ML20036B048

Notice of Violation from Insp on 930217-25.Violation Noted: Fire Barriers Designed to Separate Equipment in Redundant Trains of Sys Necessary to Maintain Hot Shutdown Have Been Deficient Since Original Installation in 1979

ML20036B048
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	05/13/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20036B044	List: ML20036B043 ML20036B048
References
50-271-93-05, 50-271-93-5, NUDOCS 9305180104
Download: ML20036B048 (37)

Text

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APPENDIX A i

NOTICE OF VIOLATION Vermont Yankee Nuclear Power Corporation Docket No. 50-271 Vermont Yankee Nuclear Power Plant License No. DPR-28 j

During an NRC inspection conducted between February 17 - 25, 1993, and, based on subsequent information obtained in an enforcement conference on April 21,1993, 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 1

are listed below:

A.

10 CFR 50, Appendix R, Paragraph III.G.2 requires, in part, that cables and equipment of redundant trains of systems necessary to maintain hot shutdown condition, located within the same fire area outside the primary containment must be l

... separated by a three hour fire barrier...

Further, Vermont Yankee Technical Specification Limiting Conditions for Operation 3.13.E.1 states, "... vital fire barrier seals protecting the Reactor Building, Control Room Building, and Diesel Generator Rooms shall be intact."

i Contrary to the above, as of April 21,1993, certain three hour fire barriers designed to separate equipment in redundant trains of systems necessary to maintain hot shutdown, including vital fire barriers protecting the reactor building, control room building, and the diesel generator rooms have been deficient since their original installation in 1979 and 1980. Specifically, numerous fire barrier penetration seals located in these barriers were not intact or were otherwise degraded due to: (1) inadequate depth of penetration fill material; (2) unqualified fill material; (3) installation of unqualified designs; and (4) through wall cracking of fire barriers.

7 This is a Severity Level IV Violation (Supplement 1) l B.

Technical Specification Section 4.13.E.1, requires that, " vital fire bamer penetration seals shall be verified to be functional by visual inspection at least once per operating cycle and following any repair.'

Contrary to the above, since 1979/1980 and continuing until December 1992, the inspection conducted at least once per operating cycle to verify vital fire barrier penetration seals were functional was inadequate in that it did not define an acceptable method or provide inspection direction sufficient to verify the adequacy of the penetrations, as evidenced by the following:

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Operating Procedure (OP) 4019, " Surveillance of Vital Barriers" in use prior to February 1993, lacked specific accept / reject criteria.

9305180104 930513 PDR ADOCK 05000271 0

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1 Appendix A 2

Inspections conducted from 1980 until December 1992 failed to identify e

that numerous vital fire barrier penetrations were not functional due to various deficiencies and degradations.

i This is a Seventy Level IV Violation (Supplement 1)

Pursuant to the provisions of 10 CFR 2.201, Vermont Yankee Nuclear Power Corporation is hereby required to submit a written rtatement or explanation to the U.S. Nuclear Regulatory Commission, A*ITN: 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 will be taken to avoid further violations; and (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information 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 will be given to extending the response time.

Under authority of Section 182 of the Act,42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

l Dated at:

King of Prussia. PA.

I this/fday of 4/4f1993.

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i ATTACIIMENT 1 i

PERSONNEL ATTENDING THE ENFORCEMENT CONFERENCE Vermont Yankee Nuclear Power Corporation 5

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Name Position t

J. Pelletier Vice President, Engineering j

B. Buteau Engineering Director

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J. DeVincentis Technical Programs Supervisor j

S. Lucas Fire Protection Coordinator l

A. Klein YNSD Fire Protection Engineer A. Parker YNSD Audit Group Supervisor E. Sawyer Fire Protection Consultant I

State Of Vermont

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i W. Sherman Nuclear Engineer j

U.S. Nuclear Reeulatory Commission M. Banerjee Senior Enforcement Specialist, Region 1 L. Bettenhausen Operations Branch, Chief, DRS, Region 1 i

D. Dorman Project Manager, NRR H. Eichenholz Senior Resident Inspector, Vermont Yankee, Region 1 A. Finkel Senior Reactor Engineer, PPS, Region 1 i

P. Harris Resident Inspector, Vermont Yankee, Region 1 M. Hodges Director, Division of Reactor Safety, Region 1 J. Linville Projects Branch No. 3, Chief, DRP, Region 1 R. Rasmussen Reactor Engineer, RPS 3B, Region 1 K. Smith Regional Counsel, Region 1 f

B. Whitacre Reactor Engineer, DRP, Region 1 l

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ATTACIL%fENT 2 LICENSEE RESPONSE PRESENTED AT THE ENFORCEMENT CONFERENCE l

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l VERMONT YANKEE FIRE BARRIER EFFORT 04/21/93 SUmiARY l

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INTRODUCTION (BRB) l h

II.

