ML17157C197
| ML17157C197 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 02/10/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17157C196 | List: |
| References | |
| 50-387-92-23, 50-388-92-23, NUDOCS 9302190049 | |
| Download: ML17157C197 (56) | |
Text
APPENDIX A NOTICE OF VIOLATION Pennsylvania Power &Light Company Susquehanna Steam Electric Station Units 1 and 2 Docket Nos.:
50-387/50-388 License Nos.:
NPF-14/NPF-22 During an NRC inspection conducted between August 24 to October 9, 1992, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are listed below:
A.
Technical Specification 3.7.7 states:
"Allfire rated assemblies, including walls, floor/ceilings, cable tray enclosures and other fire barriers separating safety related fire areas or separating portions of redundant systems important to safe shutdown within a fire area, and all sealing devices in fire rated assembly penetrations, including fire doors, fire windows, fire dampers, cable and piping penetrations, seals and ventilation seals shall be OPERABLE."
Technical Specific'ation 4.7.7.1. states:
"Each of the above required fire rated assemblies and sealing devices shall be verified OPERABLE at least once per 18 months by performing a visual inspection of:
a.
The exposed surfaces of each fire rated assembly."
Contrary to the above, between December 1989 and September 4, 1992, the exposed surfaces of each fire rated assembly constructed of Kaowool and the gypsum board enclosures in Fire Zones 0-28A and 0-28B had not been verified operable.
This is a Severity Level IV violation {Supplement Q.
B.
Technical Specification 6.8.1 states, in part, that written procedures shall be implemented for the Fire Protection Program.
9302190049 930211 PDR ADQCK 05000387 8
I Appendix A 2
Procedure NDI-QA-15.3.1, Revision 3, Fire Protection Program, states, in part:
"This NDI outlines the unique responsibilities and interfaces required to implement the Fire Protection Program.", "Fire Protection Features And Activities Requiring Quality," of NDI-QA-15.3.1 specifies, in part, that:
"Quality requirements shaH be applied to the fire protection features in the following areas:
a.
d.
Unit 1 Reactor Building;...
Control Structure;...
Fire barrier wrapping identified as being wrapped to meet Appendix R (10 CFR 50) in Drawings E 294 and E 295; Fire-rated walls, fire-rated floors,...fire-rated penetration seals within and enclosing the above areas (as specified on engineering drawings)...."
Contrary to the above, as of September 4, 1992, the following are examples found where procedures had not been properly implemented and, therefore, adequate quality was not applied to two series of design drawings for required fire protection features in the Unit 1 Reactor Building and Control Structure.
~
Drawing E-294 did not show Kaowool as fire banier wrap material on conduits A1P105, C1P107, and A1P071 in Fire Zone 0-28H located in the Control Structure.
~
One of the C-1700 series of drawings, Drawing C-1754, failed to show correctly the conduit run for conduits E1P353 and C1P077 in Fire Zone 0-28B-I located in the Control Structure.
~
Drawing C-1721, Sheet No. 2, Revision 1, and E-294 omitted showing that conduits ElK586 and E1K758 were wrapped with Thermo-Lag where they entered Fire Zone 1-2D located in the Control Structure.
Drawing E-294 had no designation in the title block indicating the quality level of the drawing, and the C-Series drawings were incorrectly labelled in the title block "NONQUALITY-RELATED."
Additional examples where quality was inadequately applied to these two series of Fire Protection design drawings are identified in Section 5.1 and 'of Region I Inspection Report 50-387 and 388/92-23 and are considered part of this violation.
This is a Severity Level IVviolation (Supplement I).
I Appendix A
/
C.
The Susquehanna Steam Electric Station Unit 1 Facility Operating License, NPF-14, was amended on March 27, 1990, by Amendment 95 to revise License Condition 2.C.(6), which states, in part:
"Pennsylvania Power Bc Light Company shall implement and maintain in effect all provisions of the approved fire protection program as described in the Fire Protection Review Report for the facility and as approved in the NRC Safety Evaluation dated August 9, 1989...."
Table 5.0-1, part C.4, "Inspection," of the Fire Protection Review Report under the heading of "Susquehanna SES Compliance" states, in part, that field personnel witnessed the fire protection installation and verified conformance with design drawings.
Bechtel Specification 8856-E-61, Revision ), "Technical Specification for Electrical Raceway Fire Insulation Barrier Materials for the Susquehanna Steam Electric Station Units 1 and 2 of the Pennsylvania Power Bc Light Company, Allentown, Pennsylvania,"
was Susquehanna Steam Electric Station's (SSES) design specification for installing safe shutdown cable raceway fire barriers during construction.
