IR 05000397/1994008
| ML17290B019 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/25/1994 |
| From: | Ang W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17290B018 | List: |
| References | |
| 50-397-94-08, 50-397-94-8, NUDOCS 9403160022 | |
| Download: ML17290B019 (15) | |
Text
U.S.
NUCLEAR REGULATORY COMHISSION REGION V
~Re ort No Docket No.:
License No.:
Licensee:
50-397/94-08 50-397 NPF-21 Washington Public Poqer Supply System (WPPSS)
Washington Nuclear Plant, Unit 2 Benton County, Washington Ins ection Conducted:
January 31 through February 4,
1994
~Ios ector:
D. Acker, Reactor Inspector A~db ng, ie
,
ngsneering rane Ins ection Summar
Ins ection durin the eriod of Januar 31 tHrou h Februar
1994 Re ort Areas Ins ected:
During this routine announced inspection the inspector reviewed the design basis testing for fire barrier penetration seals, quality assurance activities and previously identified items.
Inspection Procedures 64704, "Fire Protection/Prevention Program;"
92701,
"Followup;" and 92702,
"Followup of Enforcement Items;" were used for this inspection.
Safet Issues Hang ement S stem SIHS Item:
None.
9403i60022 94030i PDR ADQCK 05000397
Results:
General Conclusions and S ecific Findin s:
The licensee determined that their fire barrier penetration seal inspection procedure did not provide adequate acceptance criteria for seal edge gaps and seal integrity.
Consequently, the adequacy of fire barrier penetration seal inspections, performed each outage, and the adequacy of a type of fire barrier penetration seal (BISCO SF-20)
was also suspect.
The licensee did not have test records to demonstrate the, design basis qualification for some of the installed fire.barrier penetration seals.
The licensee had initiated action to review the adequacy of their fire barrier penetration seals.
Si nificant Safet Matters:
None.
Summar of'iolation or Deviations:
None.
0 en Items Summar
Two inspector followup items and three enForcement items were closed.
One inspector followup item was opened in Section 2 of this repor DETAILS Persons Contacted Washin ton Public Power Su
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- S Baker, Manager, Technical Training Benjamin, Manager, guality Assessments Coleman, Acting Manager, Regulatory Programs Davidson, Manager, equality Assurance Flasch, Director of Engineering Foley, Licensing Engineer Graham, Health, Safety and Senior Fire Protection Specialist Hancock, Shift Manager Helton, Plant Technical Engineer Hugo, Licensing Engineer Kook, Jr., Manager, Project Licensing Mann, Assistant Manager, Operations Hauws, Supervisor, Plant Technical Heade, Manager, Technical Programs Huth, Manager, Plant Assessments Parrish, Assistant Managing Director Pisarcik, Licensing Aide Seidl, Acting Supervisor, Reliability Centered Maintenance Shaeffer, Manager, Operations Swailes, Plant Manager Walker, Manager, Health, Safety and Fire Protection Washington, Manager, Nuclear Safety Engineering US Nuclear Re ulator Commission
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- D Barr, Senior Resident Inspector Corporandy, Project Engineer
- Denotes those attending the exit meeting on February 4, 1994 The the inspector also held discussions with other licensee personnel during course of the inspection.
Fire Protection Penetration Seals 64704
'a ~
Back round The licensee's Updated Final Safety Assessment Report (UFSAR),
Section F.5.7, required an inspedtion of 10K of accessible Essential Fire Rated Assemblies each outage.
The licensee defined Essential Assemblies as those assemblies which separated redundant post fire safe shutdown systems.
N The licensee installed and maintained fire barrier penetration seals in accordance with Plant Procedures Manual (PPH) 15.4.5, Revision 1, "Penetration Fire Seal Maintenance and Inspection."
The licensee performed inspections of fire barrier penetration
- seals in accordance with PPH 15.4.6, Revision 3, "Fire Rated Assembly/Inspection and Operational Verification."
Prior to this NRC inspection, licensee personnel had questioned the adequacy of PPH 15.4.6 for the performance of UFSAR, Section F.5.7 inspections of Dow Corning.3-6548 (BISCO SF-20) fire barrier penetration seals.
BISCO SF-20 material was a light foam which tended to separate from seal surfaces resulting in small gaps at the edge of seals.
In addition, only minor force was required to separate small pieces from the surface of these seals.