APPARENT VIOLATION #1 (DID)

(BARRIER INTEGRITY ISSUES)

IIL APPARENT VIOLATION #2 (DID)

(SURVEILLANCE ISSUES)

IV.

APPARENT VIOLATION #3 (EAS)

(SENSITIVTTY TESTING ISSUES)

V.

AUDIT PROGRAM ISSUES (ADP)

I VI.

CLOSING REEUtKS (BRB) i l

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i SPEAKERS INTRODUCTION B.BUTEAU ADDRESS APPARENT VIOLATION 93-05-01 J. DEVINCENTIS

... Fire barrier penetration seals were not intact and therefore did not meet Tech Spec Section 3.13.E.1 for 13 years" ADDRESS APPARENT VIOLATION 93-05-02 J. DEVINCENTIS 3

... Failure to verify the functionality, as exhibited by existence of f

deficiencies in fire barrier penetration seals for the typ of installed penetrations for 13 years" ADDRESS APPARENT VIOLATION 93-05-03 E. SA%TER

... Failure to demonstrate the operability of the smoke detector system..."

ADDRESS AUDIT PROGRAM COMAENTS A. PARKER "The audit did not identify that the fire barrier penetration seals were nonconforming and the smoke detectors were not verified to be operable. This was a missed opportunity..."

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CONCLUDING REMARKS B.BLTEAU I

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Hours Wor <ec Against P.C. 9268 34473 35000-32046

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i March '92 June '92 December '92 December 23 December 29 May '93 Intake CAR Work begins Fire watches Task Force All Fire Structure Iteconunends early on posted at all initiated Ilarrier and Problem ID'd installation of insulated pipesc TS/ App R Fire pes;cntratons removable Insulation llarrier pens (App II/TS/A) insulation to removal.

inspected, allow Any deficiency inspection of ID'd and insulated pipe repaired.

fire barrier seals at September '93 outage.

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4 DISCUSSIONS ON APPARENT VIOLATIONS I

CORRECTIVE ACTIONS TO ADDRESS BARRIER ISSLES i

IDENTIFICATION OF EVENT INVESTIGATION CAUSES CORRECTIVE ACTIONS SAFETY SIGNIFICANCE SUhBIARY METHODS FOR PERFORMING TECH SPEC SURVEILLANCES INVESTIGATION CAUSES CORRECTIVE ACTIONS SAFETY SIGNIFICANCE

SUMMARY

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i APPARENT VIOLATION #1 (BARRIERS NOT INTACT PER TS 3.13.E.1)

APPARENT VIOLATION OF TECH SPEC 3.13.E.1 WHICH REQUIRES... " VITAL FIRE BARRIER PENETRATION SEALS PROTECTING THE REACTOR BUILDING, CONTROL ROOM BUILDING AND DESEL GENERATOR ROOMS SHALL BE INTACT."

BARRIER CLASSIFICATION BRE,EDOWN 77 TOTAL BARRIERS L

43 TECH SPEC (RX

BLDG, CONTROL BLDG, DG ROOMS) 10 APPENDIX R (SEPARATE SAFE SHUTDOWN EQUIP.\\EhT) 24 APPENDIX A TO BTP 9.5-1 4

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CORRECTIVE ACTIONS TO ADDRESS BARRERISSUES i

IDENTIFICATION OF EVENT RECOADIENDED ENHANCDENT TO PROVIDE RDIOVABLE INSULATION AIADE AS PART OF THE FIRE PROTECTION PROGRAM IMPROVENENT PLAN DUE TO FINDINGS BEHIND j

INSULATED LIhTS I

IDENTIFICATION OF ADDITIONAL PENETRATION PROBLEMS DURING INSULATION REPLACENENT EFFORT NOTIFICATION OF RESIDENT INSPECTOR t