Drawing A-107, Revision 21, "Control Structure Upper Cable Sprdg Rm - El 744'-0" Battery Room - El 771'-0"," describes construction features and details of gypsum board enclosures used to provide Appendix R protection for redundant safe shutdown electrical circuits and circuit breakers.
1.
Bechtel Specification 8856-E-61, paragraph 6.4.6, states that Zetex shall have a minimum 3 inch overlap.
Contrary to'the above, on August 27, 1992, in Fire Zone 0-28H, the Cold Instrument Shop, an approximately 20 square inches triangular section of Kaowool was not covered with Zetex and the Zetex did not have the specified 3 inch overlap.
2.
Bechtel Specification 8856-E-61, paragraph 6.4.11, states that where the raceway penetrates a fire barrier wall the juncture willthen be sealed with mastic coating to not less than 1/4 inch thickness and shall not extend less than 8 inches onto the exterior of the blanket and surface of the fire barrier and wall.
Contrary to the above, on September 1, 1992, in Fire Zone 1-4A-N, a conduit D1P008 fire barrier wrap junction at a fire rated wall was observed not to be sealed with mastic coating to the specified not less than 1/4 inch thickness and to not less than 8 inches onto the exterior of the blanket and surface of the fire barrier and wall.
Appendix A 3.
Drawing A-107, Detail 4, Elev., provides details of a one hour gypsum fire barrier enclosure with an air gap between the inner and outer gypsum board.
Contrary to the above, as of September 4, 1992, in Fire Zone 0-28B-II, a one-hour rated electrical breaker enclosure fabricated with gypsum board did not have the air gap between the inner and outer gypsum board making up the fire barrier enclosure as specified by the installation drawing, A-107, in drawing detail number 4.
4.
Additional examples where SSES's required fire protection quality assurance inspections failed to identify installation deficiencies that were not in conformance to the design specifications are detailed in Section 4.3.4 and of Region I Inspection Report 50-387 & 388/92-23 and are considered part of this'violation.
This is a Severity Level IVviolation (Supplement I).
D.
The Facility Operating License, NPF-14, was issued on July 17, 1982, for Susquehanna Steam Electric Station Unit 1 and contained a condition, 2.C.(7), Battery Room Area [Section 9.5.4, Safety Evaluation Report (SER), Supplemental Safety Evaluation Report SSER¹1 and SSER¹3] that stated:
"Prior to exceeding five percent of full power and subject to NRC review and approval, PP&L shall either conduct at an approved testing laboratory an ASTM E-119 test of the as-'installed one-hour cable wrap configuration or install an automatic fire extinguishing system."
The Facility Operating License, NPF-14 was amended on March 27, 1990, by Amendment 95 to revise License Condition 2.C.(6), which states in part:
"Pennsylvania Power & Light Company shall implement and maintain in effect all provisions of the approved fire protection program as described in the Fire Protection Review Report for the facility and as approved in the Safety Evaluation dated August 9, 1989...."
Contrary to the above, as of September 4, 1992, Susquehanna Steam Electric Station was found to have a Kaowool cable wrap fire barrier installed in Fire Zone 0-28H.
PP&L did not subject this Kaowool cable wrap to an ASTM E-119 test at an approved testing laboratory and PP&L did not submit this Kaowool cable wrap configuration to the NRC for review and approval for use in Unit 1 Battery Room Area, Fire Zone 0-28H, at the Susquehanna Steam Electric Station.
There is no automatic fire extinguishing system installed in Unit 1 Battery Room Area, Fire Zone 0-28H.
0
Appendix A Additional examples of how SSES's use of Kaowool in Fire Zone 0-28H do not meet the requirements of Deviation Request 8 or 17 of the Susquehanna Steam Electric Station Fire Protection Review Report are documented in Region I Inspection Report 50-387/92-23 and are considered part of this violation.
This is a Severity Level IVviolation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Pennsylvania Power &, Light Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATIÃ: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if contested, the basis for disputing the violation; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that willbe taken to avoid further violations; and (4) the date when full compliance willbe achieved. Ifan adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.
Where good cause is shown, consideration willbe given to extending the response time.
