ML20154L602
| ML20154L602 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/15/1988 |
| From: | Hairston W GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NON-00314, NON-314, NUDOCS 8809260229 | |
| Download: ML20154L602 (8) | |
Text
_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Georg.a F%ef Compeny 333 Pet A,enue Atlanta, Georg;a 30308 Telephore 404 52665 Ma hng Address Fbst Off ce Box 4545 Atwta. Georg'a 30302
!?e scwern tvec suwwn Nsctear Operat'ons NON-00314 0045e September 15, 1988 U. S. Nucl.?ar Regulatory Commission ATTN: Document Control Desk Washington, D. C.
20555 PLANT YOGTLE - UNIT 1 NRC 00CKET 50 424 OPERAT N LICENSE NPF-68 REPLY TO M TICE OF VIOLATION Gentlemen:
I In accordance with the provisions of 10 CFR 2.201, Georgia Power Company (GPC) submits the enclosed information in response to NRC Enforcement Action 88-167 which concerns violation 50-424/88-24-01.
The subject violation was i
identified in NRC Inspection Report 50-424/88-24 and was discussed in an i
j enforcement conference with the NRC Region 11 staff on July 5,1988.
In the enclosure, transcription of the NRC violation precedes GPC's response.
Should there be any questions in this regard, please contact this office at any time.
Sincerely,
, h*
,,Js' W. G. Hairston, III JAE/KP:llh
Enclosure:
1.
Violation 88-24-01 and GPC Response l
1 i
c:
(see next page) i i.
i
{ (O l 8809260229 880915 PDR ADOCK 05000424 1
Q PDC
(\\ \\
i
GeorgiaPower A U. S. Nuclear Regulatory Connission September 15, 1988 Page Two c: Georzia Power Company Mr. . D. Rice Mr. G. Bockhold, Jr.
I Mr. J. E. Swartzwelder Mr. J. P. Kane GO-NORMS t
Vogtle-NORMS U. S. Nuclear Regulatory Comission Dr. J. N. Grace, Regional Administrator Mr. J. B. Hopkins, Licensing Project Manager, NRR (2 copies)
Mr. J. F. Rogge, Senior Resident Inspector - Operations, Yogtle i
i t
l f
1 I
l l
I l
i i
GeorgiaPower A ENCLOS@E PLANT YOGTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 NRC WOTICE OF VIOLATION 88-24-01 AND GPC RESPONSE Y!0LATION 50-424/88-24-01 "License Condition 2.G requires that the licensee implement and maintain in effect all the provisions of the approved Fire Protection Program as described in the Final Safety Analysis Report for the facility and as approved in the NRC Safety Evaluttion Report (SER) (NUREG-1137) through Supplement 5.
Section 9.5.1.1, "Fire Protection Requirements," of the SER (NUREG-1137) dated June 1985, states that General Design Criteria (GDC) 3 requires that fire fighting systems be designed to ensure that rupture or inadvertent operation does not significantly ir' pair the safety capability of structures, systems, and components important to safety.
The SER also states that in order to satisfy the requirements c' GDC 3, the licensee by letter dated February 22, 1985, stated that the components required for shutdown are designed so that rupture, inadvertent operation, or intentional operation of Fire Suppression Systems will not adversely affect the operability of these components.
In addition, redundant trains of components that are susceptible to damage from water spray are physically separated so that manual fire fighting activities will not adversely affect the operability of the components not involved in the postulated fire.
Contrary to the above, as of June 3,1988, the fire suppression systems were not designed to assure that operation of the systems or manual fire fighting activities would not adversely affect the operability of components required for shutdown or components not involved in the postulated fire. Specifically, because of improperly designed floor penetration seals, a fire in the "B"
l train cable spreading room could have caused a loss of the auxiliary shutdown panel, the "B" train safe shutdown functions, and due to the water leakage into the control room from fire suppression activities, the "A" train safe shutdown process monitoring could have been rendered inoperable.
l This is a Severity Level III violation (Supplement I)."
t i
0045e E-1 09/15/8A NON-00314
I Georgia Power d ENCLOSURE (Continued)
NRC NOTICE OF VIOLATIOW 88-24-01 AND GPC RESPONSE RESPONSE TO VIOLATION 50-424/88-24-01 Ahission or denial of alleged violation:
The violation occurred as stated.
