IR 05000387/1992033

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Forwards Fire Protection Safety Insp Repts 50-387/92-33 & 50-388/92-23 on 920824-1009.Violations Noted Re Inadequate Implementation of Fire Protection Program QA Requirement & Failure to Perform Insps of Kaewoll Fire Barrier Cable
ML17157C098
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 12/04/1992
From: Hodges M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Keiser H
PENNSYLVANIA POWER & LIGHT CO.
Shared Package
ML17157C099 List:
References
EA-92-234, NUDOCS 9212090231
Download: ML17157C098 (7)


Text

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ESSION NBR:9212090231 DOC.DATE: 92/12/04 NOTARIZED: NO DOCKET CIL:50-387 Susquehanna Steam Electric Station, Unit 1, Pennsylva 05000387 50-388 Susquehanna Steam Electric Station, Unit 2, Pennsylva 05000388 AUTH.NAME AUTHOR AFFILIATION HODGES,M.W.

Region 1 (Post 820201)

... RECIP.NAME RECIPIENT AFFILIATION KEISERgH W

Pennsylvania Power 6 Light Co.

SUBJECT:

Forwards insp rept 50-387/92-23 6 50-388/92-23 on 920824-921009.No violations noted.

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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:Maxwell,G Maxwell,G RECIPIENT ID CODE/NAME PD1-2 PD INTERNAL: ACRS AEOD/DEIB AEOD/TTC NRR MORISSEAUgD NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/PMAS/ILRB12

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PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LIPID FOR DOCUMENTS YOU DON'T NEED!

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Docket Nos.

50-387 50-388 EA No.92-234 otic

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Mr. Harold Senior Uice President - Nuclear Pennsylvania Power k, Light Company 2 North Ninth Street Allentown, Pennsylvania 18101

Dear Mr. Keiser:

SUBJECT:

INSPECTION REPORT NOS. 50-387/92-23; 50-388/92-23 This letter refers to the announced special fire protection safety inspection led by Mr. F. Bower of this office from August 24 to October 9, 1992.

This inspection was conducted as a result of information identified by an NRC Office of the Inspector General (OIG) investigation that raised questions concerning the qualification and adequacy of the Thermo-Lag fire barriers installed at Susquehanna Steam Electric Station Unit 1 to support licensing of the plant.

Therefore, the inspection included a review of activities authorized for the Susquehanna Steam Electric Station (SSES) at Berwick, Pennsylvania.

The initial inspection was conducted at Susquehanna from August 24 to September 4, 1992. At the conclusion of the initial inspection on September 4, 1992, Mr. Bower discussed the inspectors'indings with those members of your staff identified in the enclosed report.

Additional information was obtained from members of your staff during a meeting held on September 22, 1992, at PAL's Allentown, Pennsylvania, offices and from a meeting held with a former NRC employee on October 7, 1992, at the NRC offices in Rockville, Maryland.

Inspection activities continued in the Region I offices until October 9, 1992. At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed report.

Areas important to public health and safety that were examined during the inspection are identified in the report.

Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel and observations by the inspectors.

The focus of this inspection was to address questions that had been raised concerning the adequacy and qualification of Thermo-Lag fire barriers installed in SSES Unit 1 to support licensing of the plant.

Considerable attention was devoted to understanding the licensing basis for the Thermo-Lag materials used at SSES Unit 1 and the related OFFICIALRECORD COPY G:38792-23 OOOO>>

9212090231 921204 PDR ADOCK 0500038'

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communications between the PAL and NRC staffs.

The quality of these Thermo-Lag barriers and other fire barrier materials was assessed.

The inspection findings are described in detail in the attached report.

No violations were identified in this area.

Based on the results of this inspection, four apparent violations were identified and are being considered for escalated enforcement action in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), 10 CFR Part 2, Appendix C (1992).

We are concerned that each of these violations could be attributed to the inadequate application of quality and lack of management oversight which allowed these violations to occur undetected over a considerable period of time.

The first violation concerns the inadequate implementation of the fire protection program quality assurance requirement to have field personnel verify that fire protection installations were installed in accordance with design specifications.

The second violation concerns the failure to perform Technical Specification required surveillance inspections on Kaowool fire barrier cable raceway wrap systems since their installation over ten years ago.

The third violation concerns the failure to follow procedures to apply adequate quality measures to fire protection program design drawings.

The fourth violation concerns the finding that contrary to License Conditions 2.C(6) and (7) and the fire protection program, Kaowool fire barrier material had been installed in an area that was not protected by automatic fire suppression and where Kaowool had not been specifically approved for use.

Accordingly, no Notice of Violation is presently being issued for these inspection findings. In addition, please be advised that the number and characterization of apparent violations described in the enclosed inspection report may change as a result of further NRC review.

An enforcement conference to discuss these apparent violations willbe scheduled for the week of January 4, 1993.

A specific date willbe set shortly after your receipt of this letter.

The purposes of this conference are to discuss the apparent violations, their causes and safety significance; to provide you the opportunity to point out any errors in our inspection report; to provide an opportunity for you to present your proposed corrective action(s); and to discuss any other information that willhelp us determine the appropriate enforcement action in accordance with the Enforcement Policy. In particular, we expect you to address the corrective action that you plan to take to address the programmatic issues identified.

Since the qualification of Thermo-Lag has been called into question by recent NRC generic communications, it is not expected that your corrective actions to address fire barrier wrap deficiencies are fully developed.

However, it is requested that you plan to address corrective actions associated with fire barrier wrap deficiencies including one of the unresolved items identified by the report that concerned the use of a Thermo-Lag configuration, on Unit 1 OFFICIALRECORD COPY G:38792-23

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Mr. Harold cable trays, which had been found unacceptable for use on cable trays in Pire Zones 1-2D, 0-28B and 0-28H in Unit 1. You willbe advised by separate correspondence of the results of our deliberations on these matters.

No response regarding these apparent violations is required at this time.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure willbe placed in the NRC Public Document Room.

Sincerely, Marvin W. Hodges, Director Division of Reactor Safety Enclosures:

1.

Appendix A, Notice of Violation 2.

NRC Region I Inspection Report Nos. 50-387/92-23; 50-388/92-23 cc w/encls:

J. M. Kenny, Nuclear Licensing H. G. Stanley, Superintendent of Plant-SSES R. G. Byram, Vice President, Nuclear Operations M. M. Urioste, Nuclear Services Manager R. M. Peal, 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)

NRC Resident Inspector Commonwealth of Pennsylvania OFFICIALRECORD COPY G:38792-23

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Region I Docket Room (with concurrences)

M. Thadani, NRR L. Bettenhausen, DRS E. Wenzinger, DRP J. White, DRP DRS/EB SALP Coordinator J. Trapp, DRS J. Noggle, DRSS V. McCree, OEDO J. Raleigh, NRR, Project Manager P. Madden, NRR G. Kenna, OI G. Mulley, OIG N. Blumberg, DRS F. Bower, DRS R. Mathew, DRS DRS Files (2)

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