ML20137J615

Insp Repts 50-456/96-16 & 50-457/96-16 on 961013-970312. Violations Noted.Major Areas Inspected:Plant Support

ML20137J615
Person / Time
Site:	Braidwood
Issue date:	03/31/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137J563	List: ML20137J558 ML20137J604 ML20137J615
References
50-456-96-16, 50-457-96-16, NUDOCS 9704040079
Download: ML20137J615 (21)

See also: IR 05000456/1996016

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U. S. NUCLEAR REGULATORY COMMISSION

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REGION 111

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f- Docket Nos.: 50-456; 50-457

License Nos.: NPF-72; NPF-77

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Report Nos.

50-456/96016(DRS); 50-457/96016(DRS)

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i Licensee: Commonv/ealth Edison Company

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Facility: Braidwood Nuclear Power Plant

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i Location: RR #1, Box 84

] Braceville,IL 60407

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Dates: October 13,1996 through March 12,1997

, inspectors

Darrell Schrum, Reactor Engineer

j Doris Chyu, Reactor Engineer

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Approved by: Ronald Gardner, Chief

Engineering Specialists Branch 2

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Division of Reactor Safety

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97o404o079 970331 l

PDR ADOCK 05000456 j

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EXECUTIVE SUMMARY

Braidwood Nuclear Station Units 1 and 2

NRC Inspection Report 50-456/96016(DRS); 50-457/96016(DRS)  !

) This regional inspection reviewed the licensee's fire protection program and several

Appendix R issues. The following strengths and weaknesses were identified:

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Plant Suooort

• An unresolved item was identified concerning the licensee's interpretation of the

design basis for hot shorts in motor-coera%d valve control circuits that occur during

a control room fire (Section F1). i

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l * Control of combustibles and material conditicn of fire protection equipment were  !

i good (Section F2.1).

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l * An unresolved item was identified concerning the design basis of the reactor I

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coolant pump oil collection system (Section F2.2).

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i e The licensee identified, during Thermo-Lag resolution activities, that several .

incorrect cable separation assumptions could potentially result in the inability to l

achieve and maintain safe shutdown conditions if a fire occurred in certain fire '

zones. This is an apparent violation (Section F2.3).

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j The licensee identified that the roll-up doors, separating various equipment rooms

and the Turbine Building, were inoperable and did not meet the 3-hour rated fire )

i barrier requirement. This condition existed since 1991 for Unit 1 and since plant

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construction for Unit 2. This is an apparent violation (Section F2.4).

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• One violation of Technical Specification 6.8.1 was identified where the licensee

failed to properly fiil out Hot Work Permits on numerous occasions (Section F3).

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• Two weaknesses concerning fire brigade training were noted. The first weakness

concerned the large number of personnelinvolved in each fire drill which reduced I

individual participation in the drill. The second weakness involved the lack of

information exchanged during drill critiques (Section F5).

• The inspectors identified weaknesses in the use of fire watches in lieu of permanent

corrective actions (Section F6).

• One unresolved item was identified concerning the licensee's use of high energy

line break (HELB) watches to close the fire doors between Auxiliary and Turbine

Buildings in case of an HELB in the Turbine Building (Section F8).

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Report Details

] IV. Plant Suncort

F1 Control of Fire Protection Activities

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i F1.1 Motor-Ooerated Valve (MOV) Hot Shorts

l a. Insoection Scoce

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The inspectors reviewed the licensee's response to Information Notice (IN) 92-18,

Braidwood Safety Evaluation Reports (SERs), and the Braidwood Fire Protection

Report.

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j b. Findinas and Observations

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On February '28,1992, the NRC issued Information Notice (IN) 92-18, " Potential for

! Loss of Remote Shutdown Capability During a Control Room Fire." This IN

{ identified a potential common mode failure of MOVs in which a postulated fire

i could cause hot shorts in the valve control circuit and bypass the valve protective

j features (i.e., limit and torque switches). The spurious operation of the MOVs

j could cause physical damage to the valves which were required to be operated to

j achieve and maintain safe shutdown conditions.

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! The licensee's initial evaluation of IN 92-18 was performed in 1992. The licensee

elected not to take corrective actions because a fire in the control room was

j considered a low probability event. After the NRC identified that other Rill

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licensees' responses to IN 92-18 were not adequate, Braidwood initiated further

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MOV evaluations. The evaluations indicated that no pressure boundary would be i

j violated as a result of fire induced MOV damage. However,50 valves were

identified as susceptible to hot shorts. The licensee did not take corrective actions

] for the majority of the valves because the licensee assumed only one spurious

actuation and the availability of redundant equipment.

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I The licensee indicated the, except for high-low pressure interfaces, Byron and

Braidwood SER commit'nents for safe shutdown were approved for one spurious

actuation. In additior', the licensee stated that the guidance of Generic Letter

l (GL) 86-10, " Implementation of Fire Protection Requirements," was correctly

l interpreted and implemented. Therefore, a spurious actuation was not a safe

i shutdown prcblem because redundant components would be available due to

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adequate separation, and procedures were in place to accommodate each singular

j hot short.

