ML20149H782

Special Rept:On 941129,discovered That Selective Licensee Commitment (SLC) for Visual Insp of Fire Rated Assemblies Exceeded Due to Misinterpretation of Requirements of SLC 16.9-5.Fire Barriers Visually Inspected

ML20149H782
Person / Time
Site:	Catawba
Issue date:	12/20/1994
From:	Rehn D DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9412290259
Download: ML20149H782 (6)

Text

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, ll l Duke Ibwer Cornpany (803)831-3000 Catawba Nuclear Station 4800 Concord Road M. sc2971s DUKEPOWER December 20,1994 Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Catawba Nuclear Station Docket No. 50-413 and 50-414 Special Report Gentlemen:

Attached is a Special Report concerning a SELECTIVE LICENSEE COMMITMENT SURVEILLANCE FOR VISUAL INSPECTION OF FIRE RATED ASSEMBLIES EXCEEDED.

This event was considered to be of no significance with respect to the health and safety of the public.

Very truly yours, D. L. Rehn xc: Mr. S. D. Ebneter Marsh & McLennan Nuclear Regional Administrator, Region II 1166 Avenue of the Americas U. S. Nuclear Regulatory Commission New York, NY 10036-2774 101 Marietta Street, NW, Suite 2900 Atlanta, GA 30323 Mr. R. E. Martin INPO Records Center U. S. Nuclear Regulatory Commission Suite 1500 Office of Nuclear Reactor Regulation 1100 Circle 75 Parkway Washington, D.C. 20555 Atlanta, GA 30339 Mr. R. J. Freudenberger NRC Resident Inspector Catawba Nuclear Station 9412290259 941220 PDR ADOCK 05000413 S PDR p/

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U. S. Nuclear Regulatory Commission .,

December 20,1994 Page Two bxc: M. S. Tuckman - EC07H B. L. Walsh - EC11C C. A. Paton - PB02L A. V. Can - PB05E B. J. Horsley - EC12T T. E. Mooney - EC090 G. H. Savage - EC061 NSRB Staff - EC05N NC MPA-1 NCEMC PMPA SREC J. W. Glenn (PIP File) - CN05SR (with Enclosures)

K. E. Nicholson (Reg. Compl.) - CN01RC (with Enclosures)

SRG - CN05SR (with Enclosures)

Electronic Library - EC050 (with Enclosures)

Master File - CN02DC CN-815.04 (with Enclosures) l l

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l DUKE POWER COMPANY

! CATAWBA NUCLEAR STATION DOCKET NUMBERS 50-413 and 50-414 SPECIAL REPORT SELECTIVE LICENSEE COMMITMENT SURVEILLANCE FOR VISUAL INSPECTION OF FIRE RATED ASSEMBLIES EXCEEDED ABSTRACT This Special Report is being submitted to document exceeding the surveillance interval for .

Selected Licensee Commitment (SLC) 16.9-5 (a)(i). This SLC is part of the Catawba Fire Protection Program and therefore subject to the provision of the Catawba Facility Operating License Conditions C.(8) for NPF-35 (Unit 1) and C.(6) for NFP-52 (Unit 2). On November 29,1994, at 0930 hours0.0108 days <br />0.258 hours <br />0.00154 weeks <br />3.53865e-4 months <br />, with Units 1 and 2 in Mode 1, Power Operation, at 100% power, the Station Fire Protection Engineer discovered that the visual inspection of fire rated assemblies per the requirements of SLC 16.9-5 (a)(i) had exceeded the specified surveillance interval. The visual inspection was required to be performed no later than September 12,1994. The fire rated assemblies were immediately declared inoperable and visual inspections commenced. All fire rated assemblies were determined to meet the applicable acceptance criteria and were declared operable at 1540 hours0.0178 days <br />0.428 hours <br />0.00255 weeks <br />5.8597e-4 months <br /> on November 29. This event is attributed to Document Use Practices.

