ML20151F008
| ML20151F008 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 07/21/1988 |
| From: | Hairston W GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 88-005, 88-5, SL-4952, NUDOCS 8807260293 | |
| Download: ML20151F008 (7) | |
Text
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Georgia Powei Company 333 Piedmont Avenue
.o Atlanta, Georgia 30308 Telephone 404 526 6526 Mailing Address:
Post Off,ce Box 4545 At!anta, Georgia 30302 GeorgiaPower Nuclear Operations Department I?C S M he'" M W'C38 *'S SL-4952 03961 X7GJ17-H540 July 21, 1988 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Hashington, D. C.
20555 PLANT HATCH - UNIT 1 NRC DOCKET 50-321 OPERATING LICENSE DPR-57 SPECIAL REPORT 88-005 FIRE HRAP NOT INSTALLED ON CABLE RACEHAYS RESULTS IN SPECIAL REPORT AS REQUIRED DY FIRE HAZARDS REPORT Gentlemen:
In accordance with the requirements of the Plant Hatch Unit 1 Technical Specifications Section 6.9.2, and the Fire Hazards Aialysis (FHA) Appendix B,
Georgia Power Company is submitting the tnclosed Special Report (SR) concerning an event where a fire rated asse Ably was inopor91e longer than 14 days.
Sincerely, d,
I H. G. Hairston, III Senior Vice President CLT/ct
Enclosure:
SR 50-321/1988-005 c:
(see next page) amm s
\\
Georgia Power d U. S. Nuclear Regulatory Commission July 21, 1988 Page Two c:
Georaia Power Comoany Mr. J. T. Beckham, Jr., Vice President - Plant Hatch Mr. L. T. Gucwa, Manager Nuclear Safety and Licensing GO-NORMS
- b. S. Nuclear Regulatory Commission._Hashington. D. C.
Mr. L. P. Crocker, Licensing Project Manager - Hatch U. S. Nuclear Regulatory Commission. Region II Dr. J. N. Grace, Regional Adr.inistrator Mr. J. E. Henning, Senior Resident Inspector - Hatch 03961 7xns
I Georgia Power b ENCLOSURE PLANT HATCH - UNIT 1 NRC DOCKET 50-321 OPERATING LICENSE DPR-57 SPECIAL REPORT 88-005 FIRE HRAP NOT INSTALLED ON CABLE RACEHAYS RESULTS.IN SPECIAL REPORT AS REQUIRED BY FIRE HAZARDS REPQRI A.
REQUIREMENT FOR REPORT This report is required per the Unit 1 TechnicEl Specifications section 6.9.2.
This section of the Technical Specifications states that special reports for fire protection equipment operatina and surveillance requirements shall be submitted, as required, by the Fire Hazards Analysis (FHA) and its Appendix B requirements.
The FHA, Appendix B Section 1.1.1 states that fire rated assemti'es separating portions of redundant systems important to safe sautdown within a fire area shall be operable.
ACTION statement b.
of FHA, Appendix B Section 1.1.1 allows for the fire rated assembly (s) to be inoperable for up to 14 days.
If this time limit is exceeded, a special report is required.
B.
UNIT (s) STATUS AT TIME OF EVENTS On 6/10/88, 6/11/88, and 6/22/88, Unit I was in the run mode at an approximate power level of 2430 MWt (approximately 100 per.ent of rated power) when it was determined that certain fire bairier protection was inadequate.
01'96I E-1 7/21/88 SL-4952 l
roons
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Georgia Power 1 ENCLOSURE (Continued)
FIRE HRAP NOT INSTALLED ON CABLE RACEHAYS RESULTS IN SPECIAL REPORT AS REQUIRED BY FIRE HAZARDS REPORT C.
DESCRIPTION OF EVENT This report describes deficiencies which were found by the Architect Engineer (A/E) during a review of as-built notices (ABNs) for the Analog Transmitter Trip System
(. ATTS) modification against the electrical cele separation criteria of 10 CFR 50.48 and 10 CFR 50, Appendix R, III.G.2.c.
The ATTS modification was not finalized when the major modifications on Unit I were made throughout 1986 to achieve compliance with Appendix R criteria.
Therefore, the review of the ATTS ABNs was initiated to assure Appendix R criteria were met.
On 5/5/88, plant Fire Protection personnel received information from the A/E indicating that electrical raceways 2ESB170 and TB1-217 potentially required wrapping with fire barrier material.
Deficiency Cards 1-88-1966 and 1-88-1967 were initiated to document the possible deficiencies, as required by the plant's administrative control procedures.