The following Byron SSER 5 (the same SSER applies to Braidwood) statement was

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used by the licensee to support their position:

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"The applicant also performed a detailed analysis of circuits whose fire-

i induced spurious operation could adversely impact safe shutdown. This

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analysis included a review of high-low pressure interfaces. For each fire

zone, the applicant's analysis assumed all equipment and circuits located in

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the fire zone were unavailable and one spurious actuation resulted from the

fire. The applicant's analysis demonstrated that through the fail-safe design

of air-operated valves or with manual operation of components, post-fire

safe shutdown would not be adversely impacted. For the high-low pressure

interface of the Reactor Heat Removal (RHR) pump suction lines, the

applicant demonstrated that adequate separation of the valve control circuits

and pressure interlock circuits existed to ensure one valve of the redundant

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valves in series would not spuriously operate due to fire damage in any one

fire area. For the concern of spurious operation of the pressurizer Power

Operated Relief Valves (PORV's), the applicant has committed to prevent or

mitigate the spurious oparation of these valves by either 1) isolating the

valves prior to an occurrence of a fire,2) providing electricalisolation or

3) providing a means to detect and defeat any spurious operations."

The licensee stated that they comply with GL 86-10, Question 5.3.10, which

stated the following: "Per the criteria of Section Ill.L of Appendix R a loss of offsite

power shall be assumed for a fire area concurrent with the following assumptions:

a) The safe shutdown capability should not be adversely affected by any one

spurious actuation or signal resulting from a fire in any plant area; b) The safe

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shutdown capability should not be adversely affected by a fire in any plant area

which results in the loss of all automatic function (signals, logic) from the circuits

located in the area in conjunction with one worst case spurious actuation or signal

resulting from the fire; and c) The safe shutdown capability should not be adversely

affected by a fire in any plant area which results in spurious actuation of the

redundant valves in any one high-low pressure interface line."

The licensee stated that mechanical damage to multiple valves during hot shorts

was a new condition not assumed in the original design bases or required by any

NRC correspondence. In addition, the licensee stated that no actions were required

by IN 92-18 and that the need to consider multiple spurious actuations of MOVs

constituted the imposition of a new requirement not previously imposed by the

NRC.

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The licensee had identified several valves that require modifications or procedural

changes to prevent or mitigate hot shorts. The corrective actions for these valves

will be completed in 1997. The licensee's position that Braidwood's design basis

only included one hot short and did not include the need to account for mechanical

damage to multiple valves has been forwarded to the Office of Nuclear Reactor

Regulation (NRR) for review. This is an unresolved item (URI 50-456/457/96016-

01(DRS)).

c. Conclusion

An unresolved item is identified concerning the licensee's interpretation of the

Braidwood Appendix R design basis for MOV hot shorts during a control room fire.

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F.2 Status of Fire Protection Facilities and Equipment

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! F2.1 Observation of Plant Areas

a. Insoection Scone

The inspectors toured the auxiliary and turbine buildings to observe the control of

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combustibles, fire doors, hose stations, detection equipment, extinguishers, l

3 sprinkler systems, emergency lights, and housekeeping.

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b. Observations and Findinas ' '

Control of combustibles was good with few transient combustibles noted in the

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plant. Flammable liquids were stored appropriately in fire prwi cabinets and safety

cans. There was a minimal amount of oil below rotating equipment.

The material condition of the fire suppression and detection equipment was good.

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Fire brigade equipment was in good condition and was stored in locked cages in

convenient locations in the plant. Most fire doors in the plant were in good

condition. Only a few doors did not latch when they self-closed. Impaired doors

were being tracked by fire protection personnel. However, an impaired fire door

condition that existed for almost six years is described in Section F8.

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The diesel fire pump's reliability was substantially improved after it was placed on ,

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the A-1 maintenance list. Zebra mussels were being monitored and were not a '

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problem.

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) One concern identified during the previous fire protection inspection was the large

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amount of anti-contamination clothing stored below a cable tray containing safety

related cables in the Auxiliary Building. This condition was contrary to Branch

Technical Position 9.5.1 because no automatic fire suppression system was

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provided for the cable trays with combustibles stored nearby. During this

inspection, the inspectors noted that the majority of the anti-contamination clothing

had been relocated away from this area. The remaining clothing was in metal bins

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c. Conclusion

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i Control of combustible materialin the plant appeared to be good. Material

condition of the fire suppression and detection equipment was also good. One

j deficiency noted during the previous inspection concerning the storage of anti-

contamination clothing was corrected.

F2.2 Reactor Coolant Pumn Oil Collection System

a. Insoection Scoo_g

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The inspectors reviewed the documentation and scope of a modification to add

additional oil collection pans to the Reactor Coolant Pumps.

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b. Observations and Findinos l

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The licensee determined that the Reactor Coolant Pump (RCP) oil collection system

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at Byron and Braidwood required additional oil collection pans. The current oil

collection system had 5 drain pans. Two additional drain pans were being added

and a drain p6n was lengthened for each Reactor Coolant Pump. An Operability

Assessmer:t was completed at Braidwood on June 28,1996, to document

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continued operability of both Units. The Unit 2 modification was completed. The

Unit 1 modification will be completed during the next refueling outage.

