ML17306A902

LER 90-009-01:on 900911,determined That Fire Barrier Insp Criterion Not Met.Caused by Improper Installation During Construction.Review of Current Maint Programs Performed. W/920813 Ltr

ML17306A902
Person / Time
Site:	Palo Verde
Issue date:	08/13/1992
From:	Bradish T, James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
192-00797-JML-T, 192-797-JML-T, LER-90-009, LER-90-9, NUDOCS 9208200192
Download: ML17306A902 (16)

Text

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ACCESSION NDP,:+2082001./2 DQC. DA. . V2/0S/13 NOTAPI"ED: NO DOCKET 8 FACIL: ST!'il-50-529 Palo Verde Nuclear Sta+ion) UngT, 2) Ai 1zon~ Pub11 05000529 AUTH. NA!"!: AUTHOR AFF IL I ATION BRADIS!-! . R, A. 'ona Pu.'ilic, Se. v.'ce Co. < FoTrrieT lM AT izona Nuclear Poorer LEVINE) J. N AT'1 '='iia Pub RECIPIENT'tT I i c SeT vi c i Co ~ a t'c'TseT'I 'j AT'i z ona Nuc i Ii IATIQ) c.aT'oseT'EC I P. NAi"sE AFF P 92 00-* 01.'n 9'Oi23ii ir 5!i ace eo anc& CT'" %el" io,j no 'riet

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Arizona Public Service Company PALO VERDE NUCLEAR GENERATING STATION P.O. BOX 52034 ~ PHOENIX, ARIZONA 85072-2034 192-00797-JML/TRB/JRB JAMES M. LEVINE VICE PRESIDENT August 13, 1992 NUCLEAR PRODUCTION U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station Pl-37 Washington, DC 20555

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-529 (License No. NPF-51)

Licensee Event Report 90-009-01 File: 92-020-404 Enclosed please find Licensee Event Report (LER) 90-009-01 prepared and submitted pursuant to 10 CFR 50.73. This LER reports the results of Arizona Public Service Company's (APS) inspection of fire area boundaries and associated sealed penetrations. This report is being revised to provide information regarding the inspections that were conducted in Units 1 and 3 following the Unit 2 inspections reported in revision 0 of this report. APS has evaluated approximately one-third of these discrepancies for reportability and no condition has been identified which would have adversely affected the ability to achieve and maintain safe shutdown in ttIe event of a fire.

Although none of the evaluated discrepancies have been determined to be reportable, APS recognizes that certain of the identified discrepancies which have not been evaluated may be reportable. IIowever, since significant resources are necessary to evaluate each discrepancy for reportability, no further reportability evaluations are planned and the resources are being utilized to correct the identified discrepancies. In accordance with 10 CFR 50.73(d), a copy of this LER is being forwarded to the Regional Administrator, NRC Region V.

Ef you should have any questions, please contact Thomas R. Bradish of my staff at (602) 393-5421.

Very truly yours, JML/TRB/JRB/pmm Enclosure cc: W. F. Conway (all w/enclosure)

J. B. Martin J. A. Sloan INFO Records 92082001~~~ P20813 PDR ADOCK ~000529 PDR 8

I LlCENSEE EVENT REPORT (LER)

DOCKET NUMBER (2) PACE 3 FACILITYNAME (I)

Pal o Verde Uni t 2 o s o o o 52 9loF06 TITLE (4)

Report on Fire Barrier Inspection EVENT DATE (5) LER NUMBER (6) REPORT DATE P) OTHER FACIUTIES INVOLVED(6)

DAY YEAR FACIUTY NAMES DOCKET NUMBER(S)

MONTH DAY YEAR YEAR NUMBER NUMBER MONTH Palo Verde Unit 1 o s o o o 5 2 8 09119090 0 0 9 0 1 081392 THIS REPORT IS SUBMATED PURSUANT TO THE REQUIREMENTS OF 10 CFR Palo Verde Unit 3 l: (Check one or more ot 0>> Iolbwing) (1 1) o s o o o 5 3 0 OPER ATINa MoDE (0) 1 20A02(b) 20.405(c) 50.73(a/2) (Iv) 73.71(b) 20.405(aN 1)(I) 5046(c)(1) 50.73(a)(2)(v) 73.71(c) 20A05(a/1 ~ii 50.36(c)(2) 50.73(a)(2)(vII) OTHER (Sprciiy(n Abstract (10) 1 0 0 below and in Tr< NITC Farm 20A05(a)(I)(ii) 50.73(a)(2)(1) 50.73(a)(2)(vB)(A) 366A) 20.405(a)( I )(tv) 50.73(a)(2)0I) 50.73(a)(2)(vtiXB) Technical 20A05(a)(1)(v) 50.73(a) (2)(ti) 50.73(a)(2)(x) Specifications 6.9.3 LICENSEE CONTACT FOR TIES LER (12)

