IR 05000454/1987006

Safety Insp Repts 50-454/87-06 & 50-455/87-06 on 870122-0326.Violations Noted:Failure to Perform Required Associated Circuit Spurious Signal Analysis

ML20206F388
Person / Time
Site:	Byron
Issue date:	04/08/1987
From:	Gardner R, Holmes J, Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206F366	List: IR 05000454/1987006 ML20206F362 ML20206F368
References
50-454-87-06, 50-454-87-6, 50-455-87-06, 50-455-87-6, NUDOCS 8704140233
Download: ML20206F388 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-454/87006(DRS);50-455/87006(DRS)

Docket Nos. 50-454; 50-455 Licenses No. NPF-37; NPF-66 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, Units 1 and 2 Inspection At: Byron Site, Byron, Illinois Inspection Conducted: January 22 through March 26, 1987 Inspectors:We b Ynes Y437 Date b LWit Woe Ulfe Y 44?

Date Approved By: Ron Gardner, Chief f"8-I7 Plant Systems Section Inspection Summary Inspection on January 22 through March 26, 1987 (Reports No. 50-454/87006(DRS);

50-455/67006(DRS))

Areas Inspected: Routine, announced safety inspection on previous inspection findings. This inspection was conducted in accordance with Inspection Procedures 92701 and 9270 Results: Of the areas inspected, one violation was identified (Paragraph Failure to perform required associated circuit spurious signal analysis).

8704140233 870409 PDR ADOCK 05000454 G PDR

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DETAILS 1. Persons Contacted Commonwealth Edison lW. Burkam)er, QA Superintendent 12C. Diaz, : ire Protection Engineer 123M. Pietraszewski, Project Engineer IW. Prinat, Regulatory Assurance 1K. Sullivan, Technical Staff 1R. Ward, Services Superintendent Sargent & Lundy 12E. Crass, Senior Licensing Project Engineer 2L. Cypranowski, Architectural Designer 2K. Green, Project Manager 2A. Nies, Electrical Project Engineer 2R. Odegaed, Quality Assurance Coordinator 2J. Reuan, Electrical Project Engineer 25. Roy, Senior Structural Analyst 2R. Salsbury, Mechanical Engineer 25. Wahlert, Structural Project Engineer USNRC Personnel P. Brochman, Resident Inspector J. Hinds, Senior Resident Inspector I- 1 Denotes persons attending the exit meeting on January 23, 1987.

2 Denotes persons attending meeting at Sargent & Lundy on January 28, 198 Denotes person available for telephone conversation on March 26, 198 . Action on Previous Inspection Findings (Closed) Unresolved Item (454/86039-01): During the Braidwood Appendix R inspection (August 18 through October 22,1986),the inspectors reviewed the protection of associated circuits and identified that no spurious signal analysis for the reactor head vent high/ low pressure interface had been performed as require Subsequently, during the Byron Appendix R inspection (September 22-26, 1986), it was determined that no spurious signal analysis for the reactor head vent high/ low pressure interface had been performed for the Byron Plant either. In addition, the inspectors identified that no spurious signal analysis had been performed for the excess letdown high/ low pressure interface as is also required. The lack of spurious signal anal

- be a violation (454/yses for the above has been determined toof Section 2.c(

87006-01)

Operating License for Unit 1 as discussed in the Appendi _ ._

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- V As a result of this item, the licensee completed an analysis of the ,

4 reactor head vent and excess letdown high/ low pressure-interfaces for both Braidwood and Byron plants. The analysis determined that spurious '

opening of these interfaces would be precluded by de-energizing the .

reactor. head vent and excess letdown circuits from outside the control room immediately following evacuation of the control room. For. Byron-and Braidwood, the necessary required actions.to accomplish these tasks have been included in.the control room evacuation procedure-(PRI-5).for.both plant Supplement- Safety Evaluation Report No. 8 indicatedareviewofthelicensee'sjustificationconcerningthis

. issue was performed and determined to be acceptabl Therefore, due-

. to these corrective actions, no further licensee action .is required .

'. regarding this issue. -In addition, closure of this item also closes the same issue for Unit 2 identified as Open Item (455/86033-04).

