ML20077E514

Special Rept 91-03,Rev 1:on 910507,addressed Requirements for Maintaining & Implementing All Provisions of Approved Fire Protection Plan.Commits to Barriers of Specified fire- Rated Durations in Certain Plant Locations

ML20077E514
Person / Time
Site:	Sequoyah
Issue date:	06/07/1991
From:	Wallace E TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
91-03, 91-3, NUDOCS 9106100431
Download: ML20077E514 (8)

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k tennesse vaaev Autwi, iloi Mnu svert cvas,y '. . ewe aw JUN 0 71991 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Author)ty ) 50-328 SEQUOYAll NUCLEAR PLANT (SQN) UNITS 1 AND 2 - DOCKET NOS. 50-327 AND 50-328 - FACILITY OPERATING LICENSES DPh-77 AND 79 - SPECIAL HEPORT 91-03. REVISION 1 - FIRE PROTECTION PLAN The enclosed special report revision provides the results of an investigation concerning noncompliance with tha requirements of License Condition, Section 2.C.13.a. of the Unit 2 Facility Operating License, as committed in the initial special report dated May 7,1991. This report was initially provided in accordance with Unit 2 License Condition 2.M.

The changes from TVA's original response are designated by vertical bars. If you have any questions concerning this submittal, please telephone M. A. Cooper at (615) 843-8422.

Very truly yours.

TENNF3SEE VALLEY AUTil0RITY

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E. G. Wa'11 ace Nuclear Licensing and Regulatory Affairs Enclosure '

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U.S. Nuclear Regulatory Commission JUN 0 71991 cc (Enclosuru):

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

! One White Flint, North l 11555 Rockville Pike Rockville, Maryland 208S2 Mr. D. A. LaBarge, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Marylano 208S2 NRC Resident inspector Sequoyah Nuclear Plant 2600 1rqu Ferry Road Soddy Daisy, Tennessee 31379 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commicslon Region 11 101 Mariettu Street, NW, Suite 2900 Atlanta, Georgia 30323

ENCLOSURE

- 14-Day Follow-Up Report Special Report 91-03, Revision 1 Description of Condition This special report addresses the requirements of Unit $# License Condition 2.C.13.a requiring TVA to maintain and implement all provisions of the approved fire protection plan, which in part, commits to barriers of specified fire-rated durations in certain plant locations. Peripheral areas in the control building within the 3-hour rated fire barrier are required to be separated by 1 1/2-hour fire rated barriers. Cont ary to this requirement, three noncompliances with the above-cited license condition were identifled during a December 1990 walkdown in the area.

1. The design of the plaster wall panel above Door C51 located on Elevation 732 of the control building separating the corridor from the Technical Support Center (TSC) requireu installation of plaster on both faces of the wall extending to the concrete roof. However, the plaster on the corridor side of the wall extends only to the suspended corridor ceiling. Therefore, the as-constructed ( AC) configuration of this wall i does not meet the 1 1/2-bour fire rating requited by TVA's fire protection plan.

2. The design of the ceiling above the NRC of fice and conf erence room adjacent to the Technical Support Center on Elevation 732 of the control building requires installation of two layers of 5/8-inch fire code gypsmn board on top of tue metal deck. These gypsum boards are not installed.

Additionally, two deficiencies were identified in the design configuration of the ceiling. Neither the wood fiber sand planter on the underside of the ceiling nor the use of gypsum board on top of the metal deck meets an Underwriters Laboratory (UL) listed configuration. Therefore, the AC configuration does not meet the fire rating required by the design, and the design of the wall cannot be confirmed to comply with the l 1/2-hour fire rating required by TVA's fire protection plan.

3. The design of a small section of wall located above the NRC conference i room ceiling at the corridor wall separating the corridor from the relay room requires installation of fire code gypsum board on both faces of the wall. However, the gypsum ocard is installed on the corridor sice only, leaving the wall studs exposed above the conference room ceiling.

Therefore, the AC configuration of this wall does not meet the i 1/2-hour fire rating required by TVA's fire protection plan.

A skecch of these areas is provided on the attachment.

Upon discovery of these noncompliances, a roving fire watch through the area was confirmed to be in effect for previously identified breaches. Steps were taken to ensure this area remained in the fire watch route until resolution of the noted discrepancies was implemented. The resolution was added to the scope of the relay room ceiling project, currently in progress.  :

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An evaluation of previously identified fire barrier deficiencies reported in Special Reports 90-06 dated April 23, 1990, and 90-11, Revision 2 dated March 27, 1991, was conducted to determine if the previous corrective action should have identified these deficiencies. The scope of the condition adverse to quality report (CAQR) documenting the conditions reported in Special Report 90-06 addressed design deficiencies with respect to thermal expansion.

