ML20059E173

Rev 1 to Special Rept 90-10:on 900522,discovered That Stated Cables Not Covered by Fire Detectors or Automatic Fire Suppression Sys,Per 10CFR50,App R & License Condition 2.C.13.c.Caused by Personnel Oversight

ML20059E173
Person / Time
Site:	Sequoyah
Issue date:	08/30/1990
From:	Wallace E TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
90-10, NUDOCS 9009100073
Download: ML20059E173 (5)

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' t TENNESSEE VALLEY-' AUTHORITY T

CHATTANOOGA TENNESSEE 374ol SN 157B Lookout Place AUG 301990 U.S. Nuclear-Regulatory Commission ATTN ' Document-Control-Desk Washington, D.C. 20555 Gentlemen: '

'In the Matter of ) Docket No. 50-328 Tennessee Valley Authority )

SEQUOYAH N!!CLE/ut PLANT.(SQN) UNIT 2 - DOCKET NO. 50-328 - FACILITY OPERATING LICENSE DPR 79 - SPECIAL REPORT 90-10, REVISION 1 - 10 CFR 50 APPENDIX R The enclosed special report provides updated corrective actions related to a:

noncom;11 mace lwith the requirement of, License Condition 2.C.13.c of the Unit 2

~ Facility Gperating License. These updated corrective actions were based upon the~ fire hazards analysis committed to by TVA in the special report dated 1

^ June 5.'1990. The noncompliance condition was oniginally reported in

-accordance with Unit 2 License Condition 2.H.

If'you have any questions conceri.ing this submittal, please telephone M. A. Cooper'at (615) 843-6422.

Very truly yours, TENNESSEE VALLEY AUTHORITY

/ /

. E. G. Wa lace, Manager Nuclear Licensing and-Regulatory Affairs Enclosure-cc: See,page 2 9009100073 900830 ADOCK 0500 8

{DR gg ff U G tJ G J ; II " W An Equal Opportunity Employer [8

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U.S. Nuclear Regulatory Commis6,on p,lJB 301990 cc (Enclosure):

Ms. S. C. Black, Deputy Director Project Directorate 11-4 U.S. Nuclear Regulatory Commission

- One White Flint, North 11555 Rockville Pike Rockville,' Maryland 20852 Mr. J. N. Donohev, Projtet Manager U.S. Nuclear Regulatory commission One White Flint, North 11555 Rockville Pike.

Rockville, Maryland 20852 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry P.oad ,

Soddy Daisy Tennessee 37379 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission i

Region al 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 L

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i ENCLOSURE

. 14-DAY *.OLLOW-UP REPORT SQN SP4CIAL REPORT 90-10 Description of Condition This special report addresses the requirement of License condition 2.C.13.c of the Unit i Facility Operating License regarding compliance with Section 111.0 of 10 CFR 50 Appendix R. This condition is being reported in accordance with the ilnit 2 Licence Condition 2.H and is applicable to Unit 2.

A noncompliance with Unit 2 License Condition 2.C.13.c was identified on May 22, 1990, related to Section III.G.2 of Appendix R. This section stipulates several allowable configurations t ensure that one redundant train of systeits necessary to achieve and maintain hot shutdown conditions is free of fire damage. These allowable configure.tions for catles and equipment include, briefly:

1. Three-hour fire-rated barriers, or

2. Separation by more than 20 feet with no intervening combustible.or fire har.ards, and fire detectors, and an automatic fire suppression system, or

3. One-hour fire-rated barriers, and fire detectors, and an automatic fire suppression system.

During performance of a plant walkdown inspecticn in preparation for an unrelated Unit 2 design modification, it was discovered that cables related to indication of Unit 2 reactor coolant system (RCS) pressure, kCS temperature, pressurizer level, and steam generator pressure located in the area bounded by Column Lines All to A13 and Q to R of auxiliary building Elevation 690 (boric j acid storage tank arcat reference Final Safety Analysis Report, Figure 1.2.3-5) are enclosed in a 1-hour fire-related barrier, but that the area denoted by the above coordinates is not covered by. fire detectors or an-automatic fire suppression system. Therefore, those cables are not in full' cc.apliance with Section 111.0 of Appendix R and, consequently, with Unit 2 License Condition 2.C.13.c.