NAME TELEPHONE NUMBER Thomas R. Bradish, Compliance Manager 60 2393 5421 COMPLETE ONE LINE FOA EACH COMPONENT FAILURE DESCREIED IN THIS REPORT (13)

MANUFAC REPORTABLE MANUFAC- EPORTAB CAUSE SYSTEM COMPONENT SYSTEM COMPONENT TURER TO NPRDS TURER To NPRDS SUPPLEMENTAL R EPOAT EXPECTED (I 4) MONTH DAY YEAR EXPECTED SUBNSSION DATE (1 5)

YES (llyes, ocmplrte EXPECTED SUBMISSION DATE) X NO ABsTAAGT glnit sc 1400 spscra I e., spproximstrfyo'Item sbrglr spear type wrfttsn Ines) (I 6)

Palo Verde Unit 2 was in Mode 1 (POWER OPERATION) at 100 percent power when the Unit 2 eighteen-month inspection of fire area boundaries (walls, floors, and ceilings) and associated sealed penetrations (except fire doors) was completed on September ll, 1990. Palo Verde Units 1 and 3 were in Mode 1 fire barrier/penetration (POWER OPERATION) at 100 percent power when similar inspections were completed by December 31, 1990.

Approximately 1437 instances were identified out of approximately 10,000 attributes associated with fire barriers and sealed penetrations examined where either an inspection acceptance criterion was not met or the adequacy of the installed configuration was questionable. Approximately one-third of these discrepancies have been evaluated for reportability and no condition has been identified which would have adversely affected the ability to achieve and maintain safe shutdown in the event of a fire.

Fire barrier impairment compensatory actions were established in accordance with plant procedures. The identified discrepancies, with the exception of those dealing with gypsum/plaster board and concrete/block walls, have been dispositioned and corrected or scheduled for rework.

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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITYNAME DOCKET NUMBER LER NUMBER PACE SEQUENTIAL REVISION NUMBER NUMBER Palo Verde Unit 2 osooo529 9 0009 0 1 0 2 oF0 6 DESCRIPTION OF WHAT OCCURRED:

A. Initial Conditions:

Palo Verde Unit 2 was in Mode 1 (POWER OPERATION) at 100 percent power during this event. Palo Verde Units 1 and 3 were in Mode 1 (POWER OPERATION) when fire barrier/penetration inspections were completed.

B. Event Description (Including Dates and Approximate Times of Major Occurrences):

Event Classification: Potential violation of the requirements of the Fire Protection Program which would have adversely affected the ability to achieve and maintain safe shutdown in the event of a fire (Technical Specification 6.9.3).

On September ll, 1990, the Unit 2 eighteen month inspection of fire area boundaries (walls, floors, and ceilings) and associated sealed penetrations (PEN) was completed. By December 31, 1990, similar fire barrier/penetration inspections were completed in Units 1 and 3. Approximately 1437 discrepancies were identified out of approximately 10,000 attributes associated with fire barriers and sealed penetrations examined during the performance of the inspection.

The Fire Protection Program (FPP) described in the Updated Final Safety Analysis Report (UFSAR) requires periodic inspections of fire barriers and associated penetrations. Specific requirements are that 100 percent of the fire barriers and 10 percent of the barrier sealed penetrations be inspected every 18 months. The following fire barriers and sealed penetrations are included within the scope of these inspections.

1. Fire barrier walls, floors, and ceilings

2. Silicone based seals

3. Multi-cable transit seal

4. Permanent damming materials

5. Boot seals

6. Non-foam seismic gap seals

7. Spare conduits penetrating fire barriers

8. Concrete and concrete masonry barriers

9. Grout seals

10. Solid concrete block barrier walls ll. Duct penetration seals

12. Plaster seals

13. Seismic gap seals

14. Internal conduit seals

LICENSEE EVENT REPORT (LER) TEXT CONTINUATION DOCKET NUMBER PAOE FACILITYNAME SEOUENTIAL REVISION NUMBER NUMBER Palo Verde Unit 2 osooo 52990 009 0 1 0 3 oFO 6

15. Electric raceway fire barriers

16. Spray on fire proofing

17. Heating, ventilation, and air conditioning fire dampers Prior to the Unit 2 UFSAR required eighteen month inspection of fire barrier/penetrations, internal Palo Verde audits identified deficiencies in the fire barrier program. The audits identified that some sealed penetrations were not identified and specific acceptance criteria were not established for some penetration types. In addition, the audits identified programmatic concerns that included discrepancies between drawings and seal schedules and that some seal functional requirements, qualification, and installation records were not retrievable. As a result of these findings, a Fire Barrier and Penetration Seal Adequacy Verification Program was developed to address and correct the deficiencies.

