ML20150C900
| ML20150C900 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/11/1988 |
| From: | NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20127A683 | List:
|
| References | |
| NUDOCS 8803220405 | |
| Download: ML20150C900 (5) | |
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SE000YAH NUCLEAR POWER PLANT, UNITS 1 AND 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT EN 231.06(B)
"FIRE PROTECTION SYSTEMS QUALITY ASSURANCE DOCUMENTATION"
1.0 INTRODUCTION
A concern was raised on Bellefonte Nuclear Plant that addresses TVA's. review of.
General Construction Specification G-73, "Inspection, Testing, and Documentation Requirements for Fire Protection Systems and Features," which is applicable to all TVA plants and is, therefore, generic to Sequoyah.
The concern was that TVA Engineering did not establish the Ouality Assurance (QA) requirements for fire protection features consistent with the requirements of Specification G-73.
2.0 EVALUATION i
Category:
Engineering (23100)
]
Cubcategory:
Fire Protection (23106)
Element:
Fire Protection Systems Quality Assurance Documentation (231.06(B))
j Employee Concern:
QCP-10.35-1 The basis for Element Report EN23106(B) - SON, Rev. 2, dated January 27, 1987, is Sequoyah Employee Concern QCP-10.35-1 which states:
"Discrepancy between G-73 designation of fire protection drawings (QA) and engineering treatment of fire protection drawings (as non-QA)."
TVA reviewed the background on the development of the fire protection system design and documentation requirements over the past decade.
In general, the fire protection features at Sequoyah were initially designed to conform to the NRC guidelines of Appendix h to Branch Technical Position APCSB 9.5-1, "Guidelines for Fire Protection of Nuclear Pcwer Plants Docketed Prior to July 1, 1976." These features were reviewed and found acceptable by the NRC as documented in SER Supplement 1, dated February 1980.
Additional modifications were required following issuance of 10 C.F.R. Appendix R to meet the revised NRC fire protection and safe shutdown requirements.
During TVA's evaluation of Specification G-73 and discussions with TVA fire protection personnel, it was determined that this specification was developed i
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1 l to establish control over the construction activities to assure that the fire protection features were constructed in accordance with the construction documents that were prepared by engineering.
Specification G-73 was not intended to provide jurisdiction over design functions.
Other engineering i
design standards, criteria and procedures were available for this purpose.
l These engineering cocuments establish the QA requirements that must be applied to all of the fire protection features.
Fire protection systems are generally installed under a "limited QA program" and fall under the requirements of G-73 l
for construction documentation.
The "limited QA program" provides a full inspection and documentation program for the construction and installation of fire protection features, but is of a reduced scope from the traditional QA Requirements of 10 C.F.R. 50 Appendix 8.
However, this program was developed to treet the NRC fire protection guidelines.
Fire protection systems which interact with nuclear safety systems such as those in which seismic supports are needed, must confom to the QA requirements of 10 C.F.R. 50 Appendix B.
Specification G-73 states that in these situations the recuirements of 10 C.F.R. 50 Appendix B are applicable in lieu of the "limited QA program".
The responsibility to identify the type QA program to be applied to the applicable fire protection feature is assigned to design engineering.
However, the wording of Specification G-73 gives the impression that this specification has jurisdiction over TVA engineerino design.
This is not true.
TVA has committed to revise Specification G-73 to eliminate this problem.
Corrective Action Tracking Document 231.00-SQN-1 has been issued to track completion and implementation of these corrective actions.
This is acceptable for restart.
3.0 CONCLUSION
The concern of the apparent discrcpancy between the identification of the QA reouirements for fire protection features between engineering construction documents and construction QA requirements of Specification G-73 is not valid.
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Specification G-73 is a construction document prepared by engineering that specifically defers jurisdiction of CA issues to engineering.
- However, confusion does exist by Specification G-73 as to whether or not QA requirements are deferred to other documents.
TVA is to revise Specification G-73 to correct this problem.
The NRC staff concludes that TVA's investigation and resolution of the concerns described in Element Report QCP-10.35-1 were adequate.