Dated a@King of PrussiaPen, nsylvania this/4'ay of February 1993
e ATTACKMXNTI ER NNEL ATTKNDIN E R KMEN'I'FKREN E n
Ivani P wer ndLi h Position P. Brady S. Davis G. Jones H. Keiser J. Kenny D. Kohn G. Kuceynski D. Ney C. Myers R. Peal G. Stanley R. Wehry W. Williams H. Woodeshick D. Zaprazny Senior Project Engineer - Engineering Tech.
Site Fire Protection Engineer Manager - Nuclear Engineering Sr. VP - Nuclear Licensing Group Supervisor Fire Protection Engineer - NE Manager, Nuclear Systems Engineering PA DER BRP Mgr., Nuclear Regulatory Affairs Compliance Supervisor Superintendent of Plant Compliance Engineer Nuclear Licensing Engineer Special Assistant to the President, PP&L Project Engineer, Design Modification Group U.. Nuclear Re lat omm ion G. Barber L. Bettenhausen N. Blumberg F. Bower D. Galvin M. Hodges B. Letts D. Mannai B. McDermott I. Miller A. Pelletier E. Wenzinger J. White J. Wiggins SM, Susquehanna Chief, Operations Branch Chief, Performance Programs Section Reactor Engineer, DRS Intern Resident Inspector, Susquehanna Director, DRS Field Office Director Resident Inspector Reactor Engineer Reactor Systems Engineer, NRR/DSSA/SPLB Projects Engineer, PDI-2, NRR/DRPE Projects Branch Chief Chief, Reactor Projects Section 2A Deputy Director, DRP
ATZACHMIWX2 LICENSEE RESPONSE PRESI~22lTXZ) AT THE KKORCI~22FAT CONF1HKÃCE
IN'PRODUCTION/AGENDA Harold W. Keiser Senior Vice President - Nuclear FIRE PROTECTION DEFICIENCY MANAGEMENT Harold G. Stanley Superintendent of Plant - SSES FIRE PROTECTION DESIGN ISSUES George T. Jones Manager - Nuclear Engineering UALITYOF FIRE BARRIER INSTALLATIONS George J. Kuczynski Manager - Nuclear Systems Engineering ASSESSMENT/
SUMMARY
Harold G. Stanley Superintendent of Plant - SSES
FIRE PROTECTION DEFICIENCYMANAGEMENT NQA Audit Process Improvements Management Involvement Results Insurance Inspection Issues
DRAWING UALITY History Design Review and Walkdown Results Corrective Actions
CABLE A2&?ACITY Initial Assessment Walkdown Data Design Control Process
ACCEPTABILITYOF KAOWOOLBAlRRIERS Suitability of Kaowool as a Fire Barrier Zetex Overwrap-Use of Kaowool in Unsprinklered Area
DESIGN OF GYPSUM SO&0) ENCLOSHRES Walkdowns Corrective Actions
QUALITYOF FIRE BARRIER INSTALLATIONS OVERVIEW
Response
to the NRC SSES Inspection (August 24th through September 4th) was:
prompt direct comprehensive All raceway wrap including Kaowool was declared inoperable on August 31, 1992 due to Bulletin 92-01
VAI.rrVOF mm SARIS rWSVmI,AYjOXS Surveillance Discrepancies Physical Discrepancies Drawing Discrepancies
FIRE SMOKIER SURVEILLANCEDISCREPANCIES FEA'I%HUM Thermo-Lag Kaowool Gypsum Board Fire Barrier Enclosures
FIRE BAR3HER SURVEILLANCEDISCREPANCIES ISSUES Failure to perform surveillances on Kaowool Inspection methodology used
FIRE BARRIER PHYSICAL DISCREPANCIES
. Kaowool used in Zone 0-28H
. Incomplete wrap
- conduit
- hangers
- gypsum enclosures
- Wear and Tear
I" 0
FIRE BARRIER PHYSICAL DISCREPANCIES FOR EACH CATEGORY:
Declared Inoperable Firewatches Established Non-Conformances and LERs Written Repairs In Progress
UALITYOF FIRE BARRIER INSTALLATIONS SUlVHVfARY Aggressive action taken.
Reworks and repairs well defined and under way.
Surveillance program has been strengthened.
LESSON LEARNED
%e recognize that we need to treat passive civil fire protection features with the same sensitivity as active features.
ASSESSMENT/SUNG% ARY We have not totally met our standards of excellence.
This process has enhanced our Program.
Corrections have been and will remain aggressive and comprehensive.
We have incorporated the lessons learned and are continuing to improve.
The physical plant is in excellent condition.
The Program continues to be well supported by management.
SSES has a strong Fire Protection Program.