Appendix R, Section 0, states, "Such collection systems shall be capable of

collecting lube oil from all potential pressurized and unpressurized leakage sites in

the reactor coolant pump lube oil systems." It appeared to the inspectors that the

as-found oil collection systems were not capable of collecting oil from all potential

leakage sites. The inspectors considered this condition as not being in full

compliance with Appendix R, Section 0, and, therefore, outside the licensee's

design basis. However, from March 1996 to March 1997, the licensee failed to

notify the NRC of this condition as required by 10 CFR 50.73. The licensee

disagreed that this was a condition that was outside the plant design basis. This is

an unresolved item pending NRC review (URI 50-456/457/96016-02(DRS)).

c. Conclusions

An unresolved item was identified concerning the licensee's RCP oil collection

system design basis.

F2.3 Aooendix R issues

a. insnection Scoce

The licensee identified several Appendix R deficiencies as part of an effort to

evaluato Thermo-Lag installations throughout the plant in response to Generic Letter 92-08. A Thermo-Lag resolution plan was formulated to re-analyze areas where

Thermo-Lag was installed. The licensee reevaluated the safe shutdown analysis for

11 affected fire zones for both units. After completion of this effort, the licensee

developed the Appendix R Enhancement Plan to review the current safe shutdown

analysis. This effort included 100 percent cable routing verification and

documentation of design basis and assumptions.

The inspectors reviewed the Braidwood Fire Protection Report and Appendix R

Enhancement Plan; LER 95013, Revision 0, dated November 9,1995, and

Revision 1, dated July 3,1996 Plant identification Form (PIF) 456-180-95-013; PIF i

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456-180-95-013S1; and a licensee letter, dated June 12,1996, addressing safe  !

shutdown analysis deficiencies.

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b. Observations and Findinas l

Units 1 and 2 Miscellaneous Electric Eauioment Room (MEER) Supolv Fans

On October 8,1995, the licensee identified that a fire in Fire Zones 11.5-0 or

11.6-0 could render both Units 1 and 2 MEER supply fans inoperable. This was

contrary to the assumptions made in the Braidwood Fire Protection Report (FPR)

Safe Shutdown Analysis. Fire Zones 11.5-0 and 11.6-0 contained MCCs 132X5

and 232X5, which shared common source breakers with MEER supply fans. A fire

in the zones could render MEER supply fans unavailable due to opening of the I

source breakers. l

The equipment in Train A MEERs for both units was cooled by ESF switchgear room

fans and assumed not protected according to the safe shutdown analysis (SSA).

The equipment in Train B MEERs was cooled by MEER supply fans and considered

protected. A postulated loss of Train B MEER supply fans would result in a loss of

DC power and instrument buses to the main control room (MCR) and remote

shutdown panels. In addition, the control power to 4160 and 480 volt switchgear

would not be available. If a loss of DC power condition existed, the licensee could l

use fire hazards panels (FHP) and existing plant procedures BwOA-ELEC-5, "Loca! l

Emergency Control of Safe Shutdown Equipment Unit 1," to achieve safe shutdown  !

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The licensee had existing hourly fire watches for these zones when the deficiency

was identified. The licensee added breakers so that the MCCs and MEER supply (

fans had separate source breakers. Therefore, a fire in Fire Zone 11.5-0 or 11.6-0

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would no longer cause the loss of supply fans for Train 8 MEERs. This deficiency

did not adversely affect the licensee's capability to achieve and maintain safe

shutdown conditions.

kgg : * Unit 1 Emeraency Diesel Generators (EDGs)

On Cstober 20,1995, the licensee identified that a fire in Fire Zone 11.5-0 would I

render 1 A EDG inoperable because the potential transformer (PT) and current

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transformer (CT) cables were not protected with a 1-hour rated fire barrier in the l

zone. These cables were associated with operations of the EDG electronic

governor and automatic voltage regulator. Fire Protection Report, Section 2.4.2.45,

assumed 1 A EDG was protected in this zone but did not recognize that these cables

were also required for operation of 1 A EDG. Although the PT and CT cables for 1B

EDG were not routed through the same zone, unprotected power and control cables

for 1B EDG fuel transfer pumps were routed through the same fire zone. in

addition, a fire in this zone would affect offsite power because cables associated

with SAT cooling fans were routed through the same zone. A fire in this zone

could cause a Unit 1 station blackout.

In addition, the licensee identified that control cables 1DG157 and 1DG175 for 1 A

EDG were not protected with a 1-hour rated fire barrier in Fire Zone 3.2A-1. A fire

in this zone would render both Unit 1 EDGs inoperable. The licensee indicated that

the nonsegregated bus duct and control cables to the ESF bus breakers were routed

through the same fire zone. Therefore, a fire in either Zone 11.5-0 or 3.2A-1 would

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result in loss of onsite and offsite power for Unit 1. The licensee could use an

existing procedure to cross-tie power from Unit 2 and achieve safe shutdown

conditions.

The licensee had existing hourly fire watches for these zones when the deficiencies

were identified. In November 1995, the licensee rerouted the affected cables out

of the fire zones.