NOTIFICATION OF INDUSTRY VIA NUCLEAR NETWORK TASK FORCE INGEDIATELY FORSED - VP ENGINTERING LEAD S

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4 INVESTIGATION INCLUDED i

t REVEW OF 1979 DESIGN AND INSTALLATION PACKAGE REVIEW OF NRC AND ANI CORRESPONDENCE REVIEW OF SUBSEQUENT MAINTENANCE ACTIVITES AS-BUILTS WERE GENERATED AND COMPARED TO DESIGN REQUIREAENTS INTERVEWS WITH COGNIZANT DESIGN AND INSTALLATION PERSONNEL INVOLVED IN 1979 EFFORT INTERVEWS WITH EX-CHEN1 TROL QC SUPERVISOR ASSESSAENT OF LEVEL OF CONTRACTOR OVERSIGHT f

PROVIDED (FULL TIAE PERSON ASSIGhTD TO PROVIDE OVERSIGHT)

ASSESSNENT OF QUALITY OVERSIGHT OF CONTRACTOR (SURVEILLANCE WAS PERFORAED)

SEARCH FOR QC INSPECTOR REVEW OF DESIGN AND MOD 6ICATION CONTROL PROCESSES 1979 AND PRESENT INTERVIEWS WITH VARIOUS ENGINEERING AhT MAINTENANCE PERSOhWEL DISCUSSIONS WITH INDUSTRY EXPERTS i

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INVESTIGATION REVEALED INSULATION NOT REMOVED DUE TO AN ASSUMPTION THAT INSULATION PROVIDED ADEQUATE PROTECTION INADEQUATE GROUT DEITH DUE TO AN ASSUMPTION THAT GROUT TIGHT TO PIPE IS SUFFICIENT TO FORM A FIRE 1

BARRIER (DEPTH WAS NOT VERIFIED)

ASSUMPTIONS WERE NOT ADEQUATELY DOCUMEFTED IN DESIGN DOCUMENT FOR INDEPENDENT REVIEW i

PENTTRATION SEALS THAT WERE NOT IN COMPLETE CONFORMANCE WITH DESIGN REQUIREMENTS, (INADEQUATE FOAM DEPTH)

" BOOT" OPTION WAS NOT SELECTED FOR LINTS WITH LARGE DISPLACEMENTS INCONSISTENCIES BETWEEN AS-BUILT INFORMATION AND QC DOCUMENTATION LACE OF AWARENESS OF FIRE BARRIER REQUIRDIENTS i

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t PRBIARY CAUSES OF IDEN11titD BARRIER PROBLEMS INADEQUATE DOCUMENTATION OF ASSUMPTIONS DURING DESIGN SCOPING EFFORT l

i EXPECTATION THAT INSTAIIID CONFIGURATION MEETS TESTED CONFIGURATION / TYPICAL WAS NOT STRESSED (INADEQUATE FOAM DEY111)

HUMAN ERROR (BOOTS NOT USED WHEN LARGE DISPLACEMENTS WERE PRESENT)

FAILURE TO FOLLOW QC PROCEDURES (CHEMTROL QC INSPECTOR)

QUALITY OVERSIGHT OF CONTRACTOR WAS NOT SPECIFIC ENOUGH TO DETECT WEAKNESSES HUMAN FACTORS (TRAINING AhT LABELING) 4 h

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t CORRECTIVE ACTIONS COMPLETED OR PLANNED I

r DESIGN CHANGE HAS BEEN GENERATED TO ADDRESS ALL i

INSULATED LINES AND OTHERS WHERE AN APPROVED DESIGN DID NOT EXIST - WORK IS COMPLETE l

ENHANCED SURVEILLANCE ON ALL

~ BARRERS/ PENETRATIONS PERFORhED %TTH SPECIFIC CRITERLt BASED ON PENETRATION TYPE HAS BEEN PERFORSED-UPGRADES IN PROCESS DESIGN CONTROL IMPROVEMENTS PLANNED INCLUDE IMPROVED DOCL3ENTATION OF ASSL31PTIONS DLRING

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SCOPING OF DESIGNS c

CONSIDERATION OF PENETRATION DESIGN AS A

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DESIGN INPUT VS FIELD CONSIDERATION ADDITIONAL EMPHASIS ON ENSURING DESIGN DETAILS l