I (Closed)UnresolvedItem(455/83-42-03): The. licensee did not provide-the inspectors with documentation or-objective evidence that Halon and Carbon Dioxide Systems have been or would be tested to their design:

n readiness requirements and that verification of the conditions that ,

L must be maintained to achieve the required concentration hold times

. would be made as required by NFPA 12 and NFPA 12 In the Byron /Braidwood station' fire protection report (Amendment 7)

Section 3.0 " Guidelines of BTP 9.5-1," in the introduction, it states,

"The code review consisted of a review and an evaluation of the fire i' protection design, installation, original acceptance testing, and

_ periodic surveillance and maintenance as recommended by the respective NFPA standards." In Table 3-1, it indicates that

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the 18 month surveillance frequency was reviewed and is considered.

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to be satisfactory.

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The licensee provided the' inspector with the Low Pressure Carbon Dioxide Flow Calculations for the Diesel Pump Room No. 1 and river screen house Oil Tank Storage Room No.1

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Co2 System Test Report for the previously mentioned Co2. Systems- ~

- and Chemetron Drawings FL-21352-B (Sheet 32 and 33) Revision B.

No items of noncompliance were observed. This item is considered closed based on licensee's commitments and submitted material ' (0 pen)UnresolvedItem(455/83-42-04): Sealing of penetration

, openings through fire barriers and membrane protection of structural steel for Unit 2 was incomplete at the time of the last NRC Fire Inspection (NRC Inspection Report No. 50-455/85034) aue to continuing

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construction activitie *

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• Penetrations in Fire Barriers In the January 13, 1987-letter, S. Hunsader, CECO, to J..G. Keppler, NRC, it states, "At the time of achieving.5%

powerg save for those seals that are subject to maintenance modification, there will be nine (9) seals that will not be'

complete Incomplete in this connotation includes' seals necessary.for Unit 1 fire protection currently. instal?ed in Unit 1 and' Unit 2 areas. These seals have been upgradt.d and need to be replaced to satisf The letter also states that "y When other attempting Unit 2 design requirements."

to complete a seal which was of this kind, activities created a Unit 1. Reactor Trip."

The licensee indicated that a more appropriate course.of action is to upgrade these seals during the-upcoming Byron Unit 1-refueling outage. The licensee indicated appropriate-compensatory measures would be.take In Attachment 2 to Byron Station Unit 2.0perating License No. NPF-66, Section C, it states, " Prior to exceeding 5% power, the licensee shall seal all construction design penetration openings in the designated fire barriers. Completion of nine (9) seals may be accomplished as requested in the S. C. Hunsader to J. G. Keppler letter, dated January 13, 1987, and in addition,-

penetrations may be left unsealed to facilitate a requirements of-however, a

theplant modification licensee or plant shall provide maintenance compensatory requirement;is measures." Th portion of the item will remain open pending verification by Region III that work on the nine seals (identified in the January 13, 1987 letter to Keppler) has been complete * Protection of Structural Steel The Byron Field Transmittal Form dated December 31, 1986,-from J. Meister to G. Sorensen indicates that, based on a fina walkdown by Sargent & Lundy, all structural steel areas and electrical-items have been fire proofed except six points in the structural steel fire proofing that will require further review. In the transmittal form, it states in points require fireproofing from a life safety /part "These insurance viewpoint . . ."

Based on the previous statement, it is Region III's understanding that the six points in the structural steel fire proofing are not part of any rated, Appendix R fire wall used to separate safe shutdown equipmen In addition, the inspector walked down Fire Zones 2.10, 11.3, 11.4 and 11.5. The inspector did not observe any structural steel that was not protected except in Fire Zone 11.4. In this area, the lack of protection for structural steel was discussed in a letter dated August 20, 1984, to H. Denton, NCR from T. Tramm, CECO, and was found acceptable to the staff as described in the Byron Station Unit 1 and Unit 2 Safety Evaluation Report, Supplement No. 5, dated October 198 .- . .