As a
conservative action, a Limiting Condition for Operation (LCO) was initiated at that time and an hourly fire watch patrol was established to satisfy the requirement of Plant Hatch Fire Hazards Analysis (FHA), Apperidix B Section 1.1.1, ACTION a. for inoperable fire rated assemblies.
Plant Fire Protection engineering personnel then directed the A/E to evaluate the raceways further, to confirm whether they were required to meet the requirements of 10 CFR 50.48 and 10 CFR 50, Appendix R.
The A/E confirmed on 6/10/88 that the identified raceways required fire wrapping.
Electrical raceway 2ESB170 was required to have a three hour fire wrap and TB1-217 required a one hour fire wrap.
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Georgia Power A ENCLOSURE (Continued)
FIRE HRAP NOT INSTALLED ON CABLE RACEWAYS RESULTS IN SPECIAL REPORT AS REQUIRED BY FIRE HAZARDS REPORT On 6/11/88, based on further review of ABNs by the A/E and plant Fire Protection -personnel, it was determined that electrical raceways TCK8-01 and TCK8-02 also were ' required to have a one hour fire wrap.
These deficiencies were documented via s
Deficiency Card 1-88-2526.
An LC0 was initiated on 6/11/88 and an hourly fire watch patrol was established at that time.
On 6/22/88, plant personnel determined by visual inspection that cable tray REA8-04 was not protected by fire barrier material.
The review of the ABNs had earlier identified this cable tray as requiring fire wrap; however, an initial visual inspection from a distance had led to the preliminary conclusion that the tray was wrapped (Radiologically Controlled Area).
The deficiency was documented via Deficiency Card 1-88-2669.
An LC0 was initiated on 6/22/88 and an hourly fi re watch patrol was established, t
D.
CAUSE OF EVENT The cause of these events was inadequate guidance regarding the application of Appendix R
requirements in the design and implementation process for ATTS modifications which were being done concurrent with Appendix R implementation.
Although design measures were in place to minimize conflicts between ATTS and Appendix R requirenents, the implementation of the ATTS modification in parallel with the evolution of Appendix R requirements contributed to the lack of adequate guidance for applying Appendix R requirements.
The present, ongoing review of the ATTS ABNs was initiated to verify compliance with Appendix R requirements.
03961 E-3 7/21/88 SL-4952 F007FS
Georgia Power A ENCLOSURE (Continued)
FIRE HRAP NOT INSTALLED ON CABLE RACEHAYS RESULTS IN SPECIAL REPORT AS REQUIRED BY FIRE HAZARDS REPORT E.
ANALYSIS OF EVENT The installation of fire barrier. material is one of the available - means of limiting fire damage to structures, systems, or components important to safety so that the capability to safely shut down the plant is ensured.
In this event the ongoing ~ review'of ATTS ABNs identified several areas which required fire wrapping.
A review of the ATTS circuitry potencially impacted by the lack of adequate fire protection disclosed that in all cases the Emergency Operating Procedures (EOPs) provide for adequate compensatory actions should the circuitry's operation be affected by a fire.
Based on the above inforraation, it 'is concluded that this event had no adverse impact on nuc' ear safety.
The above analysis is applicable to all power levels.
F.
CORRECTIVE ACTIONS The following compensatory measures have been taken for the five electrical raceways which do not meet the criteria of 10 CFR 50.48 and 10 CFR 50, Appendix R, III.G.2.c.:
1.
An LCO was established for each of the individual raceways.
2.
An hourly fire watch patrol was established for each of the individual raceways.
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Georgia Power A ENCLOSURE (Continued)
FIRE HRAP NOT INSTALLED ON CABLE RACER 4(S RESULTS IN SPECIAL REPORT AS REQUIRED BY FIRE HAZARDS REP _QBI 3.
Plant Hatch personnel discussed the compensatory actions ir.-
regards to these deficiencies with NRC inspectors at Plant Hatch during a site inspection which occurred from 6/20/88 to 6/24/88.
The inspectors were informed that current E0Ps give compensatory actions in their flow charts for those components whose operation might be impacted due to the circuitry which lacks fire wrapping.
Design change requests (DCRs) have been issued for providing fire barrier wrap for each of the affected cable raceways.
It is anticipated that the A/E will complete the necessary electrical design documentation by 7/22/88 and the necessary work scope design documentation by 8/1/88.
At present it is anticipated that these deficiencies will be corrected prior to the next Unit I refueling outage which is scheduled to begin approximately 9/28/88.
The review of ATTS ABNs to assure Appendix R criteria were met is ongoing.
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