NRC Resident Office Illinois Department of Nuclear Safety INPO Records Center r
9 1

ATTACHMENT A ILLINOIS POWER COMPANY CLINTON POWER STATION Docket No. 50-461 Reportable 10CFR50,55(e) Deficiency 55-86-06:
Watertight Seals-and Openings in Vital Area Boundaries Amended Final Report Statement of Reportable Deficiency On August 28, 1986, Illinois Power Company.(IP) verbally notified Mr. F. Jablonski, U.S. NRC Region III (Ref: IP-Record of Coordination, Y-203105, dated September 2, 1986) of a potentially reportable deficiency under the provisions of 10CFR50.55(e) concerning flood protection of the Circulating Water Screenhouse (CWSH), and openings in the vital area boundaries that exceed personnel access criteria.

===Background===
On June 23, 1986, the Nuclear Station Engineering Department (NSED) initiated Condition Report (CR) No.
1-86-06-074 which identified openings in vital area boundaries that exceed personnel access criteria. CR No.
1-86-08-020 identified various openings'that did not meet FSAR commitments to be watertight. The identified deficiencies included the following:
two 1 5/16-inch lifting holes in the Unit #1 manway cover; five penetrations that were not water sealed on the Unit #2 side of the CWSH; a temporary construction opening still remaining on the Unit #2 side of the CWSH; and a manway cover not installed on the Unit #2 side on the CWSH.
These openings would allow a floodpath through the SX pipechase through the holes of the Unit il manway cover and into the Unit 1, Division 2 SX cubicle.
The identified deficiencies violate the design requirements for flood protection that are cited in two FSAR sections (3.4.1.1 and 9.2.1.2.3). FSAR section 3.4.1.1 states, in part, that water stops are provided in all construction joints up to the maximum flood level and that water. seal rings are provided for all penetrations in exterior walls below the maximum flood level. Section 9.2.1.2.3 states, in part',t that the Shutdown Service Water System (SSWS) will be protected from a design-basis flood.
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ATTACHMENT A (continued)
INVESTIGATION RESULTS
               .IP prepared and implemented an investigation plan to determine the extent of the subject deficiency. Based on this plan the following actions were taken:
: 1.      The Screenhouse structure was walked down to identify any floodproofing deficiencies. Results:
Plant Modification A-047 was issued to resolve all                      ,
vital area boundary deficiencies identified per Sargent & Lundy (S&L) walkdown (SLMI-20089, July 9, 1986) and the initial floodproofing deficiencies identified through NRC concerns.
During the walkdown/ review of the CWSH, six conduit penetrations and one pipe sleeve were identified as additional flowpaths during the Probable Maximum Flood (PMF) into the SX pipechase. Also, there were six additional conduit penetrations that should be sealed, however, these penetrations went from one wet area to another. The twelve (12) penetrations and one (1) pipe sleeve were repaired per ECN-7600 and issued in Plant Modification A-067.
Due to these additional penetrations being found, Plant Modification A-073 was issued revising the barrier classification of the CWSH. The revision shows the SX pipechase and respective Unit #2 areas to be flood barriers.      Maintenance Work Request (MWR) C20998 was issued for BISCO to perform a walkdown following the barrier reclassification. As a result of this walkdown, BISCO identified and installed four (4) additional seals and upgrades to three (3) seals.
One item that was addressed because of the CWSH review but is outside of the scope of this 55(e) is high mechanical failure rate of watertight doors. NSED Memorandums Y-81955, Y-82014, and Y-82015 address testing, surveillance, and operability requirements for watertight doors. CR No. 1-86-09-82, and Plant Modifications HC-19 and HC-20 deal with response and modifications to the doors to correct their high mechanical failure rate.
: 2.      All other areas of the plant subject to internal flooding were walked down during the week of August 18, 1986, to identify any floodproofing deficiencies.
Results:
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q-ATTACHMENT A (continued)
During the' walkdown/ review of the power block, only two areas were identified as requiring work.
Door Number 908, Auxiliary Building - Area 3, Elevation 737': flood outflow path from the stairwell was considered to occur through the bottom gap of the doors however, no gap existed.
Therefore, Engineering Change Notice (ECN) 7613 was issued through Plant Modification A-071. Door Number 1-319, Fuel Building - Area 6, Elevation 712': flood outflow was considered'as above.
Therefore, ECN 7701 was issued through Plant Modification A-071, Supplement 1. Refer to S&L letter SLMI-20377, dated September 16, 1986.