Essential Service Water (SX) Pumo

Fire Protection Report Section 2.4.2.34 assumed that 1 A SX pump was protected

and could be operated locally at the switchgear if a fire occurred in Fire Zone '

11.3-0. However, the licensee identified that the 1 A SX pump may not be

available after a fire in the zone because part of the pump power cable was not

protected with a 3-hour rated fire barrier. A fire in this zone would render both 1 A i

and 18 SX pumps unavailable resulting in a loss of all cooling capability and the l

loss of ultimate heat sink for Unit 1. The licensee could use BwOA PRI-8,

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" Essential Service Water Malfunction," to start a Unit 2 SX pump and open cross- 1

tie valves to supply cooling water to Unit 1 through the essential service water i

header. Therefore, safe shutdown conditions could be achieved and maintained. I

The licensee had existing fire watches for this zone when the deficiency was

identified. In October 1996, the licensee rerouted the 1 A SX pump power cable ,

out of the zone. >

_18 Auxiliarv Feedwater (AF) Pumo

FPR Section 2.4.2.50 assumed that both 1 A and 1B AF pump cables were routed

through Fire Zone 11.6-0 and that the 1B AF pump was protected. However, the

licensee did not recognize that control cables 1 AF338 and 1 AF346 were essential

for operation of the 1B AF pump from the emergency control panel. During the <

Thermo-Lag resolution effort, the licensee identified that these control cables were

not protected with a 3-hour rated barrier in Fire Zone 11.6-0. These control cables  !

were associated with the low-low suction pressure pump trip signal Fire damage j

to these unprotected control cables would render the 18 AF pump unavailable since  ;

the pump could not be started locally from the emergency control panel outside the l

AF pump room. Therefore, a fire in this zone could render both 1 A and 18 AF '

pumps inoperable. The licensee indicated that offsite power would not be available

because cables associated with SAT cooling were routed through the zone. Since

offsite power would not be available to the rnain feedwater pumps, the licensee

could not achieve and maintain safe shutdown conditions upon a loss of the Unit 1 l

AF system. l

The licensee had existing hourly fire watches in place when the deficiency was I

identified. In November 1995, the licensee made a logic change so that the control

cables would not affect the ability to start the 1B AF pump at the emergency I

control panel outside the AF pump room. The AF system was a system required

for achieving hot standby condition. This deficiency affected the licensee's ability to

achieve and maintain safe shutdown conditions.

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Loss of Unit 1 Fire Hazard Panel

On June 4,1996, the licensee identified that a fire in Fire Zones 3.2A-1,3.28-1, or

11.5-0 could render both trains of control room ventilation (VC) system and the

Unit 1 FHP unevailable. The loss of VC system would result in instrumentation and

control in the main control room and at the remote shutdown panels becoming.

inoperable. For these affected zones, the licensee initially assumed in the FPR that

VC suction and discharge dampers would fail partially open. The licensee l

concluded that only manual operation of the unaffected fan was required to restore '

VC system and the system would still be available during a fire in these zones.

However, the licensee later determined that the discharge dampers would fail

closed and prevent system flow. No procedures were in place to direct operators

to manipulate the dampers during this condition. The existing FPR bounded the

consequences of the loss of ventilation to the MCR and Auxiliary Electric Equipment

Room (AEER) assuming instrumentation at the FHP was available. However, with

Division 12 power system cables routed through the same zones and not protected,

power supply to Unit 1 FHP would not be available. The licensee concluded that

the capability to shut down Unit 1 could not be demonstrated.

For Fire Zone 3.2A-1, the compensatory actions included:

e Making part of the affected zone a transient combustible and hot work

exclusion area; and

e Providing shift briefing and procedural guidance to direct operators to open .  :

two VC dampers and control room doors and operate VC supply fan l

OVC01CA at the breaker.

For Fire Zone 3.2.B-1, the compensatory actions included:

e Making part of the affected zone a transient combustible and hot work

exclusion area;

e Providing shift briefings of equipment status to operators; and

e Placing the switches at the local panel for Fans IVXO1C and 1VE01C in the

local position.

For Fire Zone 11.5-0, the compensatory actions included:

e Establishing a dedicated fire watches in this zone; and

e Providing temporary procedures and shift briefing to direct operators l

to manually restore Train A control room ventilatbn.

In July 1996, the licensee routed an alternate power source for the Unit 1 FHP from j

a Division 11 power source. Therefore, at the Unit 1 FHP, operators could choose i

the power supply from either Division 11 or 12. In addition, in December 1996, the i

licensee created BwOP VC-18 to provide guidance to operators for restoring one  ;

train of the VC system.

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Loss of Unit 2 Fire Hazard Panel

On June 4,1996, the licensee identified that a fire in Fire Zone 11.4-0 could render

the VC system and Unit 2 FHP unavailable. For a fire in the zone, the VC supply

and return fans and redundant dampers would be disabled. The existing FPR

bounded the consequences of the loss of ventilation to the MCR and AEER

assuming instrumentation at the FHP was available. However, with Division 22

power cables unprotected and routed through this fire zone, Unit 2 FHP would not

be available. The licensee concluded that the capability to safety shut down Unit 2

could not be demonstrated. The licensee's compensatory actions included:

e Establishing dedicated fire watches in this zone;

o Providing temporary procedure to operators for manually restoring Train A of

the control room ventilation system; and

e Conducting shift briefings of equipment status and consequences of a fire in

this zone.

In July 1996, the licensee rnade a modification to provide an alternate power

source for the Unit 2 FHP from a Division 21 power source. In addition, the

licensee procedurized the steps required for restoring one train of the VC system.

Other Affected Zones Associated With VC System

in addition to the above deficiencies, the licensee identified that in the event of a

fire in Fire Zones 2.1-0,11.4C-0, or 11.6-0, the VC system would not be available.