During a 1992 review of SLC 16.9-5, Engineering personnel interpreted that by fulfilling'the requirements of SLC 16.9-5 (a)(ii) and (a)(iii) that the requirements of(a)(i) would be met. Due

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to this misinterpretation, Model Work Order 91004925 was deleted. This Model Work Order had been used to schedule the visual inspection of fire rated assemblies per SLC 16.9-5 (a)(i).

Completed corrective actions include the performance of visual inspections of fire rated t assemblies and the initiation of Model Work Order 94089298 to schedule future visual inspections of fire rated assemblies. Planned corrective actions include a review of all SLC 16.9, Fire Protection Systems, surveillance requirements to ensure that all fire protection requirements are being met and a review of SLC 16.9-5 to determine if revision is necessary to clarify the wording to ensure that future misinterpretations do not occur.

BACKGROUNQ SLC 16.9-5, Fire Barrier Penetrations, states that all fire barriers (walls, floor / ceilings, cable tray enclosures and other fire barriers) and all sealing devices in fire barrier penetrations (fire doors, fire dampers, cable, pipe and ventilation duct penetration seals) separating;

• Safety from non-safety related areas or, a Redundant analyzed Post Fire Safe Shutdown Equipment or,

• Control Complex (Control Room, Cable Rooms, and Battery Rooms) from the remainder of the plant or,

• Containment from non-containment areas, shall be OPERABLE. This requirement is applicable at all times.

. 4 DUKE POWER COMPANY CATAWBA NUCLEAR STATION PIP 0-C94-1691 PAGE 2 of 4 Per Section (a) of the Testing Requirements, at least once per 18 months the above required fire barrier penetrations and sealing devices shall be verified OPERABLE by performing a visual inspection of:

i. The exposed surface of each fire rated assembly; f

ii. At least 10% of all fire dampers. If abnormal changes in appearance or abnormal degradation are found, a visual inspection of an additional 10% of the dampers shall be made. This inspection process shall continue until a 10% sample with no abnormal chances in appearance or degradation is found. Samples shall be selected such that each fire damper will be inspected every 15 years; and iii. At least 10% of each type of sealed penetration. If abnormal changes in appearance or abnormal degradation are found, a visual inspection of an additional 10% of each type of sealed penetration shall be made. This inspection process shall continue until a 10% sample with no abnormal changes in appearance or abnormal degradation is found. Samples shall be selected such that each penetration seal will be inspected every 15 years.

PT/0/A/4200/48, Periodic Inspection of Fire Barriers and Related Structures, is the periodic test procedure used to verify that the Station's passive fire protection features are functional per the ,

requirements of SLC 16.9-5.

M Model Work Order 91004925, which replaced Standing Work Order 6238 SWR, was used by the Work Management System to control the scheduling of Work Order Tasks to perform the visual inspection of fire rated assemblies per the requirements of SLC 16.9-5 (a)(i).

Fire related assemblies were visually inspected per the requirements of SLC 16.9-5 (a)(i) on October 26,1992, and were required to be visually inspected prior to September 12, 1994.

EVENT DESCRIPTION October 26,199-2 Work Order Task 92074269 01 was performed to visually inspect each fire rated assembly per the requirements of SLC 16.9-5 (a)(i).

(This Work Order Task was generated from the controlling Model Work Order 91004925).

November 11, 1992 Model Work Order 91004925 was deleted per E,ngineering.

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y DUKE POWER COMPANY k! CATAWEA NUCLEAR STATION' PIP 0-C94-1691 PAGE 3 of 4 November 29,1994 The Station Fire Protection Engineer, during a review of fire barrier SLC requirements, determined that the surveillance interval 0930 hours0.0108 days <br />0.258 hours <br />0.00154 weeks <br />3.53865e-4 months <br /> for SLC 16.9-5 (a)(i) had been exceeded. All fire barriers were-declared inoperable and the surveillance was initiated per Work Order Task 94089300 01.