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During this inspection,.the inspector requested the licensee to demonstrate that the auxiliary steel connected to the ,

protected structural steel would not transmit sufficient heat (based on standard fire time vs. temp curve) to reduce

. the structural steel below-its required fire ratin t The licensee indicated that this scenario was evaluated by computer program which solves three dimensional transients and steady state temperature distribution problems. The licensee agreed to include the heat transfer calculations (of the heat transfer from the auxiliary steel to the structural steel) in the Byron calculation fil .

Based on the information regarding the Sargent & Lundy walkdown of all structural steel areas, the NRC walkdown of several areas, and the licensee's response to the effects of heat transfer from the auxiliary steel to the structural steel (based on computer program and standard time vs. temperature .

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curve), this portion of the item is considered close , (Closed)UnresolvedItem(455/83042-07): Fire-detectors in these areas did not appear to have been installed utilizing the guidelines contained in NFPA 72D and NFPA 72 The licensee provided the inspector with " Automatic Fire Detection System Evaluation for Commonwealth Edison Company Byron Nuclear Generating Station," Revision 2, dated January,6, 1986, obtained from M&M Protection Consultants. This evaluation states that "The

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fire detection systems (zones) at the Byron Station were reviewed against the National Fire Protection Association Standard No. 72E-1978 and 1982 editions, " Automatic Fire Detectors."

Engineering judgement was used as recuired to apply the principles of this standard. This evaluation acdresses only the physical placement and location of detectors."

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The Automatic Fire Detection Evaluation which consisted of three

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phases as indicated in the evaluation is discussed below:

• Phase 1 - Each fire detection zone was physically walked-down, confirming the number of detectors per zone, detector

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identification number, detector location, positioning of

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detector with respect to air handling equipment, piping, structural steel, plant ecuipment, and location of detector (s)

. with respect to the hazarc s in the area protecte * Phase 2 - Volume air changes were examined in each fire zone to determine allowable detector coverage as described in NFPA 72E,

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FiguresA-9-3.4(a)andA-9-3.4(b).

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• Phase 3 - In fire zones determined to have a potential for high air flow velocities, air flow readings were taken in the vicinity of the detectors. The licensee acceptance criteria for air flow in this analysis was 250 feet per minute. In the evaluation, it states, "If this figure was exceeded, we did not in all cases recommend relocation, as it was not considered practical and, in our op" inion, would not enhance the overall detection system desig The evaluation also states-(in the summary) "The actual air flow measurement (Phase III) was considered to be a " fine tuning" of the detection system design as determined by Phases I and II. Based upon our experience, as we expected the air flow phase of this evaluation did not significantly affect the detection s of detectors requiring relocation." ystem design or the number The inspector reviewed the licensee's automatic fire detection system evaluation for Unit 2 and it appeared that adequate engineeringjudgementwasutilized. Based on the licensee's analysis, this item is considered close e. (Closed) Unresolved Item (455/83-42-10): A fire at the remote i shutdown panel could result in a loss of operability of all mainsteam atmospheric relief valve The use of the mainsteam

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safety valves was determined unacceptable by NRR/ASB. One division of atmospheric relief valves is required to be protected from fire, or the capability of local manual control of the atmospheric dump valves and the capacity to maintain communications with the control room is require (1) No procedure was provided to verify local manual operations that are to be performed. This portion of the item was closed in NRC Inspection Report No. 454/86039; 455/8603 (2) Unsealed penetration openings in fire barrier This portion of the item was closed in NRC Inspection Report No. 454/86039; 455/8603 (3) Fire detector was not installed in the high ceiling area at the rear of the remote shutdown panel. In Inspection Report No. 454/86039; 455/86033, it was verified that detection was provided in the ceiling area of Unit 1 Remote Shutdown Panel Roo During this inspection, it was verified that detection was provided for the Unit 2 Remote Shutdown Panel Roo This portion of the item is considered close (4) No emergency lighting was provided. This portion of the item was closed in Inspection Report No. 434/86039; 455/8603 (5) No automatic fire suppression was provided in these area This item was closed in Inspection Report No. 454/86039; 455/8603 .- .-

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f. (Closed) Unresolved Item (455/83-42-41): Section 3.7.9.(1)(e) of the fire protection report requires that the reactor coolant pumps be equipped with an oil collection system capable of collecting the lube oil from all potential pressurized and unpressurized leakage sites in the rehctor coolant pump lube oil syste The licensee indicated that the Reactor Coolant Pump lube oil system is capable of withstanding the Safe Shutdown Earthquake (SSE).