Reason for violation:
I The violation occurred due to an inadequate design in that the vendor's i
qualification test report for the penetration seal detail did not represent typical Upper Cable Spreading Room (UCSR) penetration.
The detail that was qualified did not contain a nigh density cable fill within the penetration i
whereas the typical UCSR penetration contains a high density cable fill.
l Further, the architect engineer assumed that the seal weld at the interface of l
the embedded bottom angle to the top angle would provide an adequate water stop in the event that the UCSR had water on the floor.
Testing in Unit 2 j
(described in detail in the Licensee Event Report (LER)88-016 dated i
June 29,1988) showed that a flowpath existed for water to flow between the top angle and the floor and underneath the embedded angle and into the control i
room.
This has been attributed to the potential deformation of the embedded angle iron caused by the seal welding of the embedded angle to the top angle during installation.
The seals in the UCSR are unique when compared to most other seals in the plant since they are located above sensitive unsealed equipment (process j
control cabinets and reactor protection cabinets).
I i
Corrective steps which have been taken to avoid further action:
A.
Short-tem corrective actions:
i l
The following short-tem corrective actions were taken promptly after the incident on June 3,1988:
3 i
j (1) Silicene sealant (Dow Corning RTY 732) was applied to thr; interface
]
between the floor and the penetration top angle for all such pene-i trations in the UCSR.
This material was suitable as an interim solution as proven by a test conducted on a typical penetration in j
the Unit 2 UCSR.
Details of this test are contained in LER 88-016, 1
]
(2) The control room panels were inspected for water intrusion and damage and then dried.
No damage was found by the inspection.
An engi-neering evaluation was perfomed on potential f ailures wi'.hin the j
affected cabinetry, and a detemination was made that only the j
circuitry which spuriously actuated needed to be tested.
On v
l I
b- 0314 1
i
Georgia Power d ENCLOSURE (Continued)
NRC NOTICE OF VIOLATION 88-24-01 AND GPC RESPONSE June 4,1988, functional tests were perfomed to assure that all circuits which had spuriously actuated had not been damaged and were completely functional.
These affected panels will be inspected for corrosion during the Fall 1988 refueling outage which is scheduled to begin October 7,1988.
(3) The deluge valves for sprinkler system 080 located in the UCSR and sprinkler systems 078 and 081 located in the adjacent hallway were isolated so that a spurious actuation of the fire system would not cause a repeat of this event.
(4) A continuous fire watch was established in the UCSR as compensation for deactivation of the sprinkler systems.
Sanocag bems were built inside of both UCSR doors to a height of 6 inches in order to prevent water intrusion from the hallway.
(5) Drains for sprinkler systems 079 and 080 (within the UCSR) were routed, under temporary modification control, to the butiding floor drain.
(6) A broadness review was initiated to determine the location of other seals in the plant which, because of slight leakage, could affect safe-shutdown and water-sensitive safety ralated equipment.
The review identified locations where one train of saie-shutdown ($50) equipment in a room was located above another room containing o)posite train SSD equipment where water could leak from one train to tie other train of equipment.
8.
Long-tem corrective actions:
The following long-tem corrective actions have been taken:
1 (1) A full scale prototype test assembly was fabricated on-si te to qualify the new penetration seal detail to be used for seals of the type used in the UCSR that would be water-tight.
Figure 1 represents a schematic of the current penetration seal configuration in the I
UCSR.
The following methodology was used to determine the materials
)
to be used:
A sealant (Dow Corning RTY 790) was applied around the concrete / angle
[
iron interface and the foam / angle iron interface.
The test assembly was then subjected to water to check for leaks.
No leakage was a
observed beneath the penetration.
i A series of tests were then devised to detemine the most suitable i
material that would flow freely in and around highly dense cable t
bundles.