ATTACHMIi2IT3 SUPPORTING INFORM'ATIONTO LICENSEE RESPONSE
0
9Gl~c~i
INTRODUCTION/AGENDA Harold W. Keiser Senior Vice President - Nuclear FIRE PROTECTION DEFICIENCY MANAGEMENT Harold G. Stanley Superintendent of Plant - SSES FIRE PROTECTION DESIGN ISSUES George T. Jones Manager - Nuclear Engineering UALITYOF FIRE BARRIER INSTALLATIONS George J. Kuczynski Manager - Nuclear Systems Engineering ASSESSMENT/
SUMMARY
Harold G. Stanley Superintendent of Plant - SSES
MANAGEMENTOVERVIEW A strong nuclear safety culture is the key. to success.
Fire protection must be part of the safety culture.
Rising expectations require continual self assessment and implementation of change.
We value the input provided by the NRC inspection.
Our Fire Protection Program complies with requirements.
SSES FIRE PROTECTION PROGRAM Long history.
Constantly improving.
There is a
department commitment to satisfy requirements.
Management is and has been committed and involved.
INSPECTION RESULTS NRC Inspection was a good effort.
Raised areas of question.
NRC Inspection Report adequately defines PPEcL position with respect to the SSES spray-on Thermo-Lag barrier configuration.
0
ORIGINALLICENSING OF SPRAY-OX BARRIER MATERIAL All license conditions were satisfied.
No substantive evidence of a generic temperature requirement for barrier material.
Deviation was limited to three zones.
Requirement to add fiberglass was in lieu of sprinklers for the three specific zones.
Other plant fire barrier configurations were found acceptable by NRC Inspection.
il
PPdkL's RESPONSE Comprehensive reviews have been performed.
We are in compliance.
%e have a sound program.
We have not found evidence of programmatic breakdown.
Efforts are continuing.
FIRE PROTECTION DEFICIENCY MANAGEMENT NQA AUDITPROCESS IMPROVEMENTS Prompt responses to audit findings.
Requirement to respond to audit findings and recommendations.
Incorporation ofaudit findings and recommendations into our deficiency management program.
I e
FIRE PROTECTION DEFICIENCYMANAGEMENT MANAGEMENTINVOLVEMENT Audit exits are conducted with Senior Manager.
Management attention when responses are delayed.
r High level approvals required for delays beyond one cycle.
FIRE PROTECTION DEFICIENCYMANAGEMENT RESULTS Reduction in backlog of open audit findings.
FIRE PROTECTION DEFICIENCY MANAGEMENT HANDLINGOF INSURANCE INSPECTION ISSUES incorporated into our deficiency management program effective management attention reduction in backlog
ENGINEERING PERSPECTIVES Fire Protection Program is important.
NRC Inspection Report provided valuable insights.
Configuration Management for Fire Protection does not meet our standards.
We must treat passive fire protection design features as important.
A comprehensive review has been performed.
We are correcting our deficiencies.
We are in compliance.
DRAWING UALITY History E294/295 Drawing Series C-1700 Drawing Series Design Review and Walkdown Results discrepancies were found missing barriers barrier ratings are correct Corrective Actions
CABLE AMPACITY INITIALASSESSMENT Timeliness Analytical Basis UL testing S%'RI testing Handling of NRC IN 92-46/GL 92-08 data WALKDOWNDATA walkdown of accessible areas no unacceptable electrical problems identified no useful life problems identified DESIGN CONTROL PROCESS initially failed to communicate design guidance updated previous work reviewed no safety impact
ACCEPTABILITYOF KAOWOOLBARRIERS SUITABILITYOF KAOWOOL AS A HRE BARMER ULtesting (File R8758, Project 78NK5345 9/06/78)
Sandia testing {NUREG/CR-0596)
Zimmer Docket Farley Docket GL 85-01, 86-10 ZETEX OVERWMZ Kaowool tested without Zetex purpose is mechanical/weather protection USE OF KAOWOOLIN UNSPRINKLERED AREA I
only occurrence is Zone 0-28H area was approved for 1-hour wrap actual fire loading is significantly less than 45 minutes Kaowool is being replaced in 0-28H
DESIGN OF GYPSUM BOARD ENCLOSURES WALEDOWNS four locations
~
an independent review has established existing enclosures satisfactory for at least 55 minutes
~ fire loadings are substantially less than 55 minutes CORRECTIVE ACTIONS enclosures declared inoperable LER prepared conservative action taken to replace with approved design
UALITYOF FIRE BARRIER INSTALLATIONS OVERVIEW
Response
to the NRC SSES inspection
{August 24th through September 4th) was:
prompt direct comprehensive All raceway wrap including Kaowool was declared inoperable on August 31 due to Bulletin 92-01.