: 3. Quality Assurance (QA) performed surveillances and walkdowns of the design drawings which involve Unit
                        #1/ Unit #2 system or structural interfaces to determine if other problems exist. Results:
Based on the QA surveillance, it has been determined that the installed plant hardware meets the design-configuration in the areas of Unit #1/
Unit #2 Interface for the areas reviewed.                  Two inconsistencies were noted in the design configuration; however, Field Engineering Change Notice (FECN) 15241 was issued which had no impact on the hardware in the plant. Refer to QA letter Q-07232, dated September 11, 1986
: 4. A review was conducted by the architect engineer of the steps taken regarding delay and cancellation of Clinton Power Station (CPS) Unit #2 This review was made to determine if other similar problems could exist as a result of inadequate review of the system and/or structural interface between Unit #1 and Unit #2 Results:
The architect engineer's evaluation concludes that l                                 no specific walkdowns are required (Ref:              S&L letter SLMI-20377, dated September 16, 1986).
: 5. A review was conducted of the work document development procedures to determine what actions could be taken to strengthen the upfront engineering input to assure that design requirements are incorporated into the work document. Also, a review of work verification procedures was conducted to determine what actions could be taken to strengthen the work verification process. Results:
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ATTACHMENT A (continued)
NSED reviewed CPS Procedure 1029.01, " Preparation and Routing of Maintenance Work Requests," and QA Instruction (QAI)-305.02A08, " Maintenance Work Request Review Instructions." This review was performed because Safeguard Security MR-C17578 (Interim Report incorrectly identified this as MR-C17518) initiated and classified on May 15, 1986, was the work document which initially installed the manway cover in the Unit 1 Division 2 SX cubicle. It was installed under this Safeguard Security MR because it was identified as a breach in the vital area boundary. NSED has determined since the Interim Report on this subject that not only CPS Procedure 1029.01, Rev. 9, but also Rev. 8, allowed all work performed on the Security System to be done under a Maintenance Request (MR) per the following note in Section 8.1.11:
NOTE "All work performed on the Security System shall be done under an MR."
This note allowed all Security System work to bypass any required QA/QC review. This deficiency of allowing all Security System work to be done under the MR program was identified and CPS Procedure 1029.01, Rev.
10, was issued on May 28, 1986 deleting this note.
To identify other Security MRs that should have had a QA/QC review, a 100% review was performed by the Maintenance Support Engineering Group of the Security MRs that were initiated during Revisions 8 and 9 of CPS Procedure 1029.01. These revisions were in effect from March 25 through May 28, 1986. The review included 558 MRs of which 58 were identified as not having the required QA/QC review. The 58 MRs identified were then sent to Quality Operations and Maintenance (Q0&M) for their review to determine what, if any, OC Inspections would have been specified if these MRs had been reviewed by Q0&M originally. There were three MRs identified by Q0&M that require field verification to be performed by IPQC. One of the three MRs was MR-C17578 which dealt with the manway cover. This will not require any additional verification because it was reworked by Plant Modification A-47. MRs C31710 and C31711 were issued to verify QC requirements on the work performed by the two other identified MRs (MRs-C06741 & C17515). This verification confirned that the security doors that were worked on still close properly.
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ATTACHMENT A-(continued)
A review was. performed.of Quality Assurance (QA)
Instruction QAI-305.02A08 to determine if there was sufficient guidance to assure that design requirements are properly. incorporated into work documents. This review confirmed that QA reviews MWRs to ensure that the design requirements, as specified by engineering, are contained in the job steps and are witnessed by quality. organization when required by means of hold points.
Illinois Power's review of this matter concluded that the improper installation of the manway cover was an-isolated case where an MR was utilized to work a quality-related item which resulted in a condition significant to the safety of the plant.
: 6. S&L developed a matrix of area-related design attributes (commodities) versus design baseline.
This list was reviewed to determine which of those
       ' attributes have not already received a detailed walkdown. For those which have not received a detailed walkdown, a determination was made as to whether additional walkdowns were required.
Results:
The commodity turnover process was established by Project Management Procedure (PMP) 1.5. This procedure was reviewed to confirm the completeness of the S&L matrix in memo DKS-13-86. Piping whip restraints was the single addition to the list of commodities.
Two design baseline areas were identified as requiring further review for their impact by commodity installation. Both areas were found acceptable by the following additional programs that were performed
              --S&L review of subcompartment pressurization.
              - QA and S&L walkdown of fire suppression effects.
Verification programs that were previously performed were identified for the below-listed commodities.
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4e ATTACHMENT A (continued)
A.          Commodities:     Requires no.further confirmation of installation.
: 1. Penetrations
:                                                                                                               2. Building Gap Seals i                                                                                                               3. Construction Openings & Hatches
: 4. Doors
: 5. Curbs & Kick Plates i                                                                                                               6. Floor Drains
: i.                                                                                                              7. Field Routed Piping
: 8. HVAC Duct Penetrations
: 9. Cable Tray & Conduit L                                                                                                              10. Temporary Attachments l                                                                                                             11. Fireproofing
: 12. Fire Wraps
: 13. Fire Protection Spray Shields
: 14. Insulation
: 15. Whip Restraints B.        ALARA:  Requires no further confirmation of i                                                                                                           installation.
