ML17157C195
| ML17157C195 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 02/11/1993 |
| From: | Hodges M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Keiser H PENNSYLVANIA POWER & LIGHT CO. |
| Shared Package | |
| ML17157C196 | List: |
| References | |
| EA-92-234, NUDOCS 9302190045 | |
| Download: ML17157C195 (6) | |
See also: IR 05000387/1992023
Text
FORD 1
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9302190045
DOC.DATE: 93/02/11
NOTARIZED: NO
DOCKET
IL:50-387 Susquehanna
Steam Electric Station, Unit 1, Pennsylva
05000387
50-388
Susquehanna
Steam Electric Station, Unit 2, Pennsylva
05000388
UTH.NAME
AUTHOR AFFILIATION
HODGES,M.W.
Region
1 (Post
820201)
RECZP.NAME
RECIPIENT AFFILIATION
KEISERiH.W.
Power
& Light Co..
R
SUBJECT: Discusses
insp repts '50-387/92-23
& 50-388/92-23
on
920824-1009
& forwards notice of violation.
P
DISTRIBUTION CODE:
IE01D
COPIES
RECEIVED:LTR
ENCL U
SIZE:
TITLE: General
(50 Dkt)-Insp Rept/Notice of Violation Response
NOTES'ECIPIENT
ID CODE/NAME
PD1-2
INTERNAL: ACRS
AEOD/DEIB
AEOD/TTC
NRR MORISSEAU,D
NRR/DLPQ/LPEB10
NRR/DREP/PEPB9H
NRR/PMAS/ZLPB 2
NUDOCS-ABSTRACT
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CLARKiR
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NOTE TO ALL RIDS
RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.
ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION
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TOTAL NUMBER OF COPIES
REQUIRED:
LTTR
25
ENCL
25
FEB i y 199)
Docket Nos.
50-387
50-388
Mr. Harold W. Keiser
Senior Vice President - Nuclear
Pennsylvania Power &Light Company
2 North Ninth Street
Allentown, Pennsylvania
18101
Dear Mr. Keiser:
SUBJECT:
NOTICE OF VIOLATION- INSPECTION REPORT NOS. 50-387/92-23
AND 50-388/92-23
This refers to the special fire protection safety inspection conducted from August 24 to
October 9, 1992, at both the Susquehanna
Steam Electric Station and at your Allentown,
Pennsylvania, offices.
During the inspection, four apparent violations related to your fire
protection program were identified. The inspection report which documents
these findings
was transmitted to you on December 4, 1992.
The issues related to the apparent violations
were discussed at an enforcement conference at the NRC Region I office on
January
19, 1993.
Persons attending the conference are identified in Attachment 1.
Also,
copies of your visual presentation material used at the conference are included as
Attachments 2 and 3 to this letter.
The first apparent violation concerned your apparent failure to perform Technical
Specification inspections on Kaowool fire barrier cable raceway wrap systems and gypsum
board fire enclosures
since their installation over ten years ago.
This finding was based on
information contained in the surveillance procedure in use at the time of our inspection and
discussions with personnel performing the surveillance inspection.
Your investigation
subsequent
to our inspection determined that Kaowool wrap and gypsum board enclosures
had been inspected until a procedure change made in December
1989 deleted inspections for
these fire barrier materials.
An NRC inspection, performed on January 20 and 21, 1993, to
be documented in NRC Inspection Report Nos. 50-387/93-01 and 50-388/93-01, reviewed
your records and confirmed your finding. You further indicated you are now in the process
of enhancing your procedures
and processes for performing these surveillance inspections.
Also, surveillances have been re-performed in plant areas containing the fire barrier materials
in question using enhanced
methods.
No significant additional discrepancies
were identified.
9302190045
9302ii
ADOCK 05000387'
OFFICIALRECORD COPY
G:ENFCONFM.LET
0
'r.
Harold W. Keiser
The second apparent violation concerned 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.
You have nearly
completed a comprehensive plant walkdown of installed fire wrap barriers.
Allidentified
fire barrier defects have been or are being repaired.
The third apparent violation concerned the failure to follow procedures to apply adequate
quality measures
to fire protection program design drawings.
You have nearly completed a
comprehensive plant walkdown to compare their drawings to the installed fire wrap barriers.
Allthe drawing errors found have been corrected and further drawing enhancements
are
planned.