No further NRC action is required,
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION TVA EMPLG'IE CC.'.CERN SPECIAL P'06 RAM, REFORT t.0: 23203 LEUL0t h ELEMENT, PIPIr:G AhD VALVE CESIGN IMFs0PER PIPIAG INSULATICN MATERIAL I.
_ SUBJECT Category:
Engineering Subcategory:
Piping Design Element:
Improper Piping Insulation Material Report Number: 23203 11.
Eummary of Issues The concerned irdividual believed that mineral fiber piping in-a.
sulation material, widely used at Watts Bar Nuclear Plant and Sequoyah Nuclear Plant (SQNP), is easily damaged and ceteriorates over a period of time.
The individual felt that a "harder" type of insulation should have been used instead, b.
An employee questinned the acceptability of.onmetallic thermal insulation being installed at SONP en austenttic stainless steel components in safety-related systems.
III. Evaluation The centern that nineral fiber cicin; insulation is easily damaced a.
Ed tends to deteriorate The validity of this concern eculd not be determined.
At SCNP there is a limited use of nineral fiber insulation, primarily on piping outside containment.
The insulation applied to the pipes are covered with a 0.016 inch thi:k aluminum jacket and has good resistance to vibratien.
If damaged, the affected sections can be easily replaced.
The acceptability of mineral fiber piping insula-tion has been demonstrated by satisfactory service experience in i
widespread power plant applications.
Based on its review, the TVA concluded that this cencern is not valid for the mineral fiber types of piping insulation installed at SON.
. The NRC staff resiewed the information submitted by the TVA and the applicable NRC guidelines.
The staff's evaluation indicates that the use of mineral fiber insulation on piping would not violate the applicable NRC guicelines of 10 CFR 50, Appendix B, GDC 2, and the SRP Sections 3.7.1 - 3.7.4 and 3.9.1 - 3.9.6.
In the elenent report submitted to the staff, TVA stated that mineral fiber insulation used at SQNP is censistent with the SQN Plant Design Criteria ard the TVA Insulation Specifications.
The staff centurs with the TVA's conclusion that this cencern is nut valid.
b.
The concern that the tyce of insulation used on austenitic stainless steel tray be of unacceptable cuality.
During the investigation of this concern, TVA found that stress corrosion cracking cculd develop from the contact of austenitic stainless steel with insulating raterials c:rtaining excessive levels of bleachable chieride and fluoride icns.
The NRC guideline en this subject is found in Regulatory Guide (RG) 1.36 "Nonretallic Thermal Insulation for Austenitic Stainless Steel."
The TVA
'nvestigation Report states that although mest cf the insulating i
raterials installed at SON were the same as thi.se at other TVA plants that ccmply with RG 1.36, the compliance at SQN was uncertain I
because certification was lacking; ard future ccmpliance was not assered.
The TVA report appropriately recorrended documenting compliance with RG 1.36 guidelines and also recemrended precedural changes to assure ccr.pliance for future replacement insulation purchased by the plant.
In response to the TVA Investigation Report, the SCNP personnel cen-mitted to cerply wi*h RG 1.36.
The plant persennel corpleteo a program of testing installed and stored nonr.etallic insulation which
2 verified and documented cenpliance with PG 1.36.
Furthermore, the SQ!iP standard practice was revised to comply with the Regulatory guideiines for future procurenents of insulation.
With implemen-tation of these corrective reasurr.5, the utility concludes that the problen identified by the concerned employee is resolved.
The tiRC staff concurs in its conclusion.
IV.
Cenclusion l
Issue a l
l The concern that the mineral fiber piping insulation is easily l
damaged and tends to deteriorate is found to be not valid as a safety issue by the hRC staff.
Issue b l
l The NRC staff concludes that the actions taken by the utility to correct the proble:r identified by the concerned employee are acceptable.
The corrective measures taken by the utility to cc:rply j
with RG 1.35 guidelines relative to the insulatien procured and used at SChF in effect resolve the erployee's ccncern that the type of l
insulatien used on austenitic stainless steel nay be of unacceptable
- quality, i
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