ML17156B600
| ML17156B600 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 01/19/1990 |
| From: | Anderson C, Roy Mathew NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17156B599 | List: |
| References | |
| 50-387-89-35, 50-388-89-34, GL-86-10, IEIN-88-004, IEIN-88-4, NUDOCS 9002060006 | |
| Download: ML17156B600 (14) | |
See also: IR 05000387/1989035
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report
Nos.
50-387/89-35
50-388/89"34
Docket Nos.
50-387
50-388
License
Nos.
NPF-22
Licensee:
Power
& Li ht
Com an
2 North Ninth Street
Allentown
Penn s
1 vani a
18101
Facility Name:
Sus
uehanna
Units
1 and
2
Inspection At:
Berwick, Penns
lvania
Inspection
Conducted:
December
18-21
1989
Inspectors:
(~~
lC &
R.
K. Mathew,
eactor
Engineer
l-18'- 9o
date
Approved by:
C. J.
A derson,
Chief, Plant Systems
Section,
Engineering
Branch,
ate
9o
Ins ection
Summary:
Ins ection
on December
18-21
1989
Combined
Re ort Nos
~
50-387/89-35
and 50-388/89-34
Areas
Ins ected:
Special
announced- inspection to review the licensee's
actions
in response
to an allegation
made
by a contractor
employee,
regarding
Susquehanna
Steam Electric Station's
noncompliance
with 'appropriate
requirements
of penetration
fire seals.
This inspection also reviewed the status of corrective'ctions
associated
with three previous
NRC findings.
Results:
The fire allegation could not be substantiated
except for one item
where the licensee
had violated the Technical Specification Section 3.7-7
action statement
regarding fire watches for inoperable fire barriers.
The
licensee
established fire watches for the affected
area until the operability
of the seal
was established.
An
LER was issued
to the
NRC to report this
Technical Specification violation.
A non-cited violation was identified by the
NRC and is addressed
in Section 3.2, concern
3 of this report.
DETAILS
1.0
Persons
Contacted
1. 1
Penns
lvania
Power
and Li ht
Com an
E. T. Banks,
Foreman,
Electrical
and Structural
J. Blakeslee,
Assistant Superintendent
- R. G.
Byram, Superintendent
of Plant
"S.
Caskos,
Unit Coordinator
"T. Dalpiaz, Assistant
Superintendent,
Outages
S.
L. Denson,
Outage Supervisor
- S.
E. Davis, Site Fire Proctection
Engineer
J.
Ertman,
Compliance
P. J.
Engel, Installation Engineer
ED Figard, Supervisor,
Maintenance
- M. M. Golden,
Plant. Engineering
Supervisor
"T. Iorfida,
ICC Supervisor
G.
D. Miller, Resident
Engineering
Supervisor
H. Palmer,
Supervisor,
Operations
- L. D. O'eil, Assistant
Manager,
NgA OPS
"D.
F.
Roth, Senior Compliance'Engineer
"J.
E. O'ullivan, Supervisor,
IEG
1.2
Brand Industrial Services
Inc.
J.
E.
Newsome,
Project Manager
K. A. Graham,
Engineer
T. A. Evina, Supervisor,
gC
1.3
U.S. Nuclear
Re viator
Commission
"S. Barber,
Senior Resident
Inspector
J. Stair,
Resident
Inspector
- Denotes those
present
at the exit meeting.
2.0
Follow-u
of Previous
Ins ection Findin
s
Closed
Unresolved
Items
50-387/89-09-02
and 50-388/89-09-02
Inade
uate fire drills
The
NRC identified two concerns
in the fire brigade training during the
previous Fire Protection/Prevention
inspection (89-09).
The first concern
deals with members of the security fire brigade
not being required to
participate'n
at least
two fire drills per year
as operations
personnel.
The brigade is composed of five persons;
three
from the operations
depart-
ment
and
two from security.
The licensee
stated that the nuclear training department
reviewed the
training records of security staff for the last five years
and concluded
that each security fire brigade
person
has participated
in at least
one
drill per year.
The inspector
reviewed licensee's
FSAR, Revision
35 commitments
and noted
the following:
l.
Each individual from the operations
organization
assigned
to the
fire brigade shall participate
in at least
2 drills per year.
2.
Individuals from the security organization
assigned fire brigade-
duty at the time of drill shall participate
in the drill.
Other
security personnel
shall
be provided with a post drill br'iefing.
The inspector verified the training records for 1989
and concluded that
the licensee
is providing fire drills and post drill briefing as committed
in the
FSAR.