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t SATISFY TEST REPORT CONFIGURATIONS SEAL INSTALLATION PROCEDURES TO PROVIDE ALL

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ACCEITABLE ALTERNATIVES AN ASSESSAENT. OF HOW QUALITY OVERSIGHT IS PERFORSED ON CONTRACTOR SERVICES IS PLANNED ENHANCED GENERAL EMPLOYEE TRAINING ON FIRE BARRIER REQUIRENENTS TO IMPROVE AWARENESS IS PLANNED

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1 huh 1AN FACTORS FT.D LABELING EFFORT PLANNED

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PROCEDURE CHANGES TO PROVIDE LISTINGS (TS /

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APP R/ APP A) COMPLETED i

PROCEDURE CROSS REFERENCING BIPROVEAENTS

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PLANNED FOLLOW-UP VERIFICATION BEING PERFORhED TO ASSESS EFFECTIVENESS OF CORRECTIVE ACTIONS SAFETY SIGNIFICANCE WrrH FEW EXCtYi10NS PENETRATIONS HAD FIRE

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RESISTANT CAPABILITIES SAFETY ASSESSAIENT BEING PERFORSED BASED ON AS-i

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FOUND CONDITIONS FOCUS OF ASSESSAENT ON BARRERS THAT COULD

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SIPACT SAFE SHUTDOWN CAPABILITIES (TECH SPEC AND APPENDIX R BARRERS)

PRELBIINARY ASSESSNEhT REVEALS NO SIPACT ON

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ABILITY TO SHUTDOWN THE PLANT DUE TO AS-FOUND CONDITIONS FIRE PROTECTION PROGRAM OBJECTIVES TO USE A

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DEFENSE IN-DEPTH APPROACH TO MINIhfIZING THE BIPACT OF FIRE EVENTS TO ENSURE THAT THE REACTOR CAN BE SAFELY SHUTDOWN WAS AET

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BfMEDIATE ACTIONS WERE TAKEN TO ADDRESS THE t

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ISSUE VIA FORMATION OF A TASK FORCE 1

A COMPREHENSIVE INVESTIGATION WAS PERFORMED l

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TO EVALUATE THE ISSUES AGGRESSIVE CORRECTIVE ACTIONS HAVE EITHER t

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METHODS FOR PERFORMING TECH SPEC SURVEILLANCES INVESTIGATION CAUSES CORRECTIVE ACTIONS i

SAFETY SIGNIFICANCE i

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E (SURVEILLANCE PRACTICES)

APPARENT VIOLATION OF TECH SPEC SECTION 4.13.E.1 WHICH REQUDLES..." VITAL FIRE BARRIER PENETRATION SEALS SHALL BE VERIFIED FUNCTIONAL BY VISUAL INSPECTION AT LEAST ONCE PER OPERATING CYCLE".

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43 TECH SPEC i

10 APPENDIX R (SEPARATE 2 FIRE AREAS) 5 24 APPENDIX A TO BTP 9.5-1 VY CURRENTLY PERFORMS INSPECTION OF ALL PENETRATIONS EACH REFUELING CYCLE (18 MONTHS) 4 PICTURES TAKEN OF PENETRATIONS IN 1989 t

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VISUAL t

INSPECTION FROM BOTH SIDES TYPICALLY WITHOLT f

TH. E USE OF LADDERS OR SCAFFOLDING f

ACCEPTANCE CRITERIA INCLUDED GENERAL VISUAL ACCEPTANCE CRITERIA (CRACKS, LOOSE OR MISSING

MATERIAL, ETC)

AS WELL AS ADDITIONAL ACCEPTANCE CRITERIA BY REFERENCE TO CHEMTROL

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PRODUCT LITERATOM VISUAL INSPECTIONS DID NOT INVOLVE DESTRUCTIVELY LOOKING AT INTERNAL SEAL i

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SISBfARY OF INVESTIGATION FOCUSED ON SURVEILLANCE SETHODS AND OTHER ADNIINISTRATIVE BARRERS AVAILABLE TO DETECT CONDITION i

I INVESTIGATION INCLLTED REVIEW OF THE 1979 SEAL DESIGN CRITERIA FOR VISUAL SURVEILLANCE ATTRIBLTES l

l REVIEW OF PAST SURVEILLANCE PRACTICES

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IMPROVE 5ENTS SEETCHES ADDED TO THE PROCEDURE

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PICTURES OF EACH SEAL TAKEN IN 1989

