HL-3434, Special Rept 1-93-004:on 930512,discovered That Cable Trays TFQ5-01 & TFR3-01 Were Not Enclosed in Thermo-Lag 330-1 Fire Barrier Matl,Per Safe Shutdown Analysis Rept.Caused by Inadequate Design.Appropriate Fire Detectors Verified

Special Rept 1-93-004:on 930512,discovered That Cable Trays TFQ5-01 & TFR3-01 Were Not Enclosed in Thermo-Lag 330-1 Fire Barrier Matl,Per Safe Shutdown Analysis Rept.Caused by Inadequate Design.Appropriate Fire Detectors Verified

ML20056H063
Person / Time
Site:	Hatch
Issue date:	08/30/1993
From:	Beckham J GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1-93-004, 1-93-4, HL-3434, NUDOCS 9309080162
Download: ML20056H063 (6)

Text

,

. Georgia Power Company 40 inverness Center Parkway Post Offee Box 1295 Birmingham, Alabama 35201 Telephone 205 877 7279 J. T. sockham, Jr. Georgia Power A

Vics President Naclear Hatch Project f*e soortern e4rtnc nstem August 30, 1993 Docket No. 50-321 HL-3434 006080 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Edwin I. Hatch Nuclear Plant - Unit 1 Special Report 1-93-004, Revision 1 Fire Rated Assemblies Inoperable for Greater Than 14 Days -

Results in Special Report as Reouired by the Fire Hazards Analysis ,

Gentlemen: .

In accordance with the requirements of the Unit 1 Technical Specifications  !

and the Fire Hazards Analysis, Georgia Power Company is submitting the l enclosed, revised, Special Report concerning an event. where fire rated .!

assemblies were inoperable for greater than 14 days.

Sincerely, f  !-

J. T. Beckham, Jr.

JKB/cr

Enclosure:

Special Report 1-93-004, Revision I cc: Georaia Power Company Mr. H. L. Sumner, General Manager - Nuclear Plant NORMS U.S. Nuclear Reaulatory Commission. Washinaton. D.C.

Mr. K. Jabbour, Licensing Project Manager - Hatch U.S. Nuclear Reaulatory Commi,sion. Reaion 11 Mr. S. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident Inspector - Hatch t 930Eddli2'930sso T I

PDR S

ADDCK 05000321 POR M

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l Enclosure Edwin I. Hatch Nuclear Plant - Unit 1 Special Report 1-93-004 Fire Rated Assemblies Inoperable for Greater Than 14 Days Results in Sagcial Report as Reauired by the Fire Hazards Analysis A. Requirement for Report This report is required by the Plant Hatch Unit 1 Technical -

Specifications Section 6.9.2, and the Plant Hatch Fire Hazards Analysis, Appendix B, Section 1.1.1. Specifically, Technical Specification i l

Section 6.9.2. states:

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"Special Reports for fire protection equipment operating and surveillance requirements shall be submitted, as required, by the Fire Hazards Analysis (FHA) and its Appendix B ,

requirements."

FHA Appendix B, Section 1.1.1 states: i

" Fire-rated assemblies and sealing devices in fire-rated assembly penetrations separating portions of safety-related fire  :

areas or separating redundant systems important to safety shutdown within a fire area shall be OPERABLE."

Furthermore, Action Statement (a) of Appendix B, Section 1.1.1, allows

[ the fire rated assembly and/or sealing devices to be inoperable for up to 14 days provided, within I hour, a continuous fire watch on at least one ,

side of the affected assembly (s) and/or sealing device (s) is established, '

or fire detectors are verified operable on at least one side of the inoperable barrier and an hourly fire watch patrol is established.

Action Statement (b) states that, if the 14-day time limit is exceeded, a 1 Special Report must be submitted to the NRC within 30 days. In the event described in this report, it was determined that fire rated assemblies l were not installed on two cable trays as required by 10 CFR 50, Appendix R. Investigations showed that these conditions had existed for longer than 14 days; therefore, this Special Report is required.

l B. Unit Status at Time of Event l l

On 5/12/93 at 1700 CDT, Unit I was in the cold shutdown mode with startup preparations in progress.

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Encl'osure Special Report 1-93-004, Revision 1 C. Description of Event On 5/12/93, at 1700 CDT, plant personnel were validating procedure 42SV-FPX-028-0S, " Raceway Surveillance - TSI Materi al ," by using a raceway wrap list recently prepared by the Architect Engineer (A/E). At that time, they discovered that cable trays TFQS-01 and TFR3-01 were not enclosed in Thermo-Lag 330-1 fire barrier material as required by the Safe Shutdown Analysis Report (SSAR). Further investigation revealed that drawing H-40253 was incorrect in that the drawing did not reflect that the subject trays were enclosed in a fire rated material. Also, the trays were not included in surveillance procedure 42SV-FPX-028-OS.

Deficiency Card 1-93-2010 wi.s written to document these conditions.

Operations personnel initiated Limiting Condition for Operation (LCO) 1-93-386 as required by plant administrative control procedures, appropriate fire detectors were verified to be operable, and an hourly fire watch was established as required by the FHA, Appendix B, i Section 1.1.1.

On 5/24/93, investigation into the cause of the event revealed that this condition had apparently existed since implementation of the 10 CFR 50, Appendix R requirements. Since the trays had been in this condition for greater than 14 days, the event was required to be reported in accordance with FHA Appendix B, Section 1.1.1.