A condition adverse to quality report was immediately initiated to document the problem and its corrective action. The subject area has been and continues to be included in the surveillance of roving, hourly fire watch pat rol s . Telephone notification to NRC and subsequent confirmation by facsimile were nede in accordance with Unit 2 License Condition 2.H.

Cause of Condition The root cause of this condition has been attributed to an oversight during previous efforts to ensure compliance with Appendix R requirements. It was previously thought that the subject area was covered by fire detection and an automatic fire suopression system. Sketches used during the earlier effort I and a subsequently issued plant drawing indicate that the area is covered.

Investigation into the errors in these drawings could not confirm the reason for the discrepancy.

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t Analysis of Condition There are no plant systems or components considered inoperable or incapable of performing their design functions as a result of the condition described in this report. The affected area is included in the surveillance of hourly, roving fire watch patrols that provide assurance that a fire in this area would be identified so that appropriate response actions could be initiated..

Additionally, the subject area has a very low i.. situ combustible loading.

The area is also regulated by the SQN transient fire load program, which ensures that the area is not arbitrarily used to store combustible material.

bcsed upon walkdowns of the affected area, preliminary indications are that an unmitigated fire would not have sufficient duration to compromise the existing fire wrap during a worst-case fire. IIence, the subject Appendix R circuits protected by the 1-hour fire wrap would not be damaged by such a fire.

Corrective Action Yd As a result of a fire hazards analysis performed by "u:1;;r "n;!n;;;Ing, it has been determined that there are insufficient combustibles in the subject area to pose a significant fire hczard to the 1-hour Underwriters Laboratory rated fire wrapped cables. Because the area does not contain the potential for a fire capable of disabling the cables in their existing configuration, it is concluded that the current cable routing and current 1-hour fire protection are adequate. This condition is considered to be within the scope of an existing NRC-approved SQN Append.ix R deviation.

Deviation 12 approved by NRC's letter dated May 29, 1986, justified noncompliance with 10 CFR 50, Appendix R.Section III.G.2,'.<here a number of rooms or portions of rooms within the auxiliary building were not provided with fire detection and automatic fire suppression. These areas were shown-to contain insignificant levels of combustible fuel, and a fire within any of these areas would be detected by fire detection equipment in adjacent areas within sufficient time to permit fire brigade response and fire extinguishment prior to damage to redundant shutdown trains.

The subject area is similar to the areas described in Deviation 12 in that it is a small portion of Elevation 690 in the auxiliary building without fire detector and automatic fire suppression systems and with a very small amount of in situ combustible fuel. Additionally, the auxiliary building areas surrounding the subject area are provided with fire detectors and automatic fire suppression systems. Therefore, Jased upon the existing deviation (Deviation 12) and the results of the fire hazards analysis, it is concluded that the fire protection features provided for the subject area of this special report afford an acceptable level of protection equivalent to that required by Appendix R,Section III.G.2. Consequently, the existing configuration is deemed acceptable, and no further corrective actions are -

required. The subject area has been under the surveillance of hourly, roving fire watch patrols. Unless notified of additional NRC concerns regarding the subject atea and its disposition in this revised special report. TVA intends to discontinue the fire watch surveillance of the subject area upon completion of the Unit 2 Cycle 4 refueling outage.

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n.- j The review of'sther plant areas containing Append'x_R cables with the 1-hour i 1 ~l fire wrap that.was committed to in'the special repcit d3ted' June 3, 1990,.has ,

L been completed. .This review confirmed that the subject condition of this- j special* report is an isolated deficiency. No other instances were' identified j

'outside.of areas already covered by Deviation 12 where 1-hour wrapped- 't b

' . g" Appendix'R cables-were not protected with the required fire detection and-  ;

automatic fire suppression' systems.

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