The issue was apparently not adequately pursued by the licensee, as documented in NRC inspection 50-397/93-51.
Licensee management subsequently reviewed PPHs 15.4.5 and 15.4.6 and determined that they were inadequate to address potential fire barrier penetration seal deficiencies.
The licensee stated that these procedures did not adequately record or provide acceptance criteria for seal edge gaps and small missing pieces.
The licensee suspended PPHs 15.4.5 and 15.4.6 until new procedures could be developed.
The licensee developed a special procedure to inspect BISCO SF-20 seals and establish the acceptability of the installations.
The licensee selected a sample of penetrations to inspect and issued Work Order (WO)
EP94, Task 1, to do the inspections.
The inspector reviewed licensee actions to inspect BISCO SF-20 penetration seals.
The inspector reviewed Work Order EP94, witnessed licensee inspections, and independently inspected fire barrier penetration seals.
In addition, the inspector reviewed the technical basis for the 10 CFR, Part 50, Appendix R, fire barrier penetration seals at WNP2.
Licensee Ins ection of BISCO SF-20 Penetration Fire Seals
'he inspector observed the performance of WO EP94, Task l.
Licensee personnel performing the inspections appeared to be knowledgeable of the procedural inspection requirements, and the procedure required recording sufficient information to allow for proper analysis.
The licensee stated that further inspections would be performed based on the initial sample.
Since the licensee's inspections were just getting started, the inspector considered that there was insufficient data to draw any conclusions as to the extent of the problems with past licensee inspections of BISCO SF-20 penetration seals and the adequacy of the seals.
Walkdown of Penetration Fire Seals The inspector independently visually inspected fire barrier penetration seals throughout the plant to assess the general condition of the seals.
The inspector determined that many BISCO
f SF-20 penetration seals had small shallow gaps at the seal edges and a number of the seals had small pieces missing from the surface of the seals.
In addition, the inspector observed that some cable tray fire barrier seals had been installed with minimal separation between cables resulting in the potential for inadequate seal material between the cables.
The inspector did not find any missing or obviously impaired seals.
The inspector determined that BISCO SF-20 was the predominant material used for fire barrier penetration seals at the plant.
The inspector visually inspected fire barrier penetration seals filled with other qualified materials and did not identify any
'problems.
The inspector discussed the results of his walkdown with licensee personnel.
The licensee stated that the inspector's observations were consistent with their findings and that Work Order EP94, Task 1, data would be used to quantify the problems and develop solutions.
The inspector concluded that the licensee was aware of the potential problems with BISCO SF-20 penetration seals and was pursuing resolution.
The licensee further stated that they intended to keep NRC management personnel appraised of their progress in resolving fire barrier penetration seal problems.
Desi n Basis Testin The licensee based acceptability of the design of 10 CFR 50, Appendix R, fire barrier penetration seals on fire tests of similar configurations.
The inspector selected several of the licensee's approved seal designs and reviewed the fire tests the licensee used to qualify the designs.
v Construction Technology Laboratories performed the fire tests reviewed by the inspector.
The test reports stated that the tests were performed using the methods of American Society of Testing and Materials (ASTM) E-119,
"Standard Methods of Fire Tests of Building Construction and Materials," including a hose stream test.
The licensee's UFSAR, pages F.3-49 and F.3-58, stated that penetration seals complied with E-119 in response to Branch Technical Position APCSB 9.5-1, items D. 1.(j) and D.3.(d).
The inspector found two potential problems with the licensee's penetration seal designs and their associated qualification tests.
(1)
Penetration Size The inspector determined that the licensee's approved penetration seal installation drawings did not include a
maximum penetration size.
In addition, for cable tray type penetrations, the installation drawings did not specify the maximum number or sizes of cables.
During walkdowns the inspector found penetrations which were larger than the penetration used in the qualification tests.
The inspector considered that penetration size was an important criteria for qualification testing.
Sealing materials, such as BISCO SF-20, do not provide much structural support and rely on the barriers (walls) to hold the seals in place..
Therefore, larger openings are more likely to fail, due to stresses on the unsupported sealing material.
In addition, penetrations with a large number of cables and cable trays are more likely to conduct heat through the fire barrier and distort under fire loading, causing barrier failure.
The inspector discussed the adequacy of the fire tests with the licensee.