This was done using open ended buckets poured with foam seal s with high densi ty cable bundles through the seal.
The l
0045e E-3 09/15/88 j
NON-00314 I
l Georgia Power at.
NRC NOTICE OF VIOLATION 88-24-01 AND GPC RESPONSE ma terial, P-12 (a 50/50 blend of Dow Corning 3140 and 3145) was pou-ed around the cables.
Once the material had cured, water was poured on the top of the material and observations were made beneath for leakage.
No leakage was observed.
To confirm that the P-12 material selected for use did in fact flow around cables before applying it to the prototype for qualification, the bucket was dissected.
The P-12 material was found to penetrate between the foam and the cables and had tightly adhered to the cable jacket and the foam.
The P-12 material was then applied around cables in the prototype test assembly.
Once the material had cured. the entire test assembly was then subjected to a water spray directly cn top of the penetration seal.
Water was sprayed on ths t6st assembly until 2 inches of water was abovn the top of the seal.
This configuration was held for one hour at the end of which time the bottom of the seal was inspected for leakage.
No leakage was observed.
(2) The broadness review was coryleted on August 15, 1988 and identified 1 31 penetrations that coind potentially have water leakage and adversely affect SSO equipment and/or water-sensitive electrical equipment.
Each of tne 131 penetrations was evaluated for potential effects on safe shutdown.
This evaluation showed that potential water leakage through 122 of the penetrations would not adversely affect safe shutdown.
For the remaining penetrations, located in the mezzanine level of rooms B-47 and B-48 of the Control Building, compensatory measures have been established to preclude use of water for fire fighting purposes in the area, from any other source, since there are no sprinkler systems in the area.
These measures included posting signs that warned against the use of water for fire fighting in this srea, and placing additional dry chemical extinguishers in this area.
i l
Several short-tenn corrective actions (items A1, A3, A4, and AS) were removed l
subsequent to the initiation of the referenced long-term corrective measures.
Corrective steps which will be taken to avoid further violations:
A second full size prototype test assembly which simulates typical foam penetrations in the plant will be water tested.
The testing is scheduled for completion on September 30, 1988.
As a result, the leaktightness of various types of penetration commodities (i.e., items passing through the penetration) other than the ones shown in Figure 1 will be verified, i
l 0045e E-4 09/15/88 NON-00314 I
ew - -
--y---
-a f'N7's M
4
=w arw-
o Ge()rgia Power ENCLOS0AE (Continued)
NRC WOTICE OF VIOLATION 88-24 AND GPC RESPONSE Subsequent to the testing of the second prototype assembly, the test results will be reviewed to identify the total number of the previously identified 131 penetration seals that will require modification.
Date when full compliance will be achieved:
Completion of the penetration seal re-work is expected by January 30,1989, at which time full compliance will be achieved.
Y l
f l
l 0045e E-5 09/15/88 NON-00314
1 i
HECMANICAL P!l'E($) AM0/0R ELECTRIC.\\L CONDUlT($)
\\"(NCM.) SEAD X L"(HoH' ELF.CT M I C.\\L P,I DEEP D.C. 790 SILICCNE c,gg gg ( $ )
sulLolMG
$EALANT. CR APPROVED t/2" (nom.) THICKNESS ICMS pro 0VCT 12 CR APPROVED EQUAL E0V.\\ L
\\
EXISTING $LEEVE
- f EXTE5510N s
!s'
~
~
,i
- p.'". '.. :.. H. !.
,/
9
?
s
,s.
.: t ej e
s f.'.. ' s.g.:
l lt
[e',' 'f i
~.%
q 1/2"(MIN.) LEAD D.C.
I 790 $ILICONE BU11.DI.%
T SEALANT OR i
l'
,. *\\ '
APPROVED E0UAL EXISTING ICMS i'
INSTALLED FIRI
'l -
i SEAL
', l l'j i
'l ill H
J FIGURE.1 I
0045e E-6 09/15/88 NON-00314 i
i
_ _.. _.. _.. _. - -, _ _ _ _ _. _. _ - - _ _, _. -