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INSPECTION CRITERIA BY REFERENCE TO

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VENDOR INFORNIATION REVIEW OF PAST SURVEILLANCE RESL1TS 1979 TO PRESENT AND INTERVIEWS WITH PERSONNEL THAT PERFOR5ED PAST i

SURVFULANCE ACTIVITIES TO DISCUSS SETHODOLOGY REVIEW OF QA SURVEILLANCE PERFORSED ON 1979 SEALING EFFORT Ah3 INTERVEWS WITH PERSOhhTT 12AT PERFOR5ED THE SURVERLANCE REVEW OF MAINTENANCE RECORDS TO IDENTIFY BARRER i

REPAIR EFFORTS REVIEW OF OPERATING EXPERENCE PRACTICES

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/DOCU5ENTS (INFO NOTICES 88-04/88-56)

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INVESTIGATION REVEALED i

PAST VISUAL SURVEILLANCE NETHODOLOGY DID NOT l

IDENTIFY THE ITEMS IDEN11ntD DURING THE ENHANCED TNSPECTION 1

BARRER DEFICENCES WERE NOT IDEN1111ED (CRACKS IN BLOCK WAIJ S)

PREVIOUS VISUAL ACCEPTANCE CRITERIA WAS GENERAL

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AND NOT SPECIFIC TO APPROVED PENETRATION TYPES AND DESIGNS l

%TrH FEW EXCtr110NS DEFICENCES WERE " HIDDEN" FROM VISUAL EXAMINATION APPROACH THAT WAS EMPLOYED l

VY'S RESPONSES TO OPERATING EXPERENCE DOCUAENTS WAS PRUDENT AND REASONABLE AT THE TIhE. THE ASSESSMENT INCLUDED:

REVEW OF 1979 DESIGN / IMPLEMENTATION

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INFORMATION AND DOCUAENTATION REVEW OF HISTORICAL EXPERENCE AND l

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PRIMARY CAUSES THAT CONTRIBUTED TO NOT IDENTIFYING THE CONDITIONS DURING PAST SURVEILLANCE i

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LACK'OF SPECIFIC VISUAL ACCEPTANCE cMRIA (BASED ON DESIGN. DETAILS) IN THE SURVETTLANCE PROCEDURE CONTRIBUTED TO SOME ITEMS NOT BEING IDEN 11FIED -

l INADEQUATE DIRECTION TO INSPECTION PERSONNEL-ON -

WHAT CONSmtfit,S AN ACCEPTABLE SURVETTIANCE. AS A i

RESULT INSPECTION PERSONNEL - WERE FOCUSED ON PENETRATION INSPECTIONS AND FAILED TO PERFORM AN ADEQUATE INSPECTION OF THE OVERALL BARRIER LACK OF DIRECTION TO PERFORM INSPECTION ON BARRIER ITSELF CONTRIBUTED TO OTHERS (BLOCK WALL CRACKS) i

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CORRECTIVE ACTIONS ENHANGD CRITERIA DEVELOPED BASED ON PENETRATION TYPE AND CRITICAL DESIGN REQUIRENENTS i

ENHANGD TRAINING REQUIRENIENTS FOR INSPECTION I

PERSONNEL DAAINIING REMOVED FOR INTERNAL INSPECTION

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l MEASUREAENT DURING ENHANCED INSPECTION i

1 ENHANCED SURVEILLANCE ON ALL 77 BARRERS j

PERFORAED ADDITIONAL QUALITY OVERSIGHT OF FUTURE l

SURVEILLANCE ACTIVITIES PLANNED f

ASSESSNENT OF THE ACGPTANCE CRITERIA CONTAINED IN OTHER SURVEILLANCE PROCEDURES THAT USE A VISUAL i

EXAMINATION APPROACH IS PLANNED ~

ADDITIONAL FOCUS PLAGD ON PERFORMING FELD VERIFICATION IN SUPPORT OF POSITIONS TAKEN DURING l

REVEWS ON OPERATING EXPERIENCE DOCUMENTS l

1 FUTURE INSPECTION -APPROACH W'S'G DISCUSSED.

I RECOGNIZE THAT FUTURE INSPECTi(HS NEED TO BE i

SIMILAR TO THE ENHANGD NETHODOLOGY.

