ML18106A907

LER 98-014-00:on 980918,discovered That Fire Barrier Matl for HVAC Ducts Does Not Meet Required Level of Fire Resistance.Cause Indeterminate.Established Appropriate Compensatory Actions for Fire Barriers.With 981001 Ltr

ML18106A907
Person / Time
Site:	Salem
Issue date:	10/01/1998
From:	Bakken A, Bernard Thomas Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-98-014, LER-98-14, LR-N980462, NUDOCS 9810130318
Download: ML18106A907 (4)

Text

,.I 0PSE<l' Public Service Electric and Gas ~ompany P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236

• Nuclear Business Unit OCT 011998

'LR-N980462 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 LER 311/98-014-00 SALEM GENERATING STATION -UNIT 2 FACILITY OPERATING LICENSE NO. DPR-75 DOCKET NO. 50-311 Gentlemen:

This Licensee Event Report entitled "Fire Barrier Material for HVAC Ducts Does Not Meet Required Level. of Fire Resistance" is being submitted pursuant to the requirements License Condition 2.1 and Technical Specification 6.9.3.

Sincerely,

~~

A. C. Bakken Ill General Manager -

Salem Operations Attachment I

BJT C Distribution LER File 3.7 9810130318 981001 r PDR ADDCK 05000311 S PDR The* power is in your hands.

95-2168 REV. 6194

1- -

NRC FORM 366 AP PRO Y OMB NO. 3150-0104 EXPIRES 06/30/2001 U.S. NUCLEAR REGULATORY COMMISSION (6-1998) Estimated burden per response to comply with this mandatory information collection request: 50 hrs. Reported lessons learned are incorporated into the licensing process and fed back to industry. Forward comments regarding LICENSEE EVENT REPORT (LER) burden estimate to the Records Management Branch (T-6 F33), U.S.

Nuclear Regulatory Commission, Washington, DC 20555-0001, and to the Paperwork Reduction Project (3150-0104), Office of Management and (See reverse for required number of Budget, Washington, DC 20503. If an information collection does not display digits/characters for each block) a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

FACILITY NAME (1) DOCKET NUMBER (2) PAGE (3)

Salem Unit 2 05000311 1 OF 3 TITLE 141 Fire Barrier Material for HVAC Ducts Does Not Meet Required Level of Fire Resistance C\ICl~T nATC /1::1 CD NI lft*DCD /I ii . DCD,"\DT nATC 1"71 nTUCD _A ..... ITIC" IMVnl vcn /RI MONTH DAY YEAR YEAR SEQUENTIAL REVISION MONTH DAY YEAR FACILITY NAME DOCKET NUMBER

Salem Unit 1 05000272 FACILITY NAME DOCKET NUMBER 09 18 98 98 014 00 10 01 98 OPERATING TUIC CCDnDT '" Cl . Dll""IAft.ITTn TUC DCnl *A* ~ ,,.,...

50. 73(a)(2)(i) 1n f"CD 6° lr-hor-1<- nno nr - - * - ' 1111

50. 73(a)(2)(viii)

Mode 1 20.2201 (b) 20.2203(a)(2)(v)

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

LEVEL (10) 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50. 73(a)(2)(iii) 73.71 100 20.2203(a)(2)(ii) 20.2203(a)(2)(iii) 20.2203(a) (4) 50.36(c)( 1)

50. 73(a)(2)(iv)

50. 73(a)(2)(v) x OTHER Specify in Abstract below or in NRC Form 366A 20.2203(a)(2)(iv) 50.36(c)(2) 50. 73(a)(2)(vii)

I rno.tTl\rT ,...,,..., T1-11c * ,.... 11?1 NAME TELEPHONE NUMBER (Include Area Codel Brian J. Thomas, Licensing Engineer 609-339-2022 rn**D* CT~ no1c 1101c .-nD Cl\ru - II I*-- --~ - - * - - - lft.I "UIC" DCPnRT 1 .,,

CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE ..

• CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO EPIX TO EPIX C"llDDI -----*-~1 RCPnRT .. /1 ;ti EXPECTED *~nl\ITl-I t"IJ\Y YEllR I YES (If yes, complete EXPECTED SUBMISSION DATE). 1x NO ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)

This Special Report is being made pursuant to the requirements of License condition 2.1 which requires that a 14 day report be submitted for cases where the provisions of the approved fire protection program are not maintained. Further, Technical Specification 6.9.3 state that "violations of the fire protection program ... which would have adversely affected the ability to achieve and maintain safe shutdown in the event of a fire shall be submitted ... via the Licensee Event Report System within 30 days." The report satisfies both of these requirements.

During recent testing of the FS-195 material, the fire resistance of the FS-195 material did not meet the one-hour rating for certain electrical raceway fire barrier configurations. A review of the test results in conjunction with the as-installed FS-195 configuration for HVAC duct fire wrap resulted in the conclusion that the fire resistance of the HVAC duct fire barrier extensions is less than expected. The exact fire resistance capability of the installed HVAC fire wrap configurations has not been determined.