I Radiation Protection confirmed the completeness of the S&L matrix _for radiation concerns and confirmed the existence of a comprehensive ALARA program.
f                                                                                                                 SUPPLEMENTAL INFORMATION f
Subsequent to submittal of the final report regarding l
the subject deficiency, additional findings within the scope
<                                                                                           of this issue were identified by CPS Condition Reports i                                                                                           1-86-11-171 and 1-86-12-029 and therefore have been included in-this amended final report for completeness.
Condition Report 1-86-11-171 identified sixteen (16) seals installed through penetrations in the walls and slabs l
of the CWSH that were not qualified to meet the flood seal criteria for Elevation 714 -0" as specified on the This                                     barrier classification drawing M22-1001-00BC, Revision D.
condition existed because BISCO, the barrier seals contractor, had installed these seals per ECN 5813 which was
:                                                                                             issued September 3, 1985 to revise fire barrier requirements for the CWSH. ECN 5813 identified the flood seal elevation as Elevation 707'-9". The correct flood seal elevation of 714'-0" was issued to the contractor by FECN 10876 on July 19, 1985. An open revision of M22-1001-00BC which had not i
incorporated FECN 10876 was used as a background to present the fire barrier revisions. The background identified the
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ATTACHMENT A (continued) flood seal elevation as 707'-9". For purposes of presentation, the flood seal elevations were relocated on the drawing and inadvertently scoped (circled) - As a result of the flood seal elevation being scoped and ECN 5813 having been issued later than FECN 10876, BISCO assumed a design change for the flood seal elevation from Elevation 714'-0" to Elevation 707'-9". Classification drawing M22-1001-00BC, Revision D was issued on May 2, 1986, incorporating ECN 5813 and FECN 10876. Revision D of drawing M22-1001-00BC correctly identified the flood seal elevation as Elevation 714'-0".
Sargent & Lundy performed a review of change documents which specify barrier classification design requirements.
This review determined that the effect on design information due to incorrect scoping was limited to the subject area (Ref:    S&L Letter SLMI-20808, dated December 30, 1986).
The disposition of CR 1-86-11-171, which was issued December 31, 1986, required six (6) of the sixteen (16) seals to be replaced and the remaining ten (10) seals to be provided with a caulk interface. The disposition was implemented by MWR C08047 and the work was completed on January 7, 1987.
CR 1-86-12-029 identified that sleeve IPH0081 was not sealed in accordance with ECN 7600 which was issued through Plant Modification A-67. ECN 7600 required a BISCO flood seal to be installed, capable of withstanding a maximum flood height of 33 feet; however, CR 1-86-12-029 documents that the sleeve was sealed with a steel plate in lieu of the BISCO flood seal. This nonconformance was documented by NCMR 1-2601. The disposition of NCMR 1-2601 regarding the installed plate was use-as-is and the disposition regarding the plate welds was repair, based on visual inspection.
ROOT CAUSE The root causes of this deficiency appear to be threefold. They may be categorized as follows:
: 1)    Inadequate design review of the impact of flooding on design baseline from area-related design attributes.
: 2)    Working of security system items under an MR per Revisions 8 and 9 of CPS procedure 1029.01,
           " Preparation and Routing of Maintenance Work Requests." This allowed items to be worked without proper QA/QC review.
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V ATTACHMENT A (continued)
: 3)   Inadequate attention was identified in the commodity turnover program concerning area-related design attributes that could impact design bases or hazards analyses that are not associated with a particular system. However, the following conclusions are drawn from this review:
The list of commodities reviewed is comprehensive for non-system related commodities impacting design bases or hazards analyses.
Commodity installation was independently confirmed by verification activities directed at particular design bases or hazards analyses. Deficiencies identified during the verification activities were corrected. No general weakness in commodity installation was identified.
SAFETY IMPLICATION /SIGNTFICANCE Illinois Power's investigation of this matter is complete. Our investigation determined that the subject deficiency represented a violation of the requirements specified in 10CFR50, App. A Criterion 2     " Design Bases for Protection Against Natural Phenomena." This criterion in part states, " Structures, systems, and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami and seiches without loss of capability to perform their safety functions . . .    ."
Illinois Power has reviewed and evaluated the findings associated with this investigation and has concluded that the identified floodproofing deficiencies meet the reportability criteria specified in 10CFR50.55(e) section (1)(11) which states, "A significant deficiency in final design as approved and released for construction such that the design does not conform to the criteria and bases stated in the safety analysis report or construction permit." On this basis, the subject deficiency was evaluated to be reportable under the provisions of 10CFR50.55(e).
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