In accordance with the verification program schedule and the schedule provided to the NRC in a March 16, 1990 letter (reference APS letter number 102-01635-WFC/TRB/RJR), a 100 percent inspection of Units 1, 2, and 3 fire barriers and sealed penetrations was performed. This inspection visually compared barriers and penetrations to established acceptance criteria and was used to obtain baseline data for resolving identified programmatic concerns. Examples of the acceptance criteria are given below.

Silicone base seals No more than 1/2 inch separation or shrinkage of the seal material from the penetrant or sides of penetrations. No damage, voids, tears, cuts in excess of 1/2 inch depth.

Spare conduits Metal caps on both sides of barriers. Junction boxes that spare conduits terminate in shall have covers installed.

Non-silicone boot seals The boot shall be free of holes, rips or tears along seams in the seal fabric or around banding. All mechanical hardware shall be in place.

Concrete Walls The barrier shall be free from chips, gaps, cracks, or voids which are greater than 3/4 inch in depth.

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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION DOCKET NUMBER PACE FACILITYNAME YEAR PE SEQUENTIAL @~ REVISION NUMBER j~5 NUMBER Palo Verde Unit 2 o'sooo529 90 009 0 1 0 40F 0 6 The Unit 2 fire barrier and penetration seal 100 percent inspection was completed on September 11, 1990. The Units 1 and 3 inspections were completed by December 31, 1990. Approximately 1437 instances were identified out of approximately 10,000 attributes associated with fire barriers and sealed penetrations examined where the inspection procedure acceptance criteria was not met or the installed configuration requirements were not clear. The identified discrepancies were documented on Material Non-conformance Reports (MNCRs) in accordance with the inspection procedure. The identified discrepancies included chipped concrete barriers, concrete barriers with non thru-wall holes of varying depth, silicone seal shrinkage, excessive gaps in damming material, cracked thermolag, improperly sealed spare conduits, penetrations without seal material, and improperly installed flashing around ventilation duct penetration seals. Approximately one-third of these discrepancies have been evaluated for reportability and no condition has been identified which would have adversely affected the ability to achieve and maintain safe shutdown in the event of a fire.

Status of structures, systems, or components that were inoperable at the start of the event that contributed to the event:

Not applicable - no structures, systems, or components were inoperable at the start of the event which contributed to this event.

D. Cause of each component or system failure, if known:

Not applicable - no component or system failures have been identified to date.

Failure mode, mechanism, and effect of each failed component, if known:

Not applicable - no component failures have been identified to date.

F. For failures of components with multiple functions, list of systems or secondary functions that were also affected:

Not applicable - there were no failures of components with multiple functions.

G. For a failure that rendered a train of a safety system inoperable, estimated time elapsed from the discovery of the failure until the train was returned to service:

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LICENSE EVENT REPORT (LER) TEXT CONTINUATION FACILITYNAME DOCKET NUMBER PACE YEAR %:,' SEOUENTIAL gj REVISION NUMBEA NUMBER Palo Verde Unit 2 osooo529 0 009 0 106 OF 0 6 To adversely affect the safety of the plant, a discrepancy would have to permit a fire to propagate across a fire barrier and ignite material in another fire zone. The resultant fire would then have to affect equipment redundant to the equipment in the original fire zone. Because of the low combustible loads in most safety related areas, availability of detection (IC) and suppression (KQ, KP) systems in safety related areas, and the availability of the Palo Verde Fire Department, the probability of a fire spreading is considered remote.

III. CORRECTIVE ACTION:

Immediate:

Fire barrier impairment compensatory actions were established for the identified discrepancies. This consisted of establishing fire watch surveillance as required by the FPP.

Action to Prevent Recurrence:

The fire barrier/penetration inspections have been performed in Units 1, 2, and 3 in accordance with the schedule submitted to the NRC in the March 16, 1990 letter. The identified MNCRs, with the exception of those dealing with gypsum/plaster board and concrete/block walls, have been dispositioned and corrected or scheduled for rework. Disposition of gypsum/plaster board and concrete/block wall discrepancies is pending implementation of an engineering action plan to address plaster, gypsum, and block wall concerns which was developed in support, of the PVNGS Fire Protection Justification for Continued Operation.

Since past maintenance practices could have contributed to the event, a review of current maintenance programs was performed.

The programs currently in place are sufficient to prevent maintenance activities from degrading fire barriers. Since 100 percent of the fire barriers have been inspected and maintenance programs prevent degradation of the barriers, no further actions are required to prevent recurrence.

As a result of the internal audits the Fire Barrier and Penetration Seal Adequacy Verification Program (now referred to as the Penetration Seal Program) was 'developed. This program has clearly established design requirements for each barrier/penetration seal and will insure the barrier/penetration seal meets the requirements. The eighteen month inspection will ensure barriers are maintained such that the design function can be performed.

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