Per Generic Letter 86-10, the oil collection system should have a minimum capacity to channel the quantity of oil from one pum).

The Oil Coslection System per the licensee is identical to tie oil collection of Unit 1 (which has been accepted in SER No. 5)

and which has more than adequate capacity to channel the quantity of oil from one pump. Based on the licensee's response, this item is considered close g. (Closed) Unresolved Item (455/83-42-21): Several areas containing cables and eguipment and associated circuits or redundant safe shutdown trains did not meet the recuirements for 20 feet separation with no intervening combustibles anc automatic fire suppression and '

d & ctio A one hour fire barrier was not provided around one electrical division of the safe shutdown trains as required by Section 3.5B of the fire protection repor The areas listed by the inspector not meeting Section 3.5B of the fire protection report were from Unit 1 or common areas between Unit 1 and Unit 2. This unresolved item for Unit 1 was closed in Inspection Report No. 454/84-60, dated October 10, 198 In addition, an Appendix "R" Audit was conducted for Unit 2 on September 22-26, 1986, where a similar concern was addressed in Inspection Report No. 454/86039; 455/86033, dated November 11, 1986. In Section 3.d.(3) entitled Common Enclosure Concern, , ,

documentation (cable routing) revie: and physical in)lant inspection were performed on a sample basis. The cabling for tie identified components were found to meet the Appendix R,Section III.G.2 twenty foot separation requirements, or were protected by fire wrap, or were addressed by a deviation request; except as noted in Open Item (455/86033-05). Based on the above, this Unresolved Item (455/83-42-41) is considered close (Closed) Unresolved Item (454/85049-03; 455/85034-04): Unqualified rotection water sectional isolational supply syste Region valves installed III Inspection in theN Report fire456 p/85053; 457/85051 for Braidwood documents an NRC concern regarding unqualified sectional isolational valves installed in the reactor building fire protection water supply system. These valves are manufactured by various fire protection equipment vendors and are installed in the Fire Protection Water Supply System in accordance with seismic requirements. Underwriters Laboratories, Inc. does not list or label seismic class materials. Therefore, these valves do not have the required formal fire resistive qualification. This is

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inconsistent with the licensee's commitment in Section 3.6.b.(1)

of the Byron Fire Protection Report to install the Fire Protection Water Supply System in conformance to NFPA Standard No. 14. This is a generic concern for the Byron and Braidwood facilitie In the letter dated July 24, 1986, from R. Smith, M&M Protection, to D. Elias, CECO, it states, "As addressed for Unit 1, the valves being seismically qualified are considered, as a minimum, to be equivalent to listed / approved fire protection cortrol valves and would not adversely affect the operability or availability of Fire Protection Systems." The licensee also indicated that the valves for Unit 2 have been reviewed and found acceptable. Based on the licensee's response and submitted material, this item is considered close i. (Closed) Open Item (454/85-49-02; 455/85-34-03): Fire barrier penetration openings are required by Section 3.4.d.3.(d) of the Byron Fire Protection Report to be sealed to provide protection of the opening that is at least equivalent to that of the fire barrie The licensee's fire code CT Gypsum fire barrier penetration sealing material is an acceptable material if properly applied. The NRC raised concerns at LaSalle Station over the application of fire code CT Gypsum fire barrier penetration sealing material. The licensee has satisfactorily resolved most of these concerns. The following concerns were not resolved during the previous NRC fire inspectio (1) Depth of Penetration Opening To achieve the qualified three hour fire rating, the Gypsum material must be applied to a depth of five inches, in combination with four inches of Thermafiber CT felt. Where there are floors or walls, less than nine inches thick, the licensee had not identified or verified the acceptability of these installation During this inspection, the licensee provided the inspector with several documents regarding this issu In the licensee's document dated June 11, 1986, from G. Klopp to R. Querio the attached memo regarding Response to NRC Byron /