Special project team formed:
Engineering Drafting QA Licensing
Overview Continued Comprehensive plant walkdown vs.
the drawings was initiated in September.
98% of the plant areas with raceway wrap have been walked down, with currently inaccessible areas left to be walked down (< -1% of raceway).
6 out of 10 NRC identified physical discrepancies are repaired.
AllPAL self-identified physical discrepancies are being repaired.
Alldrawing errors found are corrected.
bevy Alldrawing enhancements and clarifications are added.
Over 3000 manhours expended on this effort by the organization since the NRC inspection team exited.
UALITYOF FIRE BARRIER INSTALLATIONS Surveillance Discrepancies Physical Discrepancies Drawing Discrepancies
FIRE SAR3OER SURVEILLANCEDISCREPANCIES Thermo-Lag Kaowool Gypsum Board Fire Barrier Enclosures
FIRE BARRIER SURVEILLANCEDISCREPANCIES ISQH~A failure to perform surveillances on Kaowool inspection methodology used - procedural guidance and acceptance criteria
FIRE BARRIER SURVEILLANCEDISCREPANCIES FAILURE TO PERFORM Thermo-Lag, Kaowool and Gypsum Board enclosures have been surveilled since 1982.
A less than adequate surveillance cycle was performed since 1990 - the station common Kaowool installations were missed.
The 1990 cycle surveillance on Kaowool was performed in December, 1992 for station common.
The 1990 cycle surveillance on Kaowool was re-performed in Unit 1
as a
conservative measure in
- January, 1993.
There is no Kaowool in Unit 2.
Upfront training and engineering oversight was provided for the re-performance of the Kaowool surveillances.
FIRE BARRIER SURVEILLANCEDISCREPANCIES INSPECTION METHODOLOGY The NRC inspection and our drawing walkdowns noted and documented physical discrepancies.
Our raceway wrap surveillance procedures are being re-written with improved methodology and clearer acceptance criteria.
The revised procedures willbe issued by April 30, 1993.
All raceway wrap surveillances will be reperformed starting in May of 1993, to be completed no later than the end of'he Unit 2 sixth refuel outage.
FIRE BAIWIERPHYSICALDISCREPANCIES Kaowool used in Zone 0-28H.
Incomplete wrap.
- conduit
- hangers
- gypsum enclosures Wear and tear.
FIRE BARSJER PHYSICALDISCREPANCIES FOR EACH CATEGORY'eclared Inoperable Firewatches Established Non-Conformances and LERs Written Repairs In Progress
FIRE BARRIER PHYSICAL DEFICIENCIES Kaowool used in Zone 0-28H without suppression.
Action:
Kaowool will be removed and replaced in Zone 0-28H.
ECD 1-28-93 Incomplete wrap - conduit and hangers:
17 instances found
- 2 sections of conduit unwrapped
- 15 minor discrepancies Action:
Wrap being installed with an ECD of April 30, 1993.
Incompleted wrap - Gypsum enclosures.
Action:
Enclosures are being re-designed and installation with an ECD of April 30, 1993.
Wear and Tear.
Action:
18 discrepancies being repaired with an ECD of April 30, 1993.
FIRE BARRIER DRAWINGDISCREPANCIES Initiated a comprehensive walkdown of all plant areas with fire rated raceway wrap.
98% of the areas completed, which is 99% of all the required raceway.
Inaccessible areas will be done during the next unit shutdown that will allow access.
Found 10 differences in barrier wrap material.
Found 7 incorrect or missing raceway labels.
Found 57 drawing errors.
The materials differences and drawing errors have all been resolved and the DCNs are posted on the drawings.
The incorrect/missing labels are being corrected with an ECD of April 30, 1993.
UALITVOF FIRE BARRIER INSTALLATIONS SUM'NARY Aggressive action taken.
Reworks and repairs well defined and under way.
Surveillance program has been strengthened.
LESSON LEARNED We recognize that we need to treat passive civil fire protection features with the same sensitivity as active features.
ASSESSMENT/SUIVIMARY We have not totally met our standards of excellence.
This process has enhanced our Program.
Corrections have been and will remain aggressive and comprehensive.
We have incorporated the lessons learned and are continuing to improve.
The physical plant is in excellent condition.
The Program continues to be well supported by management.
SSES has a strong Fire Protection Program.-