Special Report 90-06 requires that a review be performed to identify similar conditions. During this review other deficient design conditions were identified as well as apparent as-built discrepancies reported in Special Report 90-11. The scope of the CAQR was revised to includt these discrepancies; however, the root cause analysis of the CAQR was not revised to

, address the revised scope.

Cause of the Condition These discrepancies resulted f rom weaknesses in the previous SQN design and modification control program and inadequate implementation of that program.

The causes of the implementation inadecuacies could not be determined bec use l these conditions have existed as long as 10 years. The program weaknesses involved design and modification control methods that did not ensura accurate l documentation of plant configuration. Two separate drawing systems were l utilized: AC drawings, which were maintained by the plant, and as-designed I (AD) drawings, which were maintained by Nuclear Engineering (NE). This led to numerous inconsistencies between configuration information and design information. Additionally, the previous design change program issued an entire full-size AD. drawing with the portion of the drawing changed by the modification circled to indicate the work to be performed. After implementation, the construction or Modifications personnel would mark up the urawing to indicate the portions to be AC. Also, the use of the AD drawing to revise the AC drawing (called a wash-off) was a common drafting practice at the time. In this change control program, design changes were not necessurily implemented consecutively; therefore, the AD drawing often differed from the AC drawing by more than the latest design change. If both drawings were not carefully reviewed to identify dif ferences, the AC drawing could be updated without reflecting the actual plant configuration. An additional problem was that under this program, fieldwork was released on a drawing by dr1 wing basis, not as a discrete package and usually over a lengthy time epan, korkplans were frequently put on hold after work began and left on hold for long periods of time. Field changes sometimes remained unincorporated for an extended period of time. These previously identified programmatic problems contributed to the discrepant conditions described in this report.

The omission of plaster on the north face of the wall containing Door C51 (Item 1) resulted from ar inaccurate circling of the change adding the wall.

The AD drawing required plarter to be installed on both faces of the wall, yet only one side was circled to indicate a change; therefote, plaster was installed .a only one side. Revision A of the AC drawing correctly depicted the configuration of the plant. Revision B of the AC drawing appeared to have been a wash off of the AD c awing that was not carefully reviewed. This revision indicated plaster as installed on both sides.

3-The installation cf gypsum board on top of the metal deck above the .',RC of f ice and conference room (Item 2) was correctly depicted on the AC drawing as incomplete. The reason for the incomplete installation could not conclusively be determined but was believed tc be associated with a maintenance concern.

The engineering change notice (ECN) requiring the gypsum board is currently in partially implemented status. Further work on the ECN was " frozen" in the current stage of completion, and the ECN is scheduled to be downscoped and closed before October 1, 1991. The ECN closure process would have discovered and corrected the as-designed and AC discrepancy.

The omission of gypstuu board on the wall separating the relay room from the corridor (Item 3) was not correctly depicted on the AC drawings. This discrepancy also appears to have resulced from the use of a wash off of the AD drawing to create the AC drawing without ensuring it reflected actual plant configuration.

The design deficiencies in the ceiling of the NRC of fice and conferenca roon (Item 2) occurred when this ar:a was added as part of the TSC construction.

Although it was the obvious intent for the ceiling to be a 1 1/2-hour fire barrier, the design did not meet a UL-approved configuration because wood fiber sand plaster is not a tested material and gypsum board is unacceptable for use as a ceiling barrier. The standard engineering procedure at the time of the modification required a cross-disciplinary review by the ' ire protection group for fire barrier modifications. Althcugh no documentation of this review can be found, it is possible that a justification of this configuration was performed by the fire protection engineers based on analysis or a similarity evaluation.

The failure to properly analyze the root cause of the revised scope of the CAQR has been attributed to the involved engineers considering the conditions to be isolated occurrences that were being corrected and procedural raquirements governing the corrective action process that are not specific.

Not documenting the noted discrepancies in a timely manner has been attributed to the failure to realize the importance of timely documentation.

Analysis of Condition The affected areas are included in the surveillance of hourly, roving fire watch patrols. The rosing fire watch patrols, coupled with the existing fire detection and suppression systems in these areas, provide assurance that a fire in these areas would be identified and appropriate response actions

, initiated.

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Corrective Action These discrepancies will be corrected as part of modifications required to ,

correct discrepancies identified by Special Report 90-11, Revision 2, dated March 27, 1991. As stated in Special Report 90-ll, Revision 2, the walls at Fire Doors C57 and C63 in the NRC office and conference room in the Technical Support Center will be replaced with UL-approved material that extends to the concrete ceiling. This modification will eliminate the requirement for the intermediate ceiling in the NRC office and conference room to be fire rated

for compartmentation (Item 2) and will replace the small section of wall at the corridor (Item 3). The plaster wall panel above Door CSI currently extends to the asbestos ceiling that is being removed in this modifiention (1 tem 1). Therefore, the scope of the modification has been increased so include reworking this wall to ensure compliance.