The inspector also
noted that the licensee's
approved fire
protection review report
and .fire brigade training procedures
AD-gA-145
and NTP-gA-53. I are consistent with the
FSAR commitments.
ff
The second
concern
was regarding
the fire brigade drills being conducted
without the
use of full fire fighting gear.'he
licensee
agreed with the
'inspector'
concern
and decided
to conduct the drills with the full fire
fighting gear.
The inspector
could not witness
any drills during the
inspection.
However,
the inspector
interviewed the fire brigade
members
and concluded that the drills are being conducted with all the required
fire fighting gear.
The inspector
had
no further questions.
This item is closed.
Closed
Violation
50-387/88-18-03
and 50-388/88-21-03
Purchased
emer
enc
diesel
enerator
fuel does not conform to the
rocurement
documents
This violation pertains
to the failure of the licensee
to establish
procedures
which provide objective evidence that the purchased
No.
2
emergency
diesel
generator
fuel oil conforms to the
ASTM specifications
as
specified
by the procurement
documents.
The inspector
noted that the licensee
has revised
purchase
order no.
C-2-387
dated
March 1,
1989 to include the requirement for the independent
inspection
and testing of No.
2 diesel
fuel oil to meet the
ASTM D-975 specification.
The licensee
also
has
issued
a service contract order to
SGS Control Services,
Inc. for'he testing
and certification of No.
2 diesel
fuel to ASTM D-975
standards.
This testing
includes verification of fuel oil properties
such
as flash point, cloud point, water
and sediment,
carbon residue,
ash,
distillation, viscosity,
sulphur, corrosion
and cetane
number.
The licensee
stated that they conduct surveillance
sampling
and testing for viscosity,
water and sediment,
insolubles
and oxidation stability every
92 days in
accordance
with the Technical Specifications
and the
ASTM D-2274 require-
ments.
The inspector verified the test data for the last quarter
and
no
unacceptable
conditions were noted.
ei
The inspector
concluded that the licensee
has established
an adequate
method to establish
the receipt of emergency diesel
generator
fuel oil
with the evidence of. testing for the type and quality of fuel furnished
for all of the foregoing attributes of the
ASTH specifications.
This item is closed.
U dated
Unresolved
Item
50-387/89-09-01
and 50-388/89-09-01
inade
uate
C02
s
stems
acce
tance test:
The
NRC determined that the licensee
did not adequately test
C02 .systems
to determine
whether the systems
function as designed.
The design of the
C02 systems for Technical Specification related
areas
is based
on achieving
a 50;.'oncentration
for each area.
The licensee
has not established
the
C02 system acceptability of the
installation in accordance
with NFPA 12,
1977 Section 1-7.3 and
commitments'
meeting
was held
on October
25,
1989 with NRC staff to discuss this
unresolved
item.
The licensee
discussed
the utilization of a fan test
as
an alternative to full discharge testing of plant automatic
C02 systems.
During the discussions
the
NRC staff stated that they would evaluate
the
test results
and the acceptability of this alternate
methodology.
During the inspection,
the inspector
noted that the licensee is maintaining
hourly fire watches
in the affected areas.
The licensee
stated that the
C02 fan test procedure
was developed
and testing will be completed before the
end of January,
1990.
The completed
test report will be reviewed
by nuclear plant engineering
and then submitted
to the
NRC for review.
This item remains
open
pending the final review
and acceptance
of either
a full functional test or an alternative to full
discharge testing of plant automatic
C02 systems
covered
by technical
specifications.
3.0
Alle ation Follow-u
As part of the
NRC's function to assure
that the issues
raised
by allegations
are adequately
investigated
and resolved,
the inspector
reviewed the
allegations
described
below.
3.1
~Back round
On May 11,
1989,
the
NRC received
an allegation
from one of the
contractor
employees
(Brand Industrial Services
Co.
(BISCO) of
Power
and Light Company at Susquehanna
Steam Electric
Station,
regarding
several
concerns
with noncompliance
of fire
protection penetration
seal installation.
On May 15,
1989, the
alleger contacted
the licensee's
site fire protection engineer
and
expressed
several
concerns
regarding
Susquehanna
Steam Electric
Station's
(SSES)
compliance with appropriate
requirements
for pene-
tration seals.
These
concerns
were documented
on the licensee's
Significant Operating
Occurrence
Report
No. 1-89-184.
3.2
Alle ation
Review and Resolution
This section
includes
a review and discussion
of each of the allegations.
Concern
1
Appendix
R 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire seals,
conduit seals
should
be sealed
5 feet
either side of the barrier.
