05000280/LER-1999-002-01, :on 990301,prematurely Released Fire Watches Resulted in Violation of TS 3.21.B.7.Caused by Inadequate Procedure.Procedure for Opening & Sealing Fire Stops Was Revised on 990212

:on 990301,prematurely Released Fire Watches Resulted in Violation of TS 3.21.B.7.Caused by Inadequate Procedure.Procedure for Opening & Sealing Fire Stops Was Revised on 990212

ML18153A274
Person / Time
Site:	Surry
Issue date:	03/29/1999
From:	Grecheck E VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML18153A273	List: 05000280/LER-1999-002, Forwards LER 99-002-00 Per 10CFR50.73.Listed Commitments Contained in Ltr 05000280/LER-1999-002-01, :on 990301,prematurely Released Fire Watches Resulted in Violation of TS 3.21.B.7.Caused by Inadequate Procedure.Procedure for Opening & Sealing Fire Stops Was Revised on 990212
References
LER-99-002-01, LER-99-2-1, NUDOCS 9904060211
Download: ML18153A274 (4)

LER-1999-002, on 990301,prematurely Released Fire Watches Resulted in Violation of TS 3.21.B.7.Caused by Inadequate Procedure.Procedure for Opening & Sealing Fire Stops Was Revised on 990212

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(viii) 10 CFR 50.73(a)(2) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
2801999002R01 - NRC Website

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NRG FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB NO. 3150-0104 (6-1998)

EXPIRES 06/30/2001 Esllmated burden per response 10 comply w,th 1h1s manda!ory mformalion collect1on requesl 50 hrs. Reported lessons teamed are incorporated into the licensing process and led back to industry.

LICENSEE EVENT REPORT (LER)

Forward comments regarding burden es1ima1e lo the Records Managemenl Branch lT -6 F33). U S. Nuclear Regulatory Commission.

Washmglon. DC 20555-0001. and to the Paperv.ork. Reduction Projecl (3150-0104). Ollice ol Management and Budget, Washington. DC (See reverse for required number of digits/characters for each block) 20503. If an inlormalion collection does nol display a currently valid 0MB conirol number. the NRC may no! conducl or sponsor, and a person is not required to respond to, the information collection.

FACILITY NAME (1)

DOCKET NUMBER (2)

PAGE (3)

SURRY POWER STATION, Unit 1 05000 - 280 1 OF 4 TITLE (4)

Prematurely Released Fire Watches Resulted in Violation of TS 3.21.B.7 I EVENT DATE (5}

II LER NUMBER (6)

II REPORT DATE m II OTHER FACILITIES INVOLVED (8}

I SEQUENTIAL REVISION FACILITY NAME DOCUMENT NUMBER MONTH DAY YEAR YEAR MONTH DAY YEAR Surry Power Station, Unit 2 05000-281 NUMBER NUMBER 03 01 99 1999

-- 002 --

00 03 29 99 FACILITY NAME DOCUMENT NUMBER 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)

X 50.73(a)(2)(i) 50.73(a)(2)(viii)

POWER 20.2203(a)(1) 20.2203(a)(3)(i) 50.73(a)(2)(ii}

50. 73(a) (2)(x)

LEVEL (10) 100,;.

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 20.2203(a)(2)(iv) 50.36(c)(2) 50.73(a)(2)(vii) or in NRC Form 366A LICENSEE CONTACT FOR THIS LER (12)

NAME I (;;;)N;;;:;~l;~de wea Code)

E. S. Grecheck, Site Vice President COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE TO EPIX TO EPIX N/A SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MONTH DAY YEAR I YES IX I NO SUBMISSION (If yes, complete EXPECTED SUBMISSION DATE).