An a result of significant problems identified with the previous design and l nodification control program. SQN developed several major programs that i focused on the resolution of AC/AD problems. However, the scope of thesc l programs did no' include firewalls. The Design Basis and Verification Program included a walkdown and field verification for systems required to mitigate FSAR Chapter 15, *'ecident Analysis," accidents and provide for safe shutdown. PartLil4y implemented engineering changes were also reviewed to detern.ine if full implementation was required for unit restart. If a problem was identified that could potentially impact the ability of the safe shutdown systems to perform their functions, modifications were implemented.

Other major programs implemented during this period included the following:

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- Environmental Qualification Program - Field verification of installed j 10 CFR 50.49 devices.

- Cable Tray Support Program - Field structural as built and tray loading verification.

- Alternately Analyzed Piping Program - Field walkdown and verification of small bore piping and pipe supports.

- Appendix R Program - Field inspection of fire doors, separation requirements, and sprinkler coverage.

- Welding Program - Field inspection of 333 safety-related piping welds, 15 heating, venting, and air conditioning welds, and 403 structural welds.

- Sense Line Program - Field inspection of Class IE lines required to operate during and after a design basis accident.

14 Program - Field walkdown and verification of large bore pipe supports.

- Miscellaneous Programs - Field configuration verifications were performed for numerous CAQRs, employee concerns, and open techniccl concerns.

The summed total of these programs provides a high degree of confidence that significant problems do not exist as a result of possible errors la the AC drawing, discrepancies between the AC and AD drawings, and error, in design documentation, except as noted for fire walls.

Finally, the ongoing ECN closure program, scheduled for complecion in October 1991, effectively closes out the "old" change control process and eliminates the partially implemented ECNs, which will eliminate potential problems.

To prevent recurrence of problems related to discrepancies between AC and AD information, SQN implemented a design and modification control program based on INP0 Good Practice Guidelines. Features of this program include:

- Each engineering change is issued as a single, stand-alone package with complete change information included.

- Changes are released in sufficiently small blocks of work to enable implementation, return to operation, and closure within a reasonably short period of time.

- Small, discrete change sheets are issued for each work item rather than the former system of circling details on a larger print containing numerous other details and information.

- AC drawi tgs are no longer developed by the Modifications organization.

Change snects are posted against the base drawing and a single configuration control drawing is prepared by NE after one change sheet is posted for primary drawings and five changes for secondary drawings.

As a result of the multiple concerns identified related to fire barriers, extensive corrective actions are being implemented in this area. An inspection of nonmasonry, nonmetallic fire barriers will be performed to identify discrepancies between the as-built configuration and as-designed requirements. Additionally, a field verification of a sample of masonry and metallic fire barriers will be conducted. The results of these walkdowns will be utilized in a design evaluation to demonstrate the walls heve the required fire rating.

To ensure adequate root cause analyses are performed on revised corrective action documents, the appropriate site procedure governing the corrective action process wA11 be revised to clarify and enhance the requirements relative to revising corrective action documents. Additionally, the Site Quality organization ht added an attribute to the audit plan for an upcoming audit to evaluate a sample of revised CAQRs to determine whether the cause analyses and extent of the conditions are adequately assessed.

The individuals involved in the untimely documentation of these discrepancies have been made aware of the importance of promptly documenting deficiencias.

The Site Quality organization has also added an attribute for the upcoming audit to assess if problems are being promptly documented in accordance with TVA's corrective action program.

Connii tment s

1. The walls at Fire Doors C57 and C63 in the NRC office and conference room in the TSC will be replaced with UL-approved material that extends to the concrete ceiling by October 1,1991 (previous commitment in Special Report 90-11, Revision 2).

2. The plaster wall panel above Door C51 will be reworked by October 1,1991.

3. An inspection of nonmasonry, nonmetallic fire barriers will be performea to identify discrepancies between the as-ouilt configuration and as-designed requirements by August 19, 1991.

4. A field verification of a sample of masonry and metallic fire barriers will be conducted by August 19, 1991.

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5. The results of these walkdowns will be utilized in a design evaluation to demonstrate the walls have the required fire rating by October 7, 1991.

6. To er.sure adequate root cause analyses are performed on revised corrective action documents, the appropriate site procedure governing the corrective action process will be revised to clarify and enhance the requirements relative to revising corrective action documents by July 15, 1991.

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