The existing FPR bounded the consequences of the loss of ventilation to the MCR

and AEER assuming instrumentation at the FHP was available. The licensee ,

concluded that instrumentation required to shut down the units would be available '

at the FHPs. Therefore, these deficiencies would not affect the licensee's capability i

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to achieve and maintain safe shutdown conditions. The licensee initiated an

engineering request to evaluate the need to move the controls and instrumentation

of one train of the VC system from the current remote shutdown panels to another

location.

c. Conclusion

The licensee identified that a fire in either of five zones (3.2A-1, 3.2B-1,11.4-0,

11.5-0, or 11.6-0) would affect the ability to achieve and maintain safe shutdown ,

conditions. Specifically, the findings were summarized as follows: i

e A fire in Fire Zone 3.2A-1 wou!d render the VC system, Unit 1 FHP, Unit 1

EDGs, and offsite power inoperable.

e A fire in Fire Zone 3.28-1 would render the VC system and Unit 1 FHP

inoperable.

o A fire in Fire Zone 11.4-0 would render the VC system and Unit 2 FHP

inoperable.

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• A fire in Fire Zone 11.5-0 would render the VC system, Unit 1 FHP, Unit 1

EDGs, offsite power, and MEER supply fans inoperable.

• A fire in Fire Zone 11.6-0 would render the VC system, Unit 1 AF system,

offsite power, and MEER supply fans inoperable

The licensee also identified three zones in which equipment could be damaged but

would not affect the ability to achieve safe shutdown conditions.

• A fire in Zone 11.3-0 would render both Unit 1 essential service pumps ,

inoperable.  !

• A fire in Zone 2.1-0 would render the VC system inoperable.

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• A fire in Zone 11.4C-0 would render the VC system inoperable.

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10 CFR 50, Appendix R, Section Ill.G requires,in part, that one train of systems i

necessary to achieve and maintain hot shutdown conditions from either the contro!

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room or emergency control station (s) is free of fire damage. Section Ill.G.2 requires i

that, except as provided in Section Ill.G.3, where cables of equipment of redundant

trains of systems necessary to achieve and maintain hot shutdown conditions are in i

the same fire area, separation of cables of redundant trains by a fire barrier having a

3-hour rating or 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rating with fire detectoi and an automatic suppression i

system shall be provided. Failure to provide separation of cables of redundant '

trains as evidenced by the above examples is an apparent violation of 10 CFR 50, I

Appendix R, Section Ill.G.2 (EEI 50-456/457/96016-03).

F2.4 Roll-uo Door Problems

a. Insoection Scoce

The inspectors reviewed the licensee's corrective actions for problems identified

with roll-up doors installed between the Turbine Building and the Auxiliary Building.

This was a followup inspection for Unresolved item (50-456/457/96014-05 (DRS)).

On July 3,1996, mechanical maintenance personnel performed surveillance BwMS

3350-001, " Fire and Security Door Serri-Aanual Inspection," Revision O. Several

roll-up fire doors did not go closed as exoected with outside air ventilation supplied

to the room.

The main function of the roll-up doors was to roll down completely during a fire so

as to prevent the fire from affecting redundant safe shutdown equipment. Unit 1

doors were installed during a modification to prevent nuisance security alarms due

to fluctuations in the ventilation systems. Unit 2 doors were installed during initial

construction. The Braidwood Fire Protection Report identified the roll-up doors as

required 3-hour fire barriers. The roll-up doors separated the following roems from

the turbine building:

1 A & 1B diesel generator rooms

2A & 2B diesel generator rooms

Unit 1 Division 11 & 12 ESF switchgear rooms

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Unit 2 Division 21 & 22 ESF switchgear rooms

! Unit 1 non-ESF switchgear rooms

Unit 2 non-ESF switchgear rooms

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Unit 1 miscellaneous electric equipment rooms

Unit 2 miscellaneous electric equipment rooms  ;

All doors, except the EDG room doors, were normally left open to equalize the .

pressure between the auxiliary building spaces and turbine building. '

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i The inspectors reviewed BwMS 3350-001, " Fire and Security Doors Semi-Annual

Inspection"; BwAP 1110-3, " Plant Barrier impairment Program," Revision 3; BwAP

1100-8, " Fire Protection Program System Requirements," Revision 5; Problem ,

Identification Forms 456-120-96-011 and 450-201-96-2158; and Calculation 3C8- I

0691-001.

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The licensee identified additional problems during review of the roll-up door failures

} to close. Those problems are identified below.  ;

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b. Observations and Findinas

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b.1 Wrona Doors Purchased

] Some roll-up doors failed to close against a differential pressure during subsequent

testing. This problem may be applicable to other untested doors. The requirement ,

to operate across a differential pressure was not part of the specification on the

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purchase orders.

b.2 Incorrect Installation of Doors

On October 1,1996, the licensee identified that the original 'nstallation of the roll-

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up doors was not according to the manufacturer's requirement and concluded that

the doors would not meet the 3-hour fire rating. The angle irons for mounting the l

doors contained bolt slots for iron expansion during a fire. The contractor I

mistakenly used the bolt slots for adjustment purposes to miss the reenforcement

j bars in the concrete walls. Bolts at the ends of the slots would prevent the iron

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from expanding and would subsequently deform the doors during a fire. In

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addition, there were no clearances between the angle irons and the Coor for

expansion. The licensee wrote PIF 456-201-96-2158 documenting this installation

discrepancy.

