IR 05000387/1992023
| ML17157C364 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/01/1993 |
| From: | Bettenhausen L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| NUDOCS 9306160103 | |
| Download: ML17157C364 (5) | |
Text
'
Docket Nos.
50-387 50-388 JUN 1. 1993 Mr. Robert Senior Vice President - Nuclear Pennsylvania Power & Light Company 2 North Ninth Street Allentown, Pennsylvania 18101
Dear Mr. Byram:
SUBJECT:
INSPECTION NOS. 50-387/92-23; 50-388/92-23 This refers to your March 19, 1993, correspondence, in response to our February 10, 1993, letter.
Thank you for informing us of the corrective and preventive actions documented in your letter.
These actions willbe examined during a future inspection of your licensed program.
Your reply to violation C states, in part, that the reason for the violation was that the initial construction of fire barriers at the Susquehanna SES were not quality-related activities; inspections of work activities were determined by responsible field engineers; and no requirement existed stating that all activities be inspected.
We cited this violation because some quality measures were required.
During construction fire protection installation activities were not controlled under the QA organization established by 10 CFR 50, Appendix B. However, the Susquehanna SES Fire Protection Review Report (FPRR) states that your commitment for meeting the "Inspection" criterion of the quality assurance guidance in Branch Technical Position 9.5-1, Appendix A, was that field personnel witnessed the fire protection installation and verified conformance with design drawings.
This commitment became a requirement when your fire protection license condition required Pennsylvania Power and Light (PP&L) to implement and maintain all of the provisions of the approved fire protection program described in the FPRR.
Although we disagreed, in part, with your reason for the violation, no further explanation is required because the corrective actions you have committed to perform appear to be comprehensive enough to address our concerns.
OFFICIAI. RECORD COPY 6:SUS9223R 93061h0103 930601 PDR ADOCK 05000387
Mr. Robert JUN 1 1933 Additionally, we cited Violation C because we found instances where your inspection measures did not verify that all of your fire barrier wrap materials were installed in conformance with design drawings.
These nonconformances existed for 12 years after the fire barrier wraps'nstallation because none of your other quality measures, including surveillance testing, identified these installation deficiencies.
This led us to question whether other instances of nonconformances exist in fire barrier wraps or other fire protection features (such as fire doors, fire dampers, fire walls, etc.) installed in your plant.
We note that you have initiated corrective actions to address all of your fire rated raceway wraps and these actions willbe reviewed during a future inspection.
To address our concerns about what actions have been taken to review the quality of other fire protection features, you have committed to correct, reclassify to as-built and control drawings for fire wrapping material, penetration seals, suppression equipment, detection equipment, Appendix R required lighting, and barriers (including walls, doors, and dampers) by no later than May 20, 1994.
This commitment was made du'ring a May 18, 1993, telephone call that was held between Mr. J.
White of this office and Mr. J. Kenney and other members of your staff. This commitment was documented in an internal PP&L memorandum that was forwarded to the Region I offices on May 19, 1993.
Your reply to violation D states that the corrective steps which willbe taken to avoid further violations include maintaining the existing Kaowool fire barriers and not using Kaowool material for new fire barrier installations.
We note that you have verified that all of your required existing Kaowool fire barriers were accepted by the NRC's approval of Deviation Request No. 17.
We consider it appropriate that you consider the information in Generic Letter (GL) 92-08, dated December 17, 1993, as it applies to Kaowool. GL 92-08 states, in
.
part, "the staff expects that the recipients of this generic letter willreview the information to determine ifit applies to other barrier material and systems used at their facilities and consider actions, as appropriate, too avoid similar problems."
Your cooperation with us is appreciated.
Sincerely, gt<g<oaf Signed Bg:
gzz g. gettenhattÃll Lee H. Bettenhausen, Chief Operations Branch Division of Reactor Safety OFFICIALRECORD COPY G'SUS9223R
Mr. Robert CC:
J. M. Kenny, Nuclear Licensing H. G. Stanley, Superintendent of Plant-SSES M. M. Urioste, Nuclear Services Manager D. F. McGann, Supervisor, Nuclear Compliance H. D. Woodeshick, Special Office of the President J. C. Tilton, III, Allegheny Electric Cooperative, Inc.
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
K. Abraham, PAO (2) (w/copy of letter dtd March 19, 1993)
NRC Resident Inspector Commonwealth of Pennsylvania (w/copy of letter dtd March 19, 1993)
bcc:
Region I Docket Room (with concurrences)
bcc: (Via E-Mail)
V. McCree, OEDO R. Architzel, SPLB/NRR P. Madden, SPLB/NRR C. McCracken, SPLB/NRR S. West, DRIL/NRR R. Clark, NRR, Project Manager C. Miller, PDI-2, NRR L. Bettenhausen, DRS N. Blumberg, DRS F. Bower, DRS bcc:
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May 18, 1993 MEMORANDUMTO FlLE TELEPHONE CALl TO NRC REGARDING FIRE PROTECTION FEATURES DRAWINGS This memorandum documents a May 18, 1993 telephone call between Mr. John R. White, Chief, Section 2A, Projects Branch 2, Region l, US NRC, Mr. D.P. Parsons and Mr. J.M.
Kenny regarding plans to bring into compliance Susquehanna SES fire protection features drawings. Specifically, PP&L willcorrect, reclassify to askuilt and control drawings for fire wrapping material, penetration seals, suppression equipment, detection equipment, Appendix R required lighting, and barriers (including walls, doors, and dampers).
This effort will be completed no later than May 20, 1994.
This commitment was agreed to in a meeting with Mr. G.T. Jones attended by G.D. MIlier, J.M. Kenny, D.P. Parsons, M,D. Stout, FJ. Czysz, and W.W. Williams.
. Kenny cc: Mr. J.
R. White R.
G, Byram H.
G.
Stanley G.
T.
Jones C.
J.
Kuczynskl C.
D.
Miller D.
F.
Mcaann R.
R.
Wehry M. W. Simpson D,
P.
Parsons F.
J.
Czysz D.
J.
Kohn S.
F.
Davis W. W. Williams NR Files (File R41-2)
(NRC)
TW-16 SSES A6-2 SSES A6-2 SSES SSES A1-2 A1-2 A6-3 A6-3 SSES A2<
A6-2