ML18065A865

LER 96-009-00:on 960712,identified Penetration Seal Deficiency on Fire Barriers Caused by Failure to Perform & Document Comprehensive Fire Barrier Evaluation.Developed Basis document.W/960812 Ltr

ML18065A865
Person / Time
Site:	Palisades
Issue date:	08/12/1996
From:	Bordine T, Engle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-96-009, LER-96-9, NUDOCS 9608200212
Download: ML18065A865 (6)

Text

consumers Power POWERiNii lllllCHlliAN"S PROliRESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 August12, 1996 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT LICENSEE EVENT REPORT 96-009, PENETRATION SEAL DEFICIENCY ON FIRE BARRIERS Licensee Event Report (LER)96-009 is attached. This event is reportable to the NRC is accordance with 10CFR50.73(a)(2)(ii)(B) as a condition outside the plant design basis.

SUMMARY

OF COMMITMENTS This letter contains three new commitments and no revisions to existing commitments.

1. Develop a basis document for fire barriers at Palisades.

2. Develop acceptance criteria for fire barriers based upon the fire protection basis document, and utilize the new criteria to inspect all fire barriers, including penetration seals, doors, dampers etc.

9608200212 960812 PDR ADOCK 05000255 S PDR A CM5 ENERGY COMPANY

2

3. Implement programmatic controls to maintain plant fire barriers.

Thomas C. Berdine Manager, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades

.Attachment

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150:-0104 (4195) EXPIRES 4130/98 ESllW.TED IUl!lEH PER RESPONSE TO COllPL Y WITH TlilS llANDATORY INFORMATION COUECTION REQUEST: 50.0 HRS. REPORTED LESSONS LEARNED ARE INCORPORATED LICENSEE EVENT REPORT (LER) INTO THE LICENSING PROCESS AHO FED BACK TO INDUSTRY. FORWARD COllllENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AHO RECORDS llANAGEllENT 8RNICH (T.a F33), U.S. MJCLEAR REGUIATORY COlllllSSION, WASHINGTON, DC :zo55S.

0001, AHO TO THE PAPERWORK REDUC'TION PROJECT (3150-0104, OFFICE OF (See reverse for required number of digits/characters for each block) llNIAGEllENT AHO BUDGET, WASHINGTON, DC 20503 FACILITY NAME (1) DOCKET NUMBER (2) Page (3)

PALISADES NUCLEAR PLANT 05000255 1of4 1~(4) LICENSEE EVENT REPORT 96-009, PENETRATION SEAL DEFICIENCY ON FIRE BARRIERS EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

MONTH DAY YEAR YEAR I SEQUENTIAL NUMBER REVISION NUMBER MONTH DAY YEAR FACILITY NAME DOCKET NUMBER 05000 FACILITY NAME DOCKET NUMBER 07 12 96 96 - 009 - 00 08 12 96 05000 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check one or more) (11)

MODE(9) N 20.2201(b) 20.2203(a)(2)(v) 50. 73(a)(2)(i) 50. 73(a)(2)(iii)

POWER 20.2203(a)(1) 20.2203(a)(3)(i) x 50. 73(a)(2)(ii) 50.73(a)(2)(x)

LEVEL (10) 98 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50. 73(a)(2)(iii) 73.71

\ *.* .** .****.********** 20.2203(a)(2)(ii) 20.2203(a)(4) 50. 73(a)(2)(iv) OTHER 20.2203(a)(2)(iii) 50.36(c)(1) 50.73(a)(2)(v)

Specify in Abstract below or I! ! + > 20.2203lall2lliv\ 50.36lcll2l 50.73lall2llviil in NRC Form 366A LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER (Include Area Code)

Dale E. Engle, Licensing Engineer (616) 764-2848 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT 113)

CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TONPROS TONPROS SUPPLEMENTAL REPORT EXPECTED (14) MONTH DAY YEAR I YES If ves COMPLETE EXPECTED COMPLETION DATE x I NO EXPECTED SUBMISSION DATE (15)

\,

ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16) -

On July 12, 1996, at 0750 a.m., with the plant operating at 98% power, two fire barriers were identified as being degraded. While completing walkdowns of fire dampers, it was discovered that

1) Styrofoam insulation (combustible material) had been used to fill the annular space around a duct penetrating the wall assembly which separates Fire Area 3 (1-D Switchgear Room) and Fire Area 21 (Electrical Equipment Room), and 2) an unsealed penetration was observed in the floor/ceiling assembly separating Fire Area 2 (Cable Spreading Room) from Fire Area 4 (1-C Switchgear Room). The two conditions described are outside the plant design basis because they impair the function of required three-hour rated fire barriers. Immediate action was taken to verify hourly fire tours were in place per plant procedures. Fire tours have been in place for other reasons since September 1994. These conditions have existed for many years. These fire barriers will be returned to operable status following engineering and implementation of an acceptable design.