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

During a recent 1 OCFR50 Appendix B audit of the Surry Fire Protection Program conducted by the Nuclear Oversight Department, it was observed that the procedure for opening and sealing fire stops allowed the fire watch to be released after an initial inspection, but prior to final inspection and prior to the recommended 24-hour cure time of the silicone foam used. Upon further review, it was recognized that allowing the fire watch to be released prior to completion of the final inspection also constituted a past violation of Technical Specifications. The cause of this situation was an inadequate procedure. The procedure for opening and sealing fire stops has been revised to change the sequence of activities to require the final inspection after the 24-hour cure time and to release the fire watch following satisfactory completion of the final inspection. This situation resulted in no safety consequences or implications and is being reported pursuant to 1 OCFR50.73(a)(2)(i)(B) as a past occurrence of a condition prohibited by Technical Specifications.

9904060211 990329 PDR ADOCK 05000280 s

PDR NRC FORM 366 (6-1998)

e e (6-1998)

FACILITY NAME (1)

Surry Power Station, Unit 1 Surry Power Station, Unit 2 LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION DOCKET 05000 - 280 05000 - 281 TEXT (If more space is required, use additional copies of NRG Form 366A) (17) 1.0 DESCRIPTION OF THE EVENT U.S. NUCLEAR REGULATORY COMMISSION YEAR LEA NUMBER (6)

I SEQUENTIAL. I REVISION NUMBER NUMBER 1999

--002--

00 PAGE (3) 2 OF4 During a recent.1 OCFR50 Appendix B audit of the Surry Fire Protection Program conducted by the Nuclear Oversight Department, it was observed that the procedure for opening and sealing fire stops allowed the fire watch to be released after an initial inspection, but prior to final inspection of the silicone foam used. The procedure required an initial inspection during the curing process and a final inspection after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following foam application; conducting the final inspection after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following foam application is consistent with the manufacturer's recommendation. A station deviation report was issued documenting the release of the fire watch prior to final inspection.

Upon further review, it was recognized that allowing the fire watch to be released prior to the completion of the final inspection also constituted a past violation of Technical Specifications (TSs).

The Surry fire protection TSs were relocated to the UFSAR by TS Amendment 217/217, implemented on February 26, 1999. Previously the Surry TSs required that a fire watch be posted within one hour of one or more fire barrier penetrations becoming non-functional.

Although the TSs did not specify a cure time requirement, the TSs did require that, following repairs or maintenance on an affected fire barrier penetration, a visual inspection and a local leakage test (for barriers performing a pressure sealing function) be performed prior to returning the fire barrier penetration to functional status.

These requirements are now contained in the Surry UFSAR.

The procedure allowed release of the fire watch following an initial visual inspection performed after 15 minutes following application of the silicone foam; the procedure also required a final visual inspection and a local leakage test (if pressure sealing) after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following foam application.

As part of the review related to the Oversight observation, an Engineering assessment of the condition of the silicone foam was conducted and concluded that the foam could not be considered functional after 15 minutes following application.

A review of work orders was conducted to identify where the procedure for opening and sealing fire stops had been used. The review indicated that the procedure had been most recently used in July 1998 during implementation of a design modification for Units 1 and 2 that required penetrations between the Auxiliary Building and the Units 1 and 2 Cable Vaults to be breached for cable installation. The initial visual inspections of the foam applied in the Units 1 and 2 penetrations were performed on July 16, 1998 and July 15, 1998, respectively. Final inspection of the foam in the affected penetrations was conducted with satisfactory results after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following application. Both units were operating at 100% power during July 15 through 17, 1998. A second station deviation report was issued documenting the past TS violation.

This situation is being reported pursuant to 1 OCFR50. 73(a)(2)(i)(B) as a past occurrence of a condition prohibited by TSs.

I e

e l~~RC FORM 366A L6-1998)

U.S. NUCLEAR REGULATORY COMMISSION FACILITY NAME (1)

Surry Power Station, Unit 1 Surry Power Station, Unit 2 LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION DOCKET 05000 - 280 05000 - 281 TEXT (If more space is required, use additional copies of NRG Form 366A) (17)

YEAR 1999

2.0 SIGNIFICANT SAFETY CONSEQUENCES AND IMPLICATIONS

LEA NUMBER (6)

I SEQUENTIAL I REVISION NUMBER NUMBER

--002--

00 PAGE (3) 3 OF 4 This situation resulted in no significant safety consequences or implications. As noted above, an Engineering assessment of the condition of the silicone foam was conducted and concluded that the foam could not be considered functional after 15 minutes following application. This conclusion was based in part on the fact that the 3-hour fire rating of the foam could not be substantiated after 15 minutes following application. However, it is assumed that after 15 minutes following application the foam would have demonstrated some undefined degraded level of functionality.