Braidwood concerns involving Depth of Penetration Opening it states "The only areas requiring fire stops in floors which are less than 12" thick are the cable spreading rooms, located directly above the main control rooms in Unit 1 and Unit 2 In these areas, Transco has (or will) install Gypsum seals using details BY-E-05A (Byron) and BR-E-1C (Braidwood) (attached)

which involve the use of 5" CT Gypsum and 4" CT Thermafiber along with the use of a sheet metal collar attached to the floor or floor curb, and rising 5" above the floor or curb level. The CT Gypsum is installed within and to the top of the sheet metal collar, and the CT Thermafiber within the floor and/or cur v

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Use of sheet metal collared firestop has been successfully tested for three hours at CTL on December 20,1985.(TestReport No. 220, attached). Acceptance of the Test Report and the seal installation detail are documented in the Marsh & McLennon letters dated January 3,1986, and March 12, 1986 (attached)."

No deviation s or violations were identified. Based on the-licensee's submitted material, this portion of the item is considered close (2) Large Configuration The Gypsum fire barrier penetration sealing material is applied in large configurations that exceed the dimensions of the configurations qualified by fire test (i.e., control room floor penetration). The licensee has not identified the acceptability of these installation In the NRC Generic Letter 86-10, dated April 24, 1986, it indicates that where exact replication of a tested configuration cannot be achieved, the field installation should meet all of the following criteria:

(a) The continuity of the fire barrier material is maintaine (b) The thickness of the barrier is maintaine (c) The nature of the support assembly is unchanged from the tested configuratio (d) The application of the fire barrier is unchanged

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from the tested configuratio (e) The configuration has been reviewed by a qualified fire protection engineer and found to provide an equivalent level of protectio The licensee provided the inspector with a document dated June 18, 1986, from G. T. Klopp to R. E. Querto with an cttached memo regarding " Response to NRC Byron /Braidwood Concerns Involving Changed Fire Barrier Configuration This memo states "All penetration seal installation details used as fire seals are reviewed and approved by Sargent & Lundy (S&L)

with approvals also from Marsh & McLennon Protection Consultants (M&M PC) for nuclear mutual limited. Each drawing detail er,trapolates data from supportive fire test report (s) applicable to that drawing. These fire test reports are also reviewed and approved by S&L and M&M PC." In addition, this memo states i

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"For seals installed in openings larger than the overall tested configurations, specific details have been developed for us (See Detail BY-E-15 attached. BR-E-20 is similar.) These details use ceramic board type dividers to sectionalize the i large openings into components which are within the tested dimensions for the sealing material."

Based on the NRC Generic Letter and the licensee's supportive documentation, this portion of the item is considered close (3) Cable Density The fire test which qualified the Gypsum material as a three hour rated fire barrier limited cable density (area filled by cables) to 40 percent of the penetration opening. The licensee has not verified conformance of cable density to the qualifying fire test criteri The licensee provided the inspector with a CECO document from G. Klopp to R. Querio dated September 24, 1986, regarding Response to NRC Byron /Braidwood concerns involving cable density. This memo states "All penetration seal installation details used as fire seals are reviewed and approved by Sargent & Lundy (S&L) with approvals also from Marsh & McLennon Protection Consultants (M&MPC) for Nuclear Mutual Limite Each drawing detail extrapolates data from the supportive fire test report (s) applicable to that drawing. These fire test reports are also reviewed and approved by S&L and M&MPC."

In addition, the memo states, "The testing program followed by Transco is set up to test seal configurations that best represent actual field installation In that regard, therefore, Transco's tests of gypsum seals for electrical cable penetrations utilized typical cable loadings representative of the S&L desig Typically, the cable loading in the Transco tests average around 45%, which is well above the normal guideline of 40% cable loadin The licensee also indicated that on the basis of the maximum cable densities tested, Sargent & Lundy researched their design data to see where any actual cable loading exceeded those values. The Sargent & Lundy review found that no wall or floor penetrations contained cable loading greater than the maximum cable densities tested by Transco for Braidwood Unit 1 and for Byron Units 1 and 2. Cable loading for Braidwood Unit 2 will be kept within the established units via normal S&L design contro _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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The licensee also provided the inspector with a document entitled, " Processing of Sargent & Lundy Post Fuel Load Engineering Change Notices (PECN's)" which states on Page 2