The control structure is not sealed
properly.
No gA/gC coverage
was provided during the installation of
conduit seals
in the control structure.
Discussion
A Deviation Request
No.
20 from section III.G.2 of Appendix
R was
requested
by the licensee
well before the allegation to the extent
that conduits will be provided with an internal non-combustible
seal
on one side at the first accessible
opening to maintain fire barrier
integri ty.
Generic Letter 86-10 states
that "openings inside conduits larger
than
4 inches
i'n diameter
should
be sealed at the fire barrier
Openings
inside conduits
4 inches or less in diameter
should
be sealed
on each
side of the fire barrier
and sealed either
at both ends or at the fire barrier with non-combustible material to
prevent the
passage
of smoke
and hot gas
~ "-
The identified conduit sealing
methodology differs from NRC staff
guidance
provided in Generic Letter 86-10,
since only one
seal
is
being provided rather than
a seal
on each
side
as stated
in
NRC
guidance.
However,
many of the conduits at the plant terminate in
closed junction boxes
on one or both sides.
Recent tests
have deter-
mined that this would provide equivalent protection to
a rated seal.
The
NRC staff reviewed the
SSES conduit sealing
program identified in
Deviation Request
No.
20 and concluded that it provides
reasonable
assurance
that redundant trains of shutdown
components
would not be
affected
by fire or smoke
and hot gases
traveling through conduits
and approved
the deviation.
The inspector
reviewed the licensee's
installation work package
87-3028B
and specification
C-1027,
design
and installation of penetration
seals
to determine
the requirements
for the design
and installation of wall
seals.
The inspector
noted that for each installation,
the licensee
prepares
a conduit seal
review sheet to evaluate
the
conduit seal
against flood, pressure
and radiation
streaming require-
ments.
If these conditions exist,
then the conduit seals
are installed
as
3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire seals with a minimum of 9 inches fire rated
seals
in accordance
with licensee
specification
C-1027.
If the seal
requirements
are less stringent
such
as prevention of hot gas
and
smoke
from a fire, air and or radiation,
then the seals
are installed
as
non rated fire seals with non-combustible
sealant
as
shown
on the
approved deviation
No.
20 to the fire protection review report and
specification
C-1027.
Since they are not fire rated,
they are not
required to undergo testing
or
QA/QC review.
The
QA/QC requirements
and hold points are discussed
for fire rated penetration
seals
and
conduit seals.
The installation
package
87-3028B verified by the
inspector
met these
requirements.
Furthermore,
the licensee
has
a
program to conduct
QA audits of the fire protection
program in
accordance
with the Technical Specification, Sections 6.5.2.8.h,
i
and j.
The inspector
noted that the fire barrier seals installation
agrees
with the
BISCO typical installation
and penetration details
drawings.
The drawings
reviewed are identified in Attachment
A of
this report.
The inspector
concluded that the licensee's
installation of conduit
seals
and penetration
seals
meet the Generic Letter 86-10 criteria,
the approved fire protection review report and the licensee's
installation specifications.
The allegation is not substantiated.
Concern
2
Stairwells
should
be
3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating.
They are not
3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire
rated in SSES.
Discussion
Branch Technical
Position Guideline Table 5.0-1 Item f as discussed
in the approved
Fire Protection
Review Report states that stairwells
should
be designed
to minimize
smoke infiltration during
a fire.
Stairwell, elevator
and chutes
should
be enclosed
in masonry towers
with a minimum fire rating of three
hours
and automatic fire doors at
least
equal
to the enclosure
construction.
Where stairwells or
elevators
cannot
be enclosed
in three-hour fire rated barrier with
equivalent fire doors,
escape
and access
routes
should
be established
by pre-fire plan and practiced in drills by fire brigade training.
In SSES,
the stairways
are clearly marked
and are enclosed
in two-hour
shafts which is the standard
industry construction.
The licensee
has
established
escape
and access
routes
by pre-fire
plan
and are practiced
in various fire drills.
These stairwells are not ventilated
by the
HVAC system.
They are provided with fire doors which are normally
closed which minimizes
smoke infiltration.
The inspector
reviewed
the licensee's
calculations
DK-C-DJK-013 and DK-C-JAD-099 showing
justification of al 1 the exi sting fire boundaries.
The
-1 icensee
'
calculation
shows that stairwells
have
no appreciable
combustible
fire loading items
and they are not in the safe
shutdown path.