NRC FORM 366a U.S. NUCLEAR REGULATORY COMMISSION 4195 LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION

. FACILITY NAME 11l 05000255 YEAR l LER NUMBER '6\

SEQUENTIAL NUMBER REVISION NUMBER PAGE 13l 20F4 PALISADES NUCLEAR PLANT 96 009 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

EVENT DESCRIPTION On July 12, 1996, at 0750 a.m., with the plant operating at 9~% power, two fire barriers were identified as being degraded. While completing walkdowns of fire dampers, it was discovered that:

1. Styrofoam insulation (combustible material) had been used to fill the annular space around a duct penetrating the wall assembly which separates Fire Area 3 (1-D Switchgear Room) and Fire Area 21 (Electrical Equipment Room). The fire damper was installed by a modification; however, the design required the annular space between the damper/duct and the barrier to be filled with Kaowool. A Styrofoam type sheet material was used to fill the annular space

. and the Styrofoam was covered with a grout material. Over time the grout material has cracked and broken out revealing the Styrofoam. For this specific fire damper no design information could be found that directed this physical arrangement, nor could any specific installation instructions be found. Neither Kaowool nor Styrofoam are consistent with the manufacturers recommended installation practice.

• Palisades Fire Protection SER dated 9/1/78 directed the plant to seal the gap between each duct and any fire barrier walls it penefrates. It appears that the plant followed the direction found in the SER even though this violated the manufacturer's instructions. For a damper to work properly, an expansion space is provided between the damper and a wall it penetrates.

When this space is improperly filled, expansion at elevated temperature can prevent the l!

damper from closing.

2. An unsealed penetration was observed in the floor/ceiling assembly separating Fire Area 2 (Cable Spreading Room) from Fire Area 4 (1-C Switchgear Room). The penetration is a 10 inch deep cylindrical hole into a 12 inch thick concrete slab. The remaining 2 inches are filled with an undocumented substance.

No conclusive documentation could be found to provide a basis for fire barrier ratings in the plant.

It appears that fire barriers were originally determined to be adequate on the basis of engineering judgement. It is not currently possible to determine what the actual required rating is for each fire barrier. Therefore, all fire barriers are conservatively assumer' to be three-hour safety-related fire barriers unless determined otherwise.

The two conditions described above are outside the plant design basis in that they impair the function of required three-hour rated fire barriers. Immediate action was taken to verify hourly fire tours were in place per plant procedures. Fire tours have been in place for other reasons since September 1994. These conditions have existed for many years. These fire barriers will be returned to operable status following engineering and implementation of an acceptable design.

I NRC FORM 366a U.S. NUCLEAR REGULATORY COMMISSION 4195 LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION DOCKETl2\ NUMBER 6\ PAGE 13\

I FACILITY NAME 11 l 1 i::g YEAR SEQUENTIAL REVISION NUMBER NUMBER 30F4 PALISADES NUCLEAR PLANT 05000255 96 009 - 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

SAFETY SIGNIFICANCE The conditions identified in this LER are of low safety significance for the following reasons:

1. Fire barriers throughout the plant are generally considered to be intact based on continuing surveillance.

2. The fire loadings in the areas in question are low to moderate.

3. The areas in question are protected by automatic sprinkler systems and early warning smoke detection systems.

4. A fully trained and equipped fire brigade is maintained on site at all times and is available to respond to any fire that may occur.

5. Transient combustibles and hot work are administratively controlled throughout the facility.

6. The penetration and damper in question, although degraded, offer some level of fire protection in their as-built condition.

7. Fire dampers have been subjected to drop testing on an 18 month frequency, therefore their initial operation is assured.

8. Hourly fire tours are in place to further preclude the possibility of an undetected fire per the administrative requirements of the plant fire protection program.

9. The location of the penetration and damper in question is above walkways which generally preclude the placement of in situ and transient combustibles. This assures a minimal fire exposure hazard to the damper.

CAL' 1E OF THE EVENT The root causes of this situation were:

1. Failure to perform and document a comprehens.ive fire barrier evaluation when fire protection requirements were originally published, and again when IN 88-04 and other industry information was issued.

• • NRC FORM 366a U.S. NUCLEAR REGULATORY COMMISSION 4195 LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION I

FACILITY NAME 11 l DOCKETt2l LER NUMBER 61 PAGE 131 YEAR SEQUENTIAL REVISION NUMBER NUMBER 4 OF4 PALISADES NUCLEAR PLANT 05000255 96 009 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

2. Failure to perform and document adequate design reviews during original plant construction and subsequent modifications.

3. Failure to have single point accountability for fire protection/Appendix R prior to 1994.

4. Failure to properly prioritize fire protection/Appendix R efforts to satisfy regulatory/safety expectations.

CORRECTIVE ACTIONS

1. Develop a basis document for fire barriers at Palisades.

2. Develop acceptance criteria for fire barriers based upon the fire protection basis document, and utilize the new criteria to inspect all fire barriers, including penetration seals, doors, dampers etc.

3. Implement programmatic controls to maintain plant fire barriers.