The inspector requested that the licensee provide the basis for determining that fire tests of penetration seals demonstrated the adequacy of penetration seals larger than those tested.
The licensee stated that they considered that their existing design basis was not adequate with respect to penetration size.
The licensee also stated that they were aware of additional fire tests, which they considered would validate the qualification of the penetration sizes used in the plant.
The licensee noted that they had hired an industry expert to review their entire fire barrier penetration seal design basis.
The licensee stated that they would develop an adequate design basis for the installed fire barrier penetration seals through obtaining additional test data, performing additional analyses, or performing new tests.
Licensee action to establish the adequacy of the installed fire barrier penetration seals will be inspected during future inspections (Unresolved Item 50-397/94-08-01).
Dammin Material The inspector noted that licensee fire barrier penetration sealing drawings and instructions allowed smaller seal thicknesses if damming material was left installed.
PPH 15.4.5 allowed four different types of damming material to be left installed.
The inspector determined that the licensee did not have records to indicate the thickness of the damming material left installed, or exactly which type of damming material was used for each fire barrier penetration.
In addition, qualification testing for seals with the damming material left installed did not always specify the thickness of the
damming material used.
Furthermore, not all of the licensee's approved damming material was tested.
The inspector discussed with the licensee the adequacy of the testing performed to demonstrate the qualification of dammed penetration seals.
The licensee stated that they considered that their design basis was not adequate with respect to damming material left in place.
As noted in Section 2.c, the licensee stated that they had just contracted with an industry expert, to review their entire penetration seal design basis.
The licensee stated that they would develop
'an adequate design basis for the dammed fire barrier penetration seals through obtaining additional test data, performing additional analysis, or performing new tests.
Licensee action to establish the adequacy of the installed fire barrier penetration seals will be inspected during future inspections (Unresolved Item 50-397/94-08-01).
e.
Conclusion - Fire Barrier Seals Subsequent to this NRC inspection, the licensee issued Problem Evaluation Request 294-0101 to document problems found with fire barrier penetration seals.
In addition to the problems listed in this report, the licensee inspections determined that their records did not match the installation for a sufficient number of seals to create doubt as to the accuracy of the design records.
On February 15, 1994, the licensee issued a
CFR 50.72 report, declaring their fire barrier penetration seals inoperable until an adequate design basis could be established and the installed seals could be verified to be installed in accordance with licensee records.
As a compensatory measure, the licensee reported that
'hey would perform additional fire watches.
The inspector concluded that significant licensee action was necessary to resolve the adequacy of installed BISCO SF-20 fire barrier penetration seals including the design basis testing, seal installation and inspection.
The inspector also concluded that actions the licensee stated they planned to take appeared directed at resolving these problems.
Further NRC followup inspection of licensee corective actions is warranted.
No violations or deviations of NRC requirements were identifie lg 3.
~F11
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Closed Followu Item 50-397 92-01-04:
Emer enc Diesel Generator Room and Diesel Generator Electrical E ui ment Room Tem eratures Ori inal NRC 0 en Item The Electrical Distribution System Functional Inspection (EDSFI)
team determined that calculations that determined maximum allowable room temperatures for the emergency diesel generator (EDG) room and diesel generator dlectrical equipment room were non-conservative.
The team determined that the calculations did not use the heat input from a fully loaded EDG, did not consider the heat input from the EDG room into the diesel generator electrical equipment room, and did not consider the heat input from large dropping resistors located in the electrical equipment room.
The team noted associated errors in the UFSAR.
The team was unable to conclude that the licensee had determined the most limiting room temperatures.
Licensee's Actions in Res onse to the 0 en Item The licensee performed new EDG and diesel generator electrical equipment room maximum temperature calculations and updated the UFSAR.
NRC Followu Ins ections NRC inspection report 50-397/93-16 reviewed the licensee's new temperature calculations and the licensee's temperature qualification records for selected electrical equipment.
The inspector reviewed the UFSAR, Chapters 3 and 9.
Calculation HE-02-92-43, Revision 1,
"Room Temperature Calculation for DG building, Reactor building', Radwaste building, and SW Pump-house Under Design Basis Accident Conditions," contained the licensee's room temperature calculations.
