The inspectors identified that the licensee failed to implement its
Fire Protection Program in accordance with program requirements by failing to follow approved
Fire Protection Program procedures for the control of
transient combustible materials. This issue is considered to be an Unresolved Item pending additional review by the inspectors to determine whether the performance deficiency is of more than minor safety significance. On September 29, 2009, with Unit 1 operating in Mode 1, the inspectors identified unattended
transient combustible items (a plastic container with about one quart of Mobil
DTE 26 motor oil, a plastic container with about one pint of Syn-Air lubricating oil, an empty collapsible plastic container, a plastic bottle half-filled with what appeared to be a soap-bubble and water solution used for leak detection on pipe fittings, two paper towels, and other assorted small debris items) underneath two air receiver tanks in the Division 1 Diesel Generator Ventilation Fan Room on the Diesel Generator Building 762 elevation. The area in which these
transient combustible items were found contained highly visible red striped paint on the floor and markings indicating the area to be a Combustible Free Zone as described in the Clinton Power Station Fire Protection Evaluation Report (
Updated Final Safety Analysis Report (
UFSAR), Appendix E) or; alternatively, a
Transient Combustible Free Zone (TCFZ) as described in
OP-AA-201-009, Control of
Transient Combustible Material, Attachment 5, Clinton Station Specific Information, Revision 9. As stipulated in Attachment 5 of
OP-AA-201-009, the placement of
transient combustible materials in these areas without prior approval in the form of a
Transient Combustible Permit and Plant Barrier Impairment and additional compensatory measures is prohibited in Modes 1, 2, and 3. Neither a
Transient Combustible Permit nor a Plant Barrier Impairment was approved for these
transient combustible items and no compensatory measures had been established. The procedure further stated that the TCFZs at Clinton Power Station are provided for the purpose of separating redundant
safe shutdown equipment. According to the Fire Protection Evaluation Report, redundant
safe shutdown equipment of concern for the Division 1 Diesel Generator Ventilation Fan Room included equipment to support operation of the Division 1
DG and main power feed cables for the Division 2
DG. Consequently, a fire in the room could result in the loss of power from both the Division 1 and Division 2
DGs. Upon discovery, the inspectors promptly notified the licensee and the items were removed. The items discovered were determined to be Class A and Class B materials as defined in
OP-AA-201-009. It is unknown when these items were placed underneath the air receivers. The inspectors reviewed the licensees condition evaluation of this issue. The licensee concluded that the items had likely been under the air receiver tanks for several years based on the layer of dust covering them, but not until sometime after mid-2001 based on the style of the labels found on the containers. The licensee attributed the cause to the difficulty in finding the items without extra effort to look into areas not normally used for storage of materials. The inspectors previously documented findings during the fourth quarter of 2007, first quarter of 2008, and fourth quarter of 2008 involving the licensees failure to follow approved
Fire Protection Program procedures for the control of
transient combustible materials. Those findings were attributed to poor worker behaviors with storing or staging work materials in TCFZs and inadequate walk downs of the plants TCFZs. The licensee noted in its evaluation that corrective actions for these findings included several walk downs of the plants TCFZs to identify and remove materials as an extent of condition investigation; however, these walk downs were not sufficient to identify and remove all
transient combustible materials since items were found after each walk down. The inspectors noted that the unattended
transient combustible items were readily visible by dropping to one knee and looking under the air receiver tanks with a flashlight. The licensees immediate corrective action for this issue was to remove the combustible items from the TCFZ. The licensee has subsequently changed its
UFSAR and plant procedures to allow some negligible quantities of combustible materials inadvertently or accidently left within the TCFZs based upon an engineering evaluation. The inspectors have requested assistance from a regional fire protection specialist to review the licensees engineering evaluation and
UFSAR changes. This issue is considered to be an Unresolved Item (
URI 05000461/2009005-01) pending additional review to determine whether the performance deficiency is of more than minor safety significance. The licensee entered this issue into its corrective action program as Action Request (
AR) 00972704
