ML20151P080
| ML20151P080 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 12/13/1985 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 85-815, NUDOCS 8601030295 | |
| Download: ML20151P080 (4) | |
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r VIHOLNIA ELECTHIC AND POWER COMI%NY RicitxoNn,VIHOINIA 20261 W. L. STEWARIT Vaca Panasonwr wuco... or.. vww.
December 13, 1985 Dr. J. Nelson Grace Serial No.85-815 Regional Administrator NAPS /JHL:vlh Region II Docket Nos. 50,-338 U. S. Nuclear Regulatory Commission 50339 Suite 2900 License Nos. NPE34 101 Marietta St., N.W.
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Dear Dr. Grace:
u cA VIRGINIA ELECTRIC AND POWER COMPANY W
NORTH ANNA POWER STATION UNITS NO. 1 AND 2 RESPONSE TO NOTICE OF DEVIATION NRC INSPECTION REPORT NOS. 50-338/85-24 AND 50-339/85-24 We.have reviewed your letter of November 14, 1985, in reference to the inspection conducted at North Anna Power Station from September 9 to September 13, 1985, and reported in Inspection Report Nos. 50-338/85-24 and 50-339/85-24. Our response to the Notice of Deviation is addressed in the attachment.
On December 5,1985, our staffs discussed a statement made on page 34 of the inspection report relating to testing emergency battery units. Your report indicated that we were to functionally test emergency battery units for eight hours each month.
Per the discussions between our staffs, it was agreed that the statement was in error and that the emergency battery units would be tested every 18 months.
We have no objection to this inspection report being made a matter of public disclosure. If you have any questions, please contact me.
Very truly yours, 1
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s W. L. Stewart 8601030295 851213 PDR ADOCK 05000338 G
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-l VamointA ELECTRIC AND POWER COMPANY TO Dr. J. Nelson Grace cc:
Mr. Roger D. Walker, Director Division of Reactor Projects NRC Region II Mr. Lester S. Rubenstein, Director PWR' Project Directorate // 2 Division of PWR Licensing - A e
J Mr. M. W. Branch NRC Resident Inspector North Anna Power Station i
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RESPONSE TO NOTICE OF DEVIATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM SEPTEMBER 9 to 13, 1985 INSPECTION REPORT NOS. 50-338/85-24 and 50-339/85-24 NRC COMMENT:
Section 8.3 of the North Anna Power Station FSAR states that the damming material used in conjunction with RTV Silicone Foam to form fire stop seals in fire barrier walls is to be left in place as part of the permanent seal.
Contrary to the above, several conduit fire stop penetrdtion seals located in the fire barrier wall that separates the Emergency Switchgear Rooms and Instrument Rack Rooms (Fire Area 6-1) from the Turbine Building (Fire Area 8) did not have the fire damming material in place.
RESPONSE
1.
DESCRIPTION OF CORRECTIVE ACTIONS:
Specification NAS-1014, " Installation of Dow Corning Q3-6548 Silicone Foam in Penetrations," states that the penetration seal "should be filled with a minimum of 12 inches of foam and permanent damming material." The CERAFIBER or CERABLANKET permanent damming material is specified "not to exceed one inch at either end of the. penetration."
The intent of these statements is that permanent damming material may be omitted entirely from either or both sides of the seal as long as the penetration seal is a minimum of 12 inches deep. The specification states that non-permanent damming material may be used in forming the penetration seal, and that "approximately 10 minutes after completion of filling, the release board and other nonpermanent damming material may be removed."
Field inspection of the penetration seals mentioned in the deviation determined that the seals are a minimum of 12 inches deep.
It appears that, where CERAFIBER damming material was used, it was left in place; where nonpermanent damming material was used, it was removed.
The basis for the specification requirements is that penetration seals consisting of 10 inches of foam plus one inch of CERAFIBER on each side have a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating as determined by testing performed by the Virginia Electric and Power Company.
Penetration seals consisting of 12 inches of foam with no permanent damming material have a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating as determined by the manufacturer, Dow Corning. The fire resistance testing of the penetration seals is the subject of an
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Engineering Evaluation which is being submitted to NRC/NRR for review under separate correspondence. NRR review of this item is listed as Unresolved Item 338,339/85-24-12 in Inspection Report No. 85-24.
A review of UFSAR Section 8.3 indicates that the UFSAR does not accurately reflect the specification requirements or the fire resistance testing results for penetration seals. Based on the determination that the penetration seals in question do have a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating and that the installed penetration seals are in accordance with NAS-1014, we have concluded that UFSAR Section 8.3 should be revised.
2.
-ACTIONS TAKEN TO AVOID FURTHER DEVIATIONS:
No change to the design or installation process for penetration seals is required. A UFSAR change will resolve this deviation.
3.
DATE WHEN ACTION WILL DE COMPLETED:
The UFSAR change will be incorporated into the next annual revision of the UFSAR that is scheduled for completion in June 1986.