The NRC Service Water Inspection team (IR 50-397/93-201)
had reviewed the licensee's room temperature calculations, including Calculation HE-02-92-43, and had concluded that the licensee had determined the most limiting room temperatures and that maximum safety equipment temperatures were within design requirements.,
The inspector independently reviewed the licensee's temperature qualification records for selected electrical equipment and determined that the established temperature limits were technically adequate.
The inspector reviewed the UFSAR and determined that the errors noted by the EDSFI team had been adequately resolve However, the inspector noted that Calculation HE-02-92-43 assumed worst case heat exchanger cooling coil efficiency of 80%.
Licensee testing performed after completion of Calculation HE-02-92-43 determined that actual heat exchanger cooling coil efficiencies were as low as 68%.
The licensee again performed room temperature calculations using a heat exchanger cooling coil efficiency of 60% and determined that calculated worst case room temperatures were above electrical equipment temperature ratings.
Licensee's Actions After Followu Ins ection 50-397 93-33 Inspection Report 50-397/93-33 noted that the licensee planned to determine what minimum level of heat exchanger cooling coil efficiency they could maintain and the effects of this efficiency rating on existing room worst case temperature calculations.
Subsequently, the licensee established a worst case design basis for heat exchanger cooling coil efficiency as 65%.
In addition, the licensee changed their method of ventilating the rooms from total recirculation, to use of sdme outside air.
For the worst case condition, ash fall, the licensee purchased additional air filters and modified procedures to monitor and change these filters during an ash fall event.
Based on partial use of outside air the licensee again performed calculation HE-02-92-43 and concluded that maximum room air temperatures would be less than equipment ratings.
Ins ector's Actions Durin the Present Ins ection The inspector reviewed the revised calculation HE-02-92-43, ash fall condition operating procedures contained in PPH 4.12.4.5, Revision 8,
"Design Basis Ash Fallout," electrical equipment qualification records, and discussed heat exchanger monitoring with the licensee.
Discussion and Conclusions.
The licensee stated that they were monitoring heat exchanger performance to insure the efficiency would be kept above 65%.
The inspector concluded that use of outside air was technically acceptable and that the licensee procedures were adequate to preclude fouling during an ash fall event.
The inspector considered that the revised calculation and the electrical equipment qualification records were adequate to demonstrate that equipment qualification maximum temperatures would not be exceeded during design basis ash fall worst case conditions.
The licensee has adequately reviewed and resolved the EDG and EDG equipment room temperature design basis.
Therefore, this item is close b.
Closed Followu Item 50-397 92-25-04:
-Reactor Protection S stem Electrical Protection Assemblies Set oint Drift Ori inal NRC 0 en Item The NRC Test Inspection team identified that the trip points for the reactor protection system electrical protection assemblies had drifted outside the Technical Specification (TS) limits on several occasions and that the subsequent licensee analysis of the data had not identified a root cause or ensured that the surveillance cycle was adequate.
The electrical protection assemblies protected reactor protection system equipment from overvoltage, undervoltage, or underfrequency conditions.
Licensee's Actions in Res onse to the 0 en Item The licensee reviewed all the data for the electrical protection assemblies for the last four years and analyzed the data.
The l'icensee could not determine a root cause for the data noted by the Test Team.
However, the licensee noted that the data which was outside TS limits occurred in 1990 and 1991.
Subsequent data for 1991, 1992, and 1993 (four sets of data)
had all been within TS limits.
NRC Inspection Report 50-397/93-47 reviewed the licensee's progress on this item.
Ins ector's Actions Durin the Present Ins ection The inspector reviewed the data and the licensee's analysis.
Discussion and Conclusion The inspector concluded that the data did not indicate continuing equipment problems or a need to do more frequent surveillances, based on consistent data for the last four test cycles.
Despite an inability to determine a root cause, the licensee appeared to have performed a reasonable evaluation to attempt to determine the root cause.
Therefore, this item is closed.
No violations or deviations of NRC requirements were noted.
Followu of Violations and Deviations 92702
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Closed Violation 50-397 93-19-01:
Inade uate Forei n Material Control Around the Reactor Vessel Cavit Ori inal NRC Enforcement Item This item reported that the inspector found loose parts from a submarine camera within the licensee's foreign material control
area.
The inspector noted that failure to maintain foreign material control was a repeat finding.
Licensee's Actions in Res onse to the Enforcement Item In their response to the Notice of Violation, dated July 26, 1993, the licensee committed to revise their foreign material control procedure to account for the inspector's findings and additional problems they discovered during outage R8.