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i FIRE PROTECTION' PROGRAM OBJECTIVES TO USE A l

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IMPACT OF FIRE EVENTS TO ENSURE THAT THE REACTOR CAN BE SAFELY SHUTDOWN WAS AET I

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SU3BIARY SELF IDENinitu DURING BIPLEAENTATION OF AN

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BIPROVE3ENT IN THE FIRE PROTECTION WITH FEW EXCEY110NS THE ITEMS IDEN1n 1ED WOULD

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NOT HAVE BEEN IDEN In1ED UNDER A NORNIAL VISUAL INSPECTION 3ETHODOLOGY INDUSTRY /NRC WERE BBEDIATELY NOTIFIED AhT

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UPDATED BBEDIATE ACTIONS WERE TAEEN TO ADDRESS THE

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ISSUE VIA FORMATION OF A TASK FORCE A COMPREHENSIVE INTESTIGATION WAS PERFORAED

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TO EVALUATE THE ISSUES AGGRESSIVE CORRECTIVE ACTIONS HAVE EITHER

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NUCLEAR POWER STATION s

Apparent Violation f

Failure to demonstrate the operability of the j

smoke detection system Technical Specification 4.13.A.1; Fire Detection Each of the sensors specified in 3.13.A.1 and their associated instruments including the supervisory circuitry shall be i

demonstrated operable at least once per 6 months l

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VERMONT YANKER i

NUCLEAR POWER STATION i

r License Amendment No. 43; January 13, 1978:

l Appendix A Safety Evaluation Report:

Section 3.1.1 l

Bench Tests will be conducted to verify that smoke detectors will provide prompt response and have adequate sensitivity to the Products of Combustion for the l

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combustibles in the area where smoke detectors are installed.

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k VERMONT YANKEE NUCLEAR POWER STATION Vermont Yankee performed sensitivity testing on all smoke detectors upon installation.

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VERMONT YANKEE NUCLEAR POWER STATION OP

4339, Rev.

2,

" Surveillance of Fire Protection Detectors" Requires:

Visual Inspection Detector Actuation Circuit Continuity Check

• e 9

b.

2 i

VERMONT YANKEE NUCLEAR POWER STATION i

r e

iti g to be andat to prove detector operability.

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VERMONT YANKEE l

NUCLEAR POWER STATION By doing a sensitivity test upon installation, and by performing the visual inspection, detector actuation tests, and circuit continuity checks 1

included in OP 4339, Rev. 2, " Surveillance of Fire Protection Detectors," Vermont Yankee believed that this surveillance met the intent of l

requirements of Tech Spec 4.13.A.1 l

l l

l 1

VERMONT YANKFR NUCLEAR POWER STATION Based on NRC's questions regarding sensitivity testing i

Vermont Yankee has:

i Surveyed other utilities to determine how sensitivity testing is performed I

Variety of approaches

=

Some question as to its usefulness

=

t Did sensitivity testing of a small sample of

)

VY detectors i

Sensitivity of all detectors found to be l

=

satisfactory i

Vermont Yankee'will be:

{

i Continuing to investigate what the industry is doing

~

Looking further at how sens.itivity testing is i

r.,_

F AUDIT PROGRAM ISSUES j

i "The audit did not identify that the fire barrier penetration j

seals were nonconforming and the smoke detectors were not i

verified to be operable. This was a missed opportunity by the quality assurance audit program."

The Fire Program Audit Meets Criteria of Generic Letter 82-21 i

Scope of the Audit 1

Make-up and Qualifications of the Audit Team I

Audit Methods are Consistent with Other Utilities i

Plant Walkdown and Visual Inspection Techniques Sample Approach j

Examination of Records of Fire Activities Witnessing Fire Activities, When Possible j

6 Audits have Identified Legitimate Findings l

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Opportimity and Ease of Discoverv Conditions were not Obviously Visible i

Required Application ofIndirect Inspection Techniques i

Application of NFPA Codes (Detector Sensitivity) l Indication of Problem Existed i

Original Design and Inst 211ntion Assumed Correct j

Routine Plant Inspection did not Indicate a Problem f

Fire Audit Program Enhancements Integration of QA Surveillance and Audits l

Changed Focus using Vertical Slice Method j

I 4

.i

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