A single fire on one rated fire area will not propagate
through the
stairwell fire areas,
since the existing floor-to-floor separation
provides
a three hour fire rating and it has to penetrate
twice
through the two hour rated fire wall.
The inspector
concluded that the licensee
has adequately
documented
compliance for the fire rating of stairwell in the fire protection
review report.
This was reviewed
by the
NRC.
f
The allegation is not substantiated.
Concern
3
The control structure requires
a continuous fire watch at the
656'evel.
No fire watches
were established
for penetration
seals
which
were identified as being
damaged.
Power
and Light
Company/Installation
Engineering
Group
(PPE L/IEG) knows these
problems.
Discussion
As part of the Appendix
R project, all fire rated barriers in the
control structure
were inspected
by the contractor
(BISCO) to verify
the status of the penetration
seals
and to identify those which had
to be upgraded to meet the
new sealing
requi rements.
These
inspections
also identified the damaged
seals.
The licensee
documented
these
items
in Work Authorizations (WA's) and forwarded the Work Authorizations to
plant maintenance
group.
A sampling of these
reported
damaged
seals
were inspected
by the
maintenance
supervision.
The licensee
concluded that the
damage
was
only cosmetic or superficial
based
on the surveillance
inspection
criteria.
On Hay 15,
1989,
a contractor
employee
expressed
a concern
regarding
the operability of these
seals
to the licensee's
Site Fire
Protection
Engineer.
The licensee
was receptive to the alleger's
concerns
and conservatively established fire watches
on May 19,
1989
for all areas
of the control structure with fire rated penetration
seals identified as
damaged until further investigation of the issue
was completed.
Subsequent
in'vestigation confirmed that the operability
of at least
some of the identified penetration
seals
was affected
and
consequently,
all of the affected
seals
were
assumed
to be inoperable.
Based
on this determination,
the licensee
should
have declared
these
seals
as inoperable
when it was initially identified as
damaged
and
appropriate
LCO should
have
been entered
and action statement
should
have
been
implemented.
On May 26,
1989,
the licensee
reported this
event to the
NRC for not meeting the required action statement
of
,Technical Specification 3.7.7 regarding fire rated assemblies.
Failure to establish
adequate fire watches
in accordance
with Techni-
cal Specification,
Section 3.7.7 action statement
is
a violation of
the Technical Specification.
(50-287/89-35-01
and 50-288/89-34-01)
This violation is not cited
on the following bases:
1) The violation
was identified by the licensee,
2) The violation would be Severity
Level
IV or V, if cited,
3) The deficiency was adequately
reported in
LER 89-019-00,
4) Corrective actions
were taken,
and 5) The violation
was not willful or reasonably
preventable
by previous actions.
'The licensee
determined that the root cause
of the event
was the
failure to identify the significance of the penetration
seal
damage
on the operabil'ity of the penetrations.
The contributing factors
were the
use of different surveillance criteria than those
used
by
BISCo to identify damage
and
a sampling of penetration
seal
damage
indicated the problems
were minor.
The inspector
noted that the licensee
had repaired
approximately
250
seals
to meet the existing installation details
and the
remaining
50 are under repair.
During '.he field walkdown, the inspector
verified the
seal
repairs for penetration
assemblies
12-7-54,
12-7-D2,
12-7-40
and interviewed three
BISCo installation personnel.
The
inspector also verified the fire watch log at control
room and confirmed
that the fire watch is still in effect for the penetration
assemblies
that are still damaged.
Licensee's
actions to prevent recurrence
of these
events
were:
( 1) when
a work order describing penetration
damage
is issued,
the
appropriate fire watch will,be established;
(2) specification
C-1072,
the inspection of fire barriers for compliance with SSES Technical
Specification
was revised to include the inspection
acceptance
and
operability determination (criteria for fire barriers at
as
required
by Technical Specification 3/4.7.7);
and (3) surveillance
procedures
AD-QA-906, SM-013-010,
113-010
and 213-010 were issued to
give standard
acceptance
criteria consistent with the BISCo instal-
lation inspection guidelines
and also to provide standard criteria
for the operability determinations.
The licensee
stated that additional
new procedures
AD-QA-902 and
AD-QA-905 are
scheduled
to be issued before
February
1990 to improve
and to minimize seal
repairs.
The
licensee is planning to incorporate
a computerized
seal
data
base
to
trend
seal failure for effective corrective actions
The inspector concluded that the alleger's
concern
was valid and the
licensee's
corrective, actions
and actions to prevent recurrence
is
addressed
adequately.
Based
on the licensee's
prompt corrective
action
and reporting of this event to the
NRC under
LER 89-019-00
and
the subsequent
NRC review, this issue is considered
closed.