The fourth apparent violation concerned the finding that Kaowool fire barrier material had
been installed in an area that was not protected by automatic fire suppression
and where
Kaowool has not been specifically approved for use.
Your plant walkdowns have identified
no other areas that contained Kaowool that were not protected by a suppression
system or did
not have an NRC approved exemption.
To correct this deficiency, you are planning to
remove the Kaowool and replace it with Thermo-Lag material.
V
Although not an enforcement action, an unresolved item (URI 387 and 388/92-03-01) that
concerned the use of a Thermo-Lag configuration in three areas was also discussed
during
the enforcement conference.
In response to this unresolved item, you noted that our
inspection report had stated that:
(1) there was reasonable
basis for PP&L to believe the
NRC's rejection of the cable tray portion of the test results in 1982 applied only to the three
fire areas for which there had been an exemption request,
and (2) that in 1982, PP&L was
not aware of and was not attempting to meet the 250 degree temperature rise criterion. At
the enforcement conference, you indicated that our inspection report adequately defined
PP&L's position, with respect to SSES spray-on Thermo-Lag fire barrier configuration.
Therefore, you believe that your staff had addressed
all of the NRC's concerns at the time of
licensing.
Based on our inspection findings as documented in the subject inspection report and your
presentation at the enforcement conference,
we consider this unresolved item to be closed.
However, closure of this item does not constitute an NRC position on the acceptability of the
use of Thermo-Lag installed in your plant or the Thermo-Lag test acceptance
criteria which
you used.
These items are part of a generic issue concerning the acceptability of Thermo-
Lag which is currently under review by the NRC.
Licensee actions concerning the use of
Thermo-Lag are addressed
in NRC Bulletins 92-01 and 92-02, Supplement
1; and Generic Letter 92-08.
OFFICIALRECORD COPY
G:ENFCONFM.LET
~
~
Mr. Harold W. Keiser
Although the four apparent violations noted above were collectively initiallyconsidered for
escalated
enforcement action, we have determined that this action was not appropriate in this
instance.
Our determination is based on your description of the causes,
safety significance of
the violations and your corrective actions to the identified deficiencies,
as well as a
subsequent review of our overall inspection findings.
However, the above activities appear to be in violation of NRC requirements,
as specified in
the enclosed Notice of Violation (Notice).
The violations are of concern because
each of
these violations could be attributed to the inadequate application of quality and lack of
management oversight to changes in the fire protection program that allowed these violations
to occur undetected over a considerable period of time. It is noted that all of the violations
were NRC identified; it was also noted that once these problems were identified, you
initiated prompt and extensive corrective action.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response.
In your response,
you should document the
specific actions taken and any additional actions you plan to prevent recurrence.
After
reviewing your response to this Notice, including your proposed corrective actions and the
results of future inspections,
the NRC willdetermine whether further NRC enforcement
action is necessary
to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and
its enclosures wiH be placed in the NRC Public Document room.
The responses
directed by this letter and the enclosed Notice are not subject to the clearance
procedures of the Office of Management and Budget as required by the Paperwork Reduction
Act of 1980, Pub. L. No. 96.511.
Sincerely,
Qr)gina) Sign~ai ~cV:
Marvin W. ik@:: -"
Marvin W. Hodges, Director
Division of Reactor Safety
Enclosures:
1.
Appendix A, Notice of Violation
2.
Attachment 1, Personnel Attending The Enforcement Conference
3.
Attachment 2, Licensee Response
Presented
at the Enforcement Conference
4.
Attachment 3, Supporting Information to Licensee Response
OFFICIALACCORD COPY
G:ENFCONFM.LET
Mr, Harold W. Keiser
cc w/encls:
J. M. Kenny, Nuclear Licensing
H. G. Stanley, Superintendent of Plant-SSES
Vice President, Nuclear Operations
M. M. Urioste, Nuclear Services Manager, General Electric Company
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
RI'DRP
Qzggp
02/A(93
02/03/93
bcc w/encls:
Region I Docket Room (with concurrences)
J. Lieberman, OE
M. Thadani, NRR
M. Hodges, DRS
L. Bettenhausen,
W. Lanning, 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
D. Holody, EO
¹ Blumberg, DRS
F. Bower, DRS
R. Mathew, DRS
DRS Files (2)
RI:DRS:D
Bower/dmg/ajk/dmg Blumberg
RI:DRS
Bettenhausen
02/+93
RI:DRS
02//o/93
OFFICIALRECORD COPY
G:ENFCONFM.LET