. b.3 No Post-Modification Testina

The licensee identified that post-modification testing was untimely. The

modification to the Unit 1 roll-up doors was completed in 1991. The licensee

delayed the post-modification testing due to a lack of management direction and

low priority. In addition, no installation tests were performed on the Unit 2 roll-up

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doors during plant construction. In 1994, the licensee identified that the roll-up

doors were not tested before they were placed in operation. A PlF was written to

investigate the process that allowed the implementation of design changes without

testing.

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b.4 Inadeouste Surveillance Procedures

The licensee identified several discrepancies in BwMS 3350-001, " Fire and Security

Doors Semi-Annual Inspection," Revision O. Examples of procedural discrepancies

included:

e The procedure did not specify and require documentation of ventilation

status.

e The procedure did not require personnel to reset the spring tension at the

end of the test as required by vendor's information.

e The procedure did not include a closure time requirement of 1 to 2 seconds

as assumed in the High Energy Line Break (HELB) analysis.

b.5 jlprveillance Closed as Comotete

The licensee identified that roll-up door surveillances were signed off as complete

even though the roll-up doors did not fully close. The licensee stated that the

maintenance staff believed that the surveillance only tested the integrity of the door

and that a ventilation problem prevented the door from closing on its own.

However, the surveillance specifically required that the door should close smoothly

and completely. During surveillance testing, maintenance personnel pushed the

door down manually to complete the test. The inspectors identified that the .*

maintenance staff had many opportunities to identify the roll-up doors problems

during surveillance testing, but failed to identify the failure of the doors to meet

surveillance requirements.

b.6 Untimelv Comoensatorv Measures

The licensee issued PlF 456-201-96-1532 five days after identification of the

July 3,1996, failure of the rol!-up fire doors to close during surveillance testing.

As a result, the doors were not closed immediately to protect safe shutdown

equipment. In addition, the licensee did not initiate plant barrier impairments for

two months due to a lack of communication between the maintenance and

engineering staff.

b.7 incorrect Assumotions in Hiah Enerov Line Break Analysis

On September 3,1996, the licensee identified that previous assumptions in the

turbine building HELB analysis were not accurate. The licensee ensured that roll-up

doors were kept closed so that plant equipment required for safe shutdown was

protected from a HELB in the turbine build.ing. The re-performed HELB analysis

demonstrated that safe shutdown equipment would not have been effected by a

HELB with the doors in the partially closed position.

b.8 Lack of Contractor Control

The inspectors identified that the licensee did not adequately control contractor

activities associated with the original door installations.

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The licensee initially allowed 12 roll-up does to be incorrectly installed by the l

contractor. This problem was not identified for more than 6 years. During the

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original installation, the only quality control oversight provided was for holes drilled ,

in the roll-up door supporting wall and for receipt inspection of roll-up door repair

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materials. Despite these earlier problems, the current contractor repairs to the l

doors were performed without a site procedure and utilized minimal work package

guidance. Changes made to the doors as a result of repair activities were not l

formally documented. In addition, contractor preventive maintenance to the doors l

was not documented.

b.9 Enaineerina Knowledae Concerns I

The inspectors identified, during interviews with licensee's engineering staff, that I

they did not understand the basic mechanical assemblies that made the roll-up l

doors operate, even though they had been working on the roll-up door issues for '

months. For example, the engineers did not know if the springs helped the door roll

up or roll down. In addition, they did not understand the function of the ratchet

mechanism. As a result, the technical problems and resultant quality of work for

repair and preventive maintenance activities were the responsibility of the

contractor.

b.10 Opneric Imolications Not Addressed

The inspectors identified that the licensee had not addressed the generic

implications of the roll-up door failures to operate against a differential pressure.

The licensee believed that a 10 CFR 50, Part 21 could not be issued because the

differential pressure was not specified during the purchase of the doors. The

licensee had not recognized that the doors sold by the vendor may not operate in

other applications at other nuclear facilities. As a result, the licensee had not sent a

message on the nuclear network to alert other licensees of potential roll-up door

design problems.

b.11 No Preventive Maintenance

The inspectors identified that preventive maintenance was not evaluated or

scheduled since the roll-up doors were originally installed, sven though the function

of the roll-up doors to close was important to the safe shutdown of the plant.

c. Conclusion

The major deficiency associated with the type of roll-up doors used by the licensee

was that the stats that make up the door rub on the frame when there is a

differential pressure (caused by ventilation systems) between the areas that the

door protects. The doors do not have rollers on the outer edges of tN stats. The

friction increases as the door lowers because of the increased surfact aies of the

slats in contact with the frames of the guide assembly. When the friction plus the

spring tension from the counterbalancing pipe exceeds the weight of the door it

stops. During initial purchase, the licensee did not identify differential pressure as a

potential barrier to door closure. This was a basic design parameter that should

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have been identified by the licensee. As a result, the doors were purchased and

installed without taking the differential pressure into account.

The licensee did an excellent job of identifying the majority of problems related to

the roll-up doors. In addition, the corrective actions were extensive. However, l

since 1991 for Unit 1 and plant construction for Unit 2, the roll-up doors were ,

inoperable and did not meet the 3-hour rated fire barrier requirement. Therefore, a

fire in the fire zones associated with the roll-up fire doors could have damaged

redundant safe shutdown equipment. This was an apparent violation of 10 CFR

50, Appendix R, Sections Ill.G.2 (eel 50-456/457/96016-04).