1540 hours0.0178 days <br />0.428 hours <br />0.00255 weeks <br />5.8597e-4 months <br /> The visual inspection of each fire rated assembly was completed; the acceptance criteria of PT/0/A/4200/48 was met, thus satisfying the requirements of SLC 16.9-5 (a)(i). All fire rated assemblies were declared operable.

CONCLUSION This event is attributed to Document Use Practices due to the misinterpretation of the requirements of SLC 16.9-5.

During 1992, Engineering personnel responsible for Station fire protection performed a review and update of Model Work Orders associated with SLC 16.9-5. This update resulted in 30 Model Work Orders being used to perform inspections of fire barrier penetrations. Three Work Orders would be performed on an annual basis, thus all fire barrier penetrations would be inspected on a 10 year basis. This was considered to be a conservative approach due to SLC 16.9-5 (a)(ii) and (a)(iii) requiring that each fire damper and each type of sealed penetration be inspected every 15 years.

The determination was made that by satisfying the requirements of SLC 16.9-5 (a)(ii) and (a)(iii)  !

pursuant to procedure MP/0/A/7650/69, Installation and Maintenance of Fire Boundaries, via the Preventive Maintenance (PM) program that the requirements of SLC 16.9-5 (a)(i) would be satisfied. This misinterpretation of SLC 16.9-5 resulted in the deletion of Model Work Order 91004925, the Model Work Order which had been used to schedule the visual inspection of fire rated assemblies.

Additional controls have been implemented to ensure Model Work Orders associated with Technical Specification or SLC requirements are not deleted. The Work Control Group has designated a Surveillance Coordinator who is responsible for the station surveillance program.

Any change to work orders associated with the surveillance program is reviewed by the Surveillance Coordinator per the requirements of Maintenance Management Procedure 3.5, Maintenance Predefined Activities. Additionally, the station is implementing a Preventive Maintenance Optimization Effort which includes Engineering performing an assessment of changes to Model Work Orders prior to review by the Surveillance Coordinator.

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. DUKIi POWER COMPANY CATAWBA NUCLEAR STATION PIP 0-C94-1691 PAGE 4 of 4 CORRECTIVE ACTIONS l

SUBSEQUENT )

1) All fire barriers were declared inoperable, were visually inspected per the I l

requirements of SLC 16.9-5 (a)(i), and were declared operable following successful completion of the visual inspection.

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2) Model Work Order 940089298 was initiated to ensure scheduling of the visual I inspection of fire barriers per the requirements of SLC 16.9-5 (a)(i).

3) A Surveillance Coordinator has been designated to ensure Technical Specification and SLC requirements are met. l l

PLANNED l i

1) Mechanical / Civil Engineering will review all SLC 16.9 surveillance requiements i to ensure that all fire protection requirements are being met. I

2) Mechanical / Civil Engineering will review and revise SLC 16.9-5, as necessary, ,

to ensure clarity in the wording of requirements. l SAFETY ANALYSIS The functional integrity of the fire barrier and associated penetration seals ensures that fires will be confined or adequately retarded so that the following criteria is achieved:

• Fire will not spread from non-safety related areas to safety related areas,

• Fire will not damage redundant analyzed post Fire Safe Shutdown equipment,

• Fire will not spread from the balance of plant to the control complex,

• Fire will not spread from non-containment areas to containment areas. i Fire rated assemblies and fire barrier penetration seals are considered functional when the visually observed condition indicates no abnormal change in appearance or abnormal degradation.

The exposed surfaces of each fire rated assembly was visually inspected per the requirements of SLC 16.9-5 (a)(i) on October 26,1992, and were again visually inspected on November 29, 1994. The current visual inspection, as did the previous visual inspection, indicated that each fire rated assembly was functional and capable of performing its design function.

The health and safety of the public was not affected by this event.

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