Concern
4
Installed penetration
seals
do not represent
tested-conditions.
Discussions
This subject is already identified through
"Inadequate Qualification and Documentation of Fire Barrier
Seals".
During the review, the inspector
noted that the
licensee
QA audit 88-099,
had
an audit finding, deficiency report
No.88-003, citing the penetration
sealing contractor,
BISCO.
This
'udit deficiency report was for not performing
a performance verifica-
tion check for all vendor designs to assure that the deviations
do
not exist between the, tested
and installed configuration in accordance
with licensee
specification
C-1027,
Revision 4, guidelines of Generic Letter 86-10
In order to rectify the deficiency,
BISCO has revised its typical
details to include design limitations and parameters
on each typical
detail.
These
revised typical details
have
been
submitted to PPKL
and are presently
going through t.',e completion of approval
and
review process.
A qualified fire protection engineer
was assigned
to perform
a sample analysis of approximately
800 penetration
seals
(including Tech Spec related fire seals)
to verify the as-built
configuration
compared
to the
new updated
BISCo typical design
criteria.
The data is documented
in a Performance
Verification
Check Sheet.
The data
was submitted to Engineering for evaluation.
The licensee
is planning to complete this analysis
before the end of
January
1990.
I
The 'inspector
concluded that the licensee
had promptly addressed
this deficiency in their
QA audit before the allegation
and is being
tracked
by PPKL under the Industry Event Review Program
( IERP),
items88-051
and 88-210.
There is no immediate safety concern for
the operability of the seals
due to the fact that it meets
al,l of the
initial installation criteria to establish
a
3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating
and
the
new inspection criteria is an enhancement
to the existing instal-
lation.
During the field walkdown, the inspector
noted that the
minimum 9 inch thickness for the fire rated seals
are fully imple-
mented for 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated penetration
seals.
This allegation
issue is closed.
The inspector toured accessible
vital and non-vital plant areas
and
examined fire detection
and alarm systems,
automatic
and manual fixed
suppression
systems,
interior hose stations, fire barrier penetration
seals,
and fire doors.
The inspector
observed
general
plant housekeeping
'
10
conditions
and randomly checked
tags of portable extinguishers
for evidence
of periodic inspections.
No deterioration of equipment
was noted.
The
inspection
tags attached
to extinguishers
indicated that monthly inspections
were performed.
No deficiencies
were identified.
5.0
Exit Interview
The inspector
met with licensee
management
representatives
(see
section
1.0
for attendees)
at the conclusion of the inspection
on December
21,
1989.
The inspector
summarized
the
scope
and findings of. the inspection -at that
time.
The inspector
also confirmed with the licensee
that the report will
not contain
any proprietary information.
The licensee
agreed that the
inspection report
may be placed in the Public Document
Room without prior
licensee
review for proprietary information ( 10 CFR 2.790).
At no time during this insp ction,
was written material
provided to the
licensee
by the inspector.
'i
ATTACHMENT A
LIST OF
DOCUMENTS REVIBIED
Specification
No. C-1027
Design
and Installation of Penetration
Seals
,Licensee
Event Report
No
~ 89-019-00
Specification
C-1072 - The inspection of fire barrier s for compliance with
SSES technical
specifications.
SM-213-010,
Revision
3 - 18 month inspection of Unit 2 penetration
seals
SM-013-010,
Revision
0 -
18 month inspection of common penetration
seals
SM-113-010,
Revision
3 - 18 month inspection of Unit
seals
AD-QA-906, Revision
0 - Fire rated penetration
seal
surveillance
program
NDI-QA-15.3. 1, Revision
3 - Fire protection
program
NTP-QA-53. 1, Revision
4 - 'Susquehanna
fire safety training system
AD-QA-145, Revision
3 - Fire brigade
AD-QA-110, Revision
4
Station fire protection
program
= AD-QA-141, Revision
3 - Fire protection
system status
control
Drawing No.
107 - Typical installation drawing for cable through 3-hour rated
Drawing Nos.
144,
145,
146
Typical installation drawing for pipe, conduit
and/or cable tray through
3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated walls
Drawing No.
105
Typical installation drawing for cables
through sleeve
or
core drill in wall
Drawing No.
5 - Cable tray through fire barrier
Drawing No.
6 - Sleeve with cables
through
3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier
Drawing No. X-12-6, Sheets
1,
2 and
3 - Penetrations,
Central
Control
Building, Area
12, plan of elevation 753'0"