Ins ector's Actions Durin the Present Ins ection The inspector reviewed the licensee's revised procedure, PPM 1.3. 18, Revision 9, "Foreign Material Control Around the Spent Fuel Pool, the Reactor Cavity and the Dryer-Separator Pit."
Discussion and Conclusion The inspector concluded that the revised procedure had improved guidance.
In addition, the inspector noted that a peer group audit of the licensee's operating event review program identified a weakness in the licensee's review of industry information concerning foreign material control problems.
As part of the corrective actions for the peer audit', the licensee committed to have quality assurance personnel monitor compliance to PPH 1.3. 18 during outage R-9.
Based on an improved procedure and the licensee's commitment to monitor the effectiveness of the revised procedure during outage R-9, the inspector concluded that the licensee's actions were adequate to resolve the violation.
This violation is closed.
Closed Violation 50-397 93-25-01:
Failure to U date Maintenance Re uirements for Installed Desi n Chan es v
Ori inal NRC Enforcement Item The inspector determined that licensee personnel failed to comply with a procedur'e which required a Scheduled Maintenance System (SHS)
Data Input Sheet be prepared as part of several design changes.
Failure to submit the SHS cards resulted in a lack of maintenance instructions for safety related equipment installed as part of the design changes.
The inspector considered that an inadequate procedure contributed to the failure because the procedure called for a signature verification on a table which did not have an associated signature block.
Licensee's Actions in Res onse to the Enforcement Item The licensee, in their written response to this violation, dated September 13, 1993, committed to initiate the missing SHS Data Input Sheets, correct the associated procedure, and train associated personnel on this issu Ins ector's Actions Durin the Present Ins ection The inspector reviewed the new SMS Data Input Sheets; the revised procedure; PPM 1.4. 1, Revision 16, "Plant Modifications;" and the training performed.
Discussion and Conclusion The inspector concluded that new SMS Data Input Sheets had been correctly initiated, the procedure had been clarified, and the training was adequate to, ensure that associated personnel were informed of the problem.
The inspector noted that the procedure had also been improved in other areas noted as weak in Inspection Report 50-397/93-25.
The inspector considered that the licensee's actions were adequate to resolve this violation.
This violation is closed.
Closed Violation 50-397 93-40-Gl:
Failure to Perform Inde endent Audit of Unannounced Fire Drill Ori inal NRC 0 en Item An inspector determined that the licensee had not had an independent and qualified individual critique a randomly selected unannounced fire drill at a three year interval as required by 10 CFR, Part 50, Appendix R, and the licensee's UFSAR.
Licensee's Actions in Res onse to the Enforcement Item The licensee, in their written response to the violation, dated November 29, 1993, committed to:
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Have an independent qualified person critique an unannounced fire drill.
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Update plant procedures to clearly indicate the requirement for the independent critique.
Assign the Health, Safety, and Fire Protection Manager the responsibility for ensuring the independent critique was satisfactorily completed.
The licensee identified that the root cause of the problem was inadequate communications between organizations and failure of procedures to assign responsibility to ensure the independent critique was accomplishe Ins ector's Actions Durin the Present Ins ection The inspector reviewed the results of the independent critique of a random unannounced fire drill, accomplished on October 20, 1993, and the revised procedure, PPH 1.3. 10, Revision 14, "Fire Protection Program Implementation."
Discussion and Conclusion The inspector concluded that the procedure clearly stated the requirement for the independent critique and assigned responsibility for ensuring that the critique was performed.
The inspector concluded that the independent critique of the unannounced fire drill, conducted on October 20, 1993, met the licensee's 10 CFR, Part 50, Appendix R, commitment.
This violation is closed.
No violations or deviations from NRC requirements were noted.
5.
UNRESOLVED ITEMS n
mp Paragraph
~Ei<<i The inspector conducted an exit meeting on February 4,
1994, with members of the licensee staff as indicated in Section 1.
The inspector summarized the scope of the inspection activities and reviewed the inspection findings as described in this report.
The licensee acknowledged the concerns identified in the report.
The licensee identified that fire barrier penetration seal test reports were proprietary.
Although these test reports are discussed in this inspection report, no proprietary information is included in this inspection report.
Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of onco liance or deviations.
An unresolved item is discussed in
.d of this report.