F3 Fire Protection Procedures and Documentation

a. Insoection Scope

The inspectors reviewed fire protection surveillances, maintenance history on fire

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protection equipment, fire brigade training and drill records, fire reports, hot work

permits, deviation reports, work requests, safety evaluations, controls to prevent

biological fouling by zebra mussels, and audits of fire protection activities.

b. Observations and Findinos

A review of fire reports for the past three years indicated only a few fires involving

hot work. This was an indicator of good transient combustible controls and safely

performed hot work.

During a review of a sample of hot work permits, dated from January 16,1996, to

September 26,1996, the inspector identified that the applicable portions of the hot

work permits were not accurately filled out prior to work.

Some hot work permits did not identify the correct type of hot work. A large  ;

percentage of the hot work permits had blanks where data was required.  :

Applicable precaution statements were not correctly identified in many cases. Non- l

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applicable precautions were often marked. There were examples where the latest

revision of the hot work permit was not used, so the latest precautions statements

were not available to staff,i.e., precaution added as a result of a LaSalle hot work

fire. Braidwood Technical Specification 6.8.1.a required that procedures be

established, implemented, and maintained for activities covered in Appendix A of

Regulatory Guide 1.33. Regulatory Guide 1.33, Appendix A, included fire

protection procedures. The failure to correctly implement Braidwood Station Hot

Work Permit, Attachment A of BwAP 1100-15 is a Violation of TS 6.8.1 (50-

456/457/96016-05(DRS)). Although the few plant hot work fires that occurred i

during the last three years indicated good work practices, even without the exact

controls implemented by the hot work permit, the inspectors were concerned that

plant supervisors allowed the hot work permits to be improperly filled out. In

addition, the fire protection staff did not take action to end this practice. The

licensee took corrective actions for this problem during the inspection.

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c. Conclusions

One violation was identified concerning the failure to properly fill out hot work

permits.

F5 Fire Protection Staff Training and Qualification

a. insoection Scone

The inspectors reviewed fire brigade training, qualification records, and fire brigade

critiques.

b. Findinas and Observations l

A review of records indicated that the fire brigade was meeting its quarterly fire I

brigade training requirements. The records for the fire brigade were adequately l

maintained and indicated whether the brigade members were qualified. l

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A review of fire brigade critiques indicated several weaknesses. There were an

excessive number of persons on each fire brigade drill. Many fire brigade drills had

12 to 14 participan'ts. The majority of the individuals had little participation and i

training during a drill; however, these drills were given credit for the persons having i

met their fire drill requirement. A second weakness was that the fire brigade ,

critiques identified very few problems during fire drills. There was little information i

provided for future training to improve fire brigade performance.

c. Conclusions

, The inspectors identified two weaknesses concerning fire brigade training. The first

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weakness concerned the large number of personnel involved in each fire drill which

reduced individual participation in the drill. The second weakness involved the lack

of information exchanged during drill critiques.

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F6 Fire Protection Organization and Administration

a. insoection Scoce

The inspectors reviewed the timeliness of the licensee's corrective actions in the

! fire protection area. In addition, the f' ire watch program was assessed.

b. Observations and Findinas

The inspectors noted that the number of impairments had been reduced during the l

past year but was still high. Overall, there was a lack of timely corrective actions  !

! for plant barrier impairments and fire protection work request backlog. Some items l

dated back several years. Many impairments were only corrected during outages

resulting in an increase in the number of impairments between outages.

The inspectors identified that the licensee used fire watches extensively for

compensatory measures. This was also noted during the 1993 fire protection

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inspection. The licensee's current practice was to have three roving fire watches

cover the plant all of the time. The licensee did not consider new impairments a

significant concern because the fire watches were already covering the affected

areas. The lack of progress to take timely corrective actions to reduce the plant

barrier impairments and fire protection work request backlog, and the extensive use

of fire watches for compensatory measures was a program weakness.

The inspectors also identified a weakness with the fire watch program in that fire

watches did not observe or know what the impairments were during their fire

watch rounds. For example, by not knowing that a fire door was impaired the fire

watch could not ensure that transient combustibles were kept away from the door.

Any nearby combustibles could significantly increase the risks associated with the

impaired door.

c. .C_onclusions

The inspectors identified weaknesses in the use of fire watches in lieu of permanent

corrective acti^ns.

F7 Quality Assurance in Fire Protection Activities ~

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Audit investigations for fire protection were limited in scope. Very few fire

protection field monitoring reports (FMRs) had been performed. The effectiveness

of identifying problems in the fire protection program was questionable.

F8 Miscellaneous Fire Protection issues

(Onen) Violation 50-456/457/93022-01a(DRS): Untimely corrective actions for an

impaired fire door, between the auxiliary building and the turbine building. The site

hao exhaust and intake air fan problems in the auxiliary building resulting in air

pressure imbalances since construction. A high differential pressure between the

turbine building and the auxiliary building would cause the doors between the

auxiliary and turbine building to slam excessively and be damaged. The doors were

blocked open in March 1991 to partially equalize the air pressure between the

areas. The licensee did not take any corrective actions to modify the fire door or

resolve the ventilation problems prior to the 1993 fire protection inspection.