D. Cause of Event The cause of this event was an inadequate design. Untimely corrective action was the result of personnel error.

Cable trays TFQS-01 and TFR3-01 were not enclosed in Thermo-Lag 330-1 fire barrier material during the implementation of the 10 CFR 50 Appendix R requirements as a result of an inadequate design. The original analysis was incorrect in that the circuit routing used in the analysis did not reflect actual plant conditions. Specifically, these cable trays contain circuits associated with the Path 3 Safe Shutdown "

equipment and were not analyzed for the appropriate fire area.

Consequently, the requirement for a fire rated enclosure for these cable trays was not identified at that time and the requirement was not translated into the appropriate design and plant documents.

t HL-3434 006080 E-2

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. Enclosure  !

Special Report 1-93-004, Revision 1 l i

The cause of untimely corrective action was personnel error in that the i design deficiency was not clearly communicated to the appropriate l Management in a timely manner. The circuit routing discrepancy was identified by A/E personnel in 1990 as requiring a fire' barrier -

enclosure. While A/E personnel did revise the SSAR on 5/25/90 to. include i these cable trays, they failed to notify plant personnel of the deficient condition through the deficiency card process. Consequently, no actions ,

were initiated to provide fire rated enclosures for the cable trays at t that time nor were any actions taken to update the appropriate drawings  ;

and plant procedures to show that the subject trays were required to be enclosed in Thermo-Lag 330-1. j Subsequent to the initial submittal of this special report, GPC has i determined that rerouting the Path 3 circuits contained in these cable i

! trays to a different fire area rather than providing a fire rated assembly represents the preferred solution. In this case, rerouting the i circuits to a different fire area directly establishes the independence- ,

of the alternate circuits. ,

E. Analysis of Event 1

l In this event, licensed operations personnel initiated LC0 1-93-2010 on t i

5/12/93. Appropriate fire detectors were verified to be operable and an l hourly fire watch was established as required by the FHA, Appendix B, Section 1.1.1, Action Statement (a). Action Statement (a) requires that:

With one or more of the required fire rated assemblies and/or '

sealing devices _ inoperable, within I hour establish a continuous '

fire watch on at least one side of the affected -assembly (s) and/or sealing devices (s) or verify the operability of fire 4 detectors on at least one side of the inoperable assembly (s) and sealing devices (s) and establish an hourly fire watch patrol. ,

These actions would help ensure early detection of a fire in the zone such that timely actions could be taken-to extinguish the fire.

The combustible loading in the affected fire zone is such that a design  !

basis fire would develop slowly allowing ample time for response to the i plant fire brigade. Additionally, full coverage of the area by linear

• heat detection and manual and automatic suppression systems ensures i timely detection and suppression of a fire. Consequently, a fire in the i area would most likely be detected immediately and rapidly extinguished.  ;

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HL-3434 006080 E-3 4

. Enciosure Special Report 1-93-004, Revision 1 i

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In the unlikely event that a fire developed in the area resulting in a loss of function of unprotected circuits including those in cable trays TFQS-01 and TFR3-01, the capability would still exist to achieve and  ;

maintain safe shutdown of the plant. Specifically, the ability to scram i the reactor would be unaffected. Also, the Automatic Depressurization j System (ADS), and a division of the Residual Heat Removal - Low Pressure  !

Coolant Injection (RHR-LPCI) system would be unaffected by such a fire therefore, they would be available to provide adequate core cooling.  !

Based on the above information, it is concluded that this event' had no adverse impact on nuclear safety.  ;

F. Corrective Actions l i

1. LCO l-93-2010 was initiated, appropriate fire detectors were verified _;

to be operable, and an hourly fire watch was established as required  ;

by the FHA, Appendix B, Sectit n 1.1.1, Action Statement (a). These actions were taken on 5/12/93 when the deficient condition was identified.

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2. The involved A/E personnel were counseled regarding failure to notify  !

plant personnel of deficient plant conditions.  !

3. During the development of Design Change Request (DCR) IH93-028, GPC .

determined that rerouting the Path 3 circuits contained in cable j trays TFQS-01 and TFR3-01 is the preferred solution as opposed to -l providing fire rated enclosures for the cable trays. Rerouting the  ;

circuits to a different fire area directly establishes the  !

independence of the alternate circuits.

Additionally, given the current generic' issues related to the  ;

Thermo-Lag 330-1 fire barrier material, rerouting will preclude '

additional installations of this material. Consequently, GPC will '

reroute the Path 3 safe shutdown circuits contained in cable trays TFQ5-01 and TFR3-01. The modification will be completed during the Fall 1994 Unit 1 outage. The hourly fire watch will continue until I

that time. 1

4. Corrective actions relative to the untimely dissemination of information by A/E personnel were previously implemented in 1992 in response to an event as described in Licensee Event Report 1

50-321/92-13. The corrective actions consisted of a procedural revision to provide more specific instructions relative to the {

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HL-3434 i 006080 E-4 I

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. Enciosure Special Report 1-93-004; Revision 1 l responsibility for reporting deficient conditions. These corrective actions would not have prevented the event described in this report l as the event occurred prior to implementation of the corrective l actions. .

5. A review of the administrative controls and procedures used to '

1 implement SSAR requirements will be performed to ensure that the processes and controls are adequate. This review will be completed by 9/30/93. ,

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HL-3434 006080 E-5 t

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