Final inspection of the foam was conducted with satisfactory results after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following application.

In the event of a fire during implementation of the design modifications cited above, the detection equipment (smoke and heat detection in Cable Vaults and smoke detection in Auxiliary Building) would have alerted the Control Room operators. In turn, the Control Room operators would have notified fire brigade members, who would have promptly responded to extinguish the fire. Until the fire brigade's arrival, it is assumed that the degraded foam would have deterred the passage of flame. In addition, the Cable Vaults are equipped with an automatic CO2 suppression system with sprinkler backup, and there are fire hose stations located in the Auxiliary Building.

These fire detection and suppression systems were operable or otherwise satisfying the (former) TS requirements during the time when the penetrations were breached and for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following foam application. If a fire had occurred in the Cable Vaults or the Auxiliary Building, it would have been promptly detected, reported, deterred from spreading, and extinguished.

Based on the above considerations and because a fire did not occur, the health and safety of the public were not affected.

3.0 CAUSE

The cause of this situation was an inadequate procedure in that the procedure for opening

• and sealing fire stops allowed the fire watch to be released prior to the final inspection required by the TSs, as well as prior to the 24-hour cure time.

Before an April 21, 1994 procedure change, the procedure for opening and sealing fire stops did require that the final inspection be performed after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following application and that the fire watch be released following satisfactory completion of the final inspection. The records associated with the April 21, 1994 change to this procedure indicate the change was made to provide better conformance to the manufacturer's recommendations for inspection; however, no supporting documentation could be located.

Based on recollection by personnel involved at that time, it appears as though the change had been made based on informal information from the manufacturer that was interpreted to mean that the foam could be considered functional in less time than the 24-hour cure time.

II e

e (6-1998)

U.S. NUCLEAR REGULATORY COMMISSION FACILITY NAME (1)

Surry Power Station, Unit 1 Surry Power Station, Unit 2 LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION DOCKET 05000 - 280 05000 - 281 TEXT (If more space is required, use additional copies of NRC Form 366A) (17) 4.0 IMMEDIATE CORRECTIVE ACTION($)

YEAR 1999 LER NUMBER (6)

I SEQUENTIAL I REVISION NUMBER NUMBER

--002--

00 PAGE (3) 4 OF4 As a result of the Nuclear Oversight Audit observation and station deviation report, the procedure for opening and sealing fire stops was revised on February 12, 1 *999. This revision changed the sequence of activities to require final inspection after the 24-hour cure time and to release the fire watch following satisfactory completion of the final inspection.

5.0 ADDITIONAL CORRECTIVE ACTIONS

None.

6.0 ACTIONS TO PREVENT RECURRENCE A review of the procedures used in the repair or maintenance of fire barriers will be conducted to verify that the UFSAR (and former TS) requirements-to restore functionality, as well as the manufacturer's recommendations regarding cure times and inspections, are properly reflected.

7.0* SIMILAR EVENTS t.ER S1-1998-004 Fire Watch Prematurely Released Resulting in Violation of TS 3.21.B.7 - The cause of this event was that the planning of a repair activity (on caulking between a door frame and wall) failed to identify that an approved procedure existed; in this case, the existing procedure for sealing fire stops provided sufficient guidance to perform the repair, including the manufacturer's specified cure time, and released the fire watch following the

• specified cure time.

8.0 MANUFACTURER/MODEL NUMBER Dow Corning 03-6548 Silicone Foam applied using PR855 Semkit (Semco Division of Products Research & Chemical Corporation).

9.0 ADDITIONAL INFORMATION

None.