The door was still blocked open during this inspection. The inspectors noted that a

permanent watch had been assigned to the blocked open door. The licensee stated

that this watch was stationed as compensatory measure for a licensee identified

high energy line break (HELB) concern. The watch was assigned to close the door

during a HELB in the turbine building. As a result of concerns, the resident

inspectors performed a followup inspection for this impairment. The results are

documented in Inspection Report 50-456/457/96011.

The inspectors had a concem about the HELB watch's ability to close the impaired

door during a HELB event and subsequent high temperature steam environment in

the turbine building. Pending additional review this is considered an Unresolved

item (URI 50-456/457/96016-06(DRS)).

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The licensee indicated that a modification will be completed during 1997. The

modification would include the installation of fire dampers in a doorway between

the auxiliary and turbine buildings to equalize the pressures between the areas.

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Conclusions

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The inspectors were concerned about the timeliness of corrective actions because

the door had been impaired for six years. The violation (50-456/457/93022-

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01a(DRS)) for this issue will not be closed until the licensee comcletes the ,

modification.

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(Closed) Violation 50-456/457/93022-01 b: Failure to identify and take corrective

actions for a high failure rate of emergency lights. Effective corrective actions were

taken for emer0ency lighting problems. The failure rate for emergency lighting

during this inspection was very low. This violation is closed.

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V. Manaaement Meetinos

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X1 Exit Meeting Summary

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On March 12,1997, the inspectors presented the inspection results to licensee

management. The licensee acknowledged the findings presented.

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The inspectors asked the licensee whether any materials examined during the inspection

. should be considered proprietary. No proprietary information was identified. ,

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PARTIAL LIST OF PERSONS CONTACTED  :

Licensee

M. Anjum, System Engineer

B. Boyle, Assistant Fire Marshal

M. Cassidy, Regulatory Assurance - NRC Coordinator

D. Christiana, Engineering Programs Lead

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D. Cooper, Operations Manager

H. Cybul, System Engineer Supervisor

J. Gosnell, System Engineer

A. Haeger, Regulatory Assuranc9 Supervisor

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G. Kinsella, Fire Marshall

R. Kerr, Engineering and Construction Manager

T. Kirman, Electrical Maintenance Staff Supervisor

W. Kraus, Root Cause Team

F. Lesage, Site Quality Verification

J. Lewand, Regulatory Assurance

J. Maraida, SEC Engineer

J. Meister, Engineering Manager

D. Miller, Technical Services Superintendent

H. Pontious, Nuclear Licensing Administrator

D. Pierce, Couf. Man. Supervisor  !

K. Radke, Fire Protection System Engineer '

M. Togliette, Regulatory Assurance

T. Tulon, Station Manager

U.S. Nuclear Reaulatory Commission

D. Chyu, Reactor Engineer

R. Gardner, Engineering Branch Chief  !

C. Phillips, Senior Resident inspector

D. Schrum, Reactor Engineer

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INSPECTION PROCEDURES USED

IP 64704: Fire Protection Program

IP 37550: Engineering

IP 37551: Onsite Engineering

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lP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, ard Preventing

Problems

IP 92902: Followup - Engineering

ITEMS OPENED, CLOSED, AND DISCUSSED

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Ooened

50-456/457/96016-01 URI Licensee interpretation of singular hot short during a

control room fire.

50-456/457/96016-02 URI Design basis and capacity of RCP oil collection system. I

50-456/457/96016-03 eel Lack of cable separation in certain fire zones.

50-456/457/96016-04 eel Inoperable roll-up doors as 3-hour rated fire barriers. l

50-456/457/96016-05 VIO Failure to properly filled out Hot Work Permits

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50-456/457/96016-06 URI Ability of personnel to close fire doors during a HELB l

condition in the turbine building. l

Closed

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50-456/457/93022-01B VIO Failure to identify and take corrective actions for a high '

failure rate of emergency lights

Discussed l

50-456/457/93022-01 A VIO Untimely corrective actions for an impaired fire door

between the auxiliary and turbine buildings

LIST OF ACRONYMS USED

AEER Auxiliary Electric Equipment Room

AF Auxiliary Feedwater l

BwAP Braidwood Administrative Procedure

BwMS Braidwood Maintenance Surveillance l

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CFR Code of Federal Regulations

DRP Division of Reactor Projects

DRS Division of Reactor Safety

CST Central Standard Time

DG Diesel Generator

EA Enforcement Action

eel Escalated Enforcement item

EDG Emergency Diesel Generator

ESF Engineered Safety Function

FHAR Fire Hazards Analysis Report

FHP Fire Hazards Panel

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LIST OF ACRONYMS USED (cont'd)  !

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FMR Field Monitoring Report

FPR- Fire Protection Report

GL Generic Letter

HELB High Energy Line Break l

IN information Notice

LER Licensing Event Report

MCC Motor Control Center

MCR Main Control Room

l MEER Miscellaneous Electrical Equipment Room

l MOV Motor-Operated Valves

PDR Public Document Room

l NEl Nuclear Energy Institute l

PlF Problem investigation Form l

PORVs Power Operated Relief Valve

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NEl Nuclear Energy institute  !

NRC Nuclear Regulatory Commission  :

NRR Office of Nuclear Reactor Regulation  ;

NUREGs Nuclear Regulations i

RHR Reactor Heat Removal

SER Safety Evaluation Report

SSA Safety System Actuation l

l SSER Safety Evaluation Report

SL Sargent & Lundy

l SX Essential Service Water

l URI Unresolved item

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