Appropriate compensatory actions for HVAC duct fire barrier extensions have been established in accordance with the fire protection program.

NRC FUMIVI 366 (6-1998)

e*

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (6-1998)

LICENSEE EVENT REPORT (LER)

. TEXT CONTINUATION DOCKET 121 PAGE 131 FACILITY ~'"ME 111 LER NUMBER 161 NUMBER 121 SEQUENTIAL IREVISION SALEM UNIT2 05000311 YEAR I NUMBER NUMBER 2 OF 3 98 - 014 - 00 TEXT (If more space is required, use additional copies of NRC Form 366AJ 1171 PLANT AND SYSTEM IDENTIFICATION Westinghouse - Pressurized Water Reactor Fire Protection

• Energy Industry Identification System (EllS) codes and component function identifier codes appear as {SS/CCC}

CONDITIONS PRIOR TO OCCURRENCE Salem Unit 1and 2 were in Mode 1 at 100% reactor power.

DESCRIPTION OF OCCURRENCE As a result of NRC inspections conducted during 1993 and 1997, the Electrical Raceway Fire Barrier System (ERFBS) project was established to review the fire resistance rating of various materials which were used to protect the electrical raceways at Salem. One of the fire barrier materials being reviewed by the ERFBS project is the 3M FS-195 fire barrier material. The FS-195 fire barrier material was originally evaluated and selected based on limited testing performed by PSE&G and 3M in accordance with the guidance available at the time of initial testing. Although the test configurations did not bound each configuration installed in the plant, the FS-195 material was believed to provide an adequate one-hour fire barrier rating for the protection of electrical raceways. Until the issue of the qualification of the ERFBS fire wrap material is resolved, PSE&G committed to maintain compensatory measures as described in letter LR-N97320 dated May 19, 1997.

Following the issuance of 10CFR50 Appendix R, fire dampers were required to be installed in various fire barriers throughout Salem. Since the fire dampers were being installed after the ventilation systems were constructed, placing the fire dampers at the opening of the fire barrier was not always possible. As stated in PSE&G's letter NLR-N88070 to the NRC,*dated July 15, 1988, forfire barriers where the fire damper was not installed *in the fire barrier, the ductwork between the fire barrier and the fire damper was wrapped in FS-195 to extend the fire barrier to the fire damper.

During recent testing of the FS-195 material, the fire resistance of the FS-195 material did not meet the one-hour rating for certain electrical raceway fire barrier configurations. A review of the test results in conjunction with the as-installed FS-195 configuration for HVAC duct fire wrap resulted in the conclusion that the fire resistance of the HVAC duct fire barrier extensions is less than expected. The exact fire resistance capability of the installed HVAC fire wrap configurations has not been determined.

Appropriate compensatory actions for HVAC duct fire barrier extensions have been established in accordance with the fire protection program.

NRC FORM 366A (6*1998)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (6-1998)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY l"'.\ME (11 DOCKET (2) LER NUMBER (6) PAGE (3)

NUMBER (2)

SEQUENTIAL IREVISION SALEM UNIT2 05000311 YEAR I NUMBER NUMBER 3 OF 3 98 - 014 -- 00 TEXT (If more space is required, use additional copies of NRC Form 366AJ (17)

CAUSE OF OCCURRENCE.

The cause of this condition is attributed to the level of understanding that existed for the evaluation, testing and installation of the fire barriers at the time the barriers were selected and installed. A contributing cause to the unacceptable evaluation at the time of installation of the fire barriers was the evolution of more stringent requirements for fire protection within the nuclear industry over time.

PRIOR SIMILAR OCCURRENCES A review of LERs for the past three years did not identify any similar occurrences.

SAFETY CONSEQUENCES AND IMPLICATIONS The fire protection program uses defense in depth with multiple levels of protection. The multiple levels of protection include limiting combustibles and ignition sources in plant design, administrative control of transient combustibles and ignition sources, detectors for prompt detection of fires, automatic suppression in areas with high fire loads, fire barriers to provide for the separation and containment of fires, and an on-site fire department which responds and extinguishes fires upon detection. Although the fire resistance of the installed configuration of the FS-195 material was less than expected, this results in a reduction of only one level of fire protection. In addition, HVAC ductwork is constructed of metal and does not contain combustible material. Therefore a fire of significant magnitude would not be expected to occur that would not be detected and extinguished prior to breaching the integrity of the fire barrier. Based on the above there was rio impact to the health and safety of the public.

CORRECTIVE ACTIONS:

1. The affected fire dampers were identified via walkdowns and approprjate compensatory measures were established in accordance with the fire protection program. These compensatory actions will remain in place until the fire barrier wrap issue is resolved for the affected components.

2. To ensure qualified HVAC fire.barriers are installed in the plant either;

• A review of the safe shutdown analysis will be performed to determine if the fire barrier can be eliminated, or

• The fire barrier(s) will be upgraded or replaced as appropriate.

The above actions will be completed as part of the ERFBS project and are consistent with our approach outlined in letter LR-N97357, dated June 6, 1997.

NRC FORM 366A (6-1998)