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of the systems interaction checklist in Section I.D., entitled,

'/ " Fire Protection" Item 7 "Has the cable tray fill density in an electrical fire stop been exceeded?" It is the inspectors understanding that any future cable modification will be reviewed to ensure that the cable tray fill density is less than the tested configuratio Based on the licensee's response and supportive documentation, this portion of the item is considered close J. (Clcsed) Open Item (455/86033-01): The inspectors examined systems required for safe shutdown as related to Section III.G and L of Appendix No discrepancies were noted except the lack of direct indication of the CST level either at the remote shutdown panel or locally at the tank. Nor is adequate assurance provided by procedures to verify CST level. This is of concern since the suction for the auxiliary feedwater (AF) pump may have to be aligned from the condensate storage tank to the essential service water system prior to the depletion of the CST volum The licensee provided the inspector with the abnormal operating procedure (No. 2 BOA PRI-5) entitled, " Control Room-Inaccessibility -

Unit 2 - Recovery From Safety Injection - Attachment C - (Page 4 of 14)." The licensee's revision states, in part, in Step 3b and 7b, "if CST level indication is NOT available or is suspect, dispatch an Equipment Attendant to continuously monitor AF pump suction pressure locally." In addition, the letter dated January 30, 1987, from CECO to NRC, indicates that the licene,ed operator required reading program will include the procedure revision and the use of an operator aide at each pane Based on the licensee's corrective actions, this item is considered close (Closed) Open Item (455/86033-02): During a review of the procedure entitled " Control Room Inaccessibility Unit 2, No. 280A PRI-5," it was noted that there was no provision for ensuring that either the MSIV's or steam dumps to the condenser would close, thereby, adding a path for inadvertent or uncontrolled blowdown of the steam generator The licensee provided the inspector with Revision 54 of 2B0A PRI-5 which indicates in Step 9.c to close the steam dump isolation valves if the MSIV's or the steam dump valves are ope __ _ _ _ - _ _ - _ - _ _ _ _ _

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O .(Closed)OpenItem(455/86033-03): During the walkdown of the Control Room Inaccessibility Proc.edure (No. 280A PRI-5)

on September 25, 1986, two areas of insufficient emergency lighting were observed as listed below:

Containment lighting required for a path to tne letdow isolation valve AFW throttle valves (005 valves) area in Auxiliary Buildin During this inspection, the licensee indicated that the path taken by the operator during the procedural walkdown would not be the path usually taken to go to the letdown isolation valve CV 8149 A:B: The licensee indicated that the operator would take a more direct lighted path. The licensee provided the inspector with a diagram showing the locations of the lights. The inspector was not able to visually observe installation of the emergency lights inside containment because of the low power testing that was being conducted during the time of the inspection. This portion of the item is closed based on the licensee's response and drawings indicating that emergency lighting in the area is adequat The inspector observed that the emergency lights (No. 708, 709, and 710) for the AFW throttle valve (005) area in the Auxiliary Building were installed. Based on the licensee's corrective action, this item is considered close (Closed) Open Item (455/86033-05): The Auxiliary Building General Area (elevation 383 feet) was found not in compliance with Section III.G.2 separation requirements. Cabling for the redundant diesel driven auxiliary feedwater pump remote start switch is routed through the area with less than 20 feet separation (without fire wrap protection) from motor driven auxiliary feedwater pump cable The diesel driven auxiliary feedwater pump remote start capability is required in the event of : fire in Fire Zone No.11.4- The inspector observed that the remote start switch (No. 2C2E) for the diesel driven auxiliary feedwater pump was rerouted directly from 364 general area to auxiliary feedwater diesel room elevation 838' which is adequately separated from the motor driven auxiliary feedwater pump. Based on the licensee's corrective actions, this item is considered close . Exit Interview The inspector met with the licensee representatives at the conclusion of the inspection on January 23, 1987, and at the Sargent & Lundy on January 28, 1987. The licensee acknowledged the statements made by the inspector. The informational content of the inspection report with regard to documents reviewed by the inspector was discusse The licensee did not identify any such documents as proprietar On March 26, 1987, a conference call was held with the licensee to discuss the violation determined as a result of a followup in-office revie