ML20215F440

Notice of Violation from Insp on 850114-18.Violations Noted: Fire Protection Features Not Provided for Certain Redundant Trains of Equipment &/Or Cabling Necessary to Achieve & Maintain Hot Shutdown

ML20215F440
Person / Time
Site:	Sequoyah
Issue date:	06/08/1987
From:	James Keppler NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20215F404	List: IR 05000327/1985001 ML20215F401 ML20215F440
References
50-328-85-01, 50-328-85-1, EA-85-048, EA-85-48, NUDOCS 8706220383
Download: ML20215F440 (4)

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NOTICE OF VIOLATION Tennessee Valley Authority Docket No. 50-328 Sequoyah Unit 2 License No. DPR-79 EA 85-48 As a result of an inspection conducted on January 14-18, 1985, violations of NRC fire protection requirements were identified. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR 4 Part 2, Appendix C (1987), the violations are set forth below:

I.. Operating License DPR-79, Section 2.C.(13)c for Unit 2 requires that TVA shall comply with Section III.G, III.J, III.L. and III.0 of Appendix R-of 10 CFR.Part 50, except where NRC has approved deviations. The NRC had not approved any deviations from these sections.

A.. 10 CFR Part 50, Appendix R, Section III.G 1 requires that fire protection features shall be provided.for structures, systems., and components important to safe shutdown. These features shall be capable of limiting fire damage so that one train of systems necessary to achieve and maintain hot shutdown from either the control room or emergency control station (s) is free of fire damage. ,

SectionsIII.G.2andIII.G.3specifyfouralternativesthatmaybe implemented outside of primary containment to assure that one-redundant train of equipment, cabling, and associated circuits necessary to achieve and maintain hot shutdown remains free of fire damage. The alternatives are:

Separation of redundant trains of equipment, cabling, and associated circuits by a three-hour rated fire barrier.

Separation of redundant trains of equipment, cabling, and associated circuits by a horizontal distance of 20 feet with no intervening combustibles and fire detection and automatic fire suppression systems installed in the area.

Enclosure of redundant trains of equipment, cabling, and associated circuits by a one-hour rated fire barrier with fire detection and automatic fire suppression systems installed in the area. i Installation of alternative or dedicated shutdown capability independent of the equSpment, cabling, and associated circuits.

under consideration, and installation of fire detection and fixed fire suppression. systems in the area under. consideration.

Contrary to the above, as of August 10, 1984, fire protection' features were not provided fortcertein redundant trains of equipment and/or cabling necessary to achieve and maintain hot-shutdown'from either the control room or' emergency control stations such that one train would remain free of fire damage. -The redundant trains of equipment and/or cabling were. located in' the same fire

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areaoutsidetheprimarycontainment..Noneofthe' k

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! f provided by Sec' tion III.G.2 and III.G.3 'were . implemented.  ;

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Specifically: ,

i 1 1. ' Thirty-six examples wit in '19 plant areas existed in which both

/ s's. Wredundantftrains were located in the'same fire area and not

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'pbovidef Lthe fire protection; features of-Section'III.G.2 or )

. III.G.3. These areas involved' systems such'as auxiliary feedwater,- 1 componsnthceoling-water, essentiat raw cooling water, chemical-  ;

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/ ,' volum and control, pressurizer. heater controls, steam generator- j

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'- ' control', and on-site power distribution.

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2. 3 Two hundred for,ty-five. associated circuits having;a common .

power source with i

> operation or,cause; shutdown malfunction-of equipment.which equipment necessary to.could prevent .;

' / achieve and maintain hot' shutdown conditions were-noti properly i

electrically protected from the circuit.'of concern nor provided  ;

,q the fire protection features of Section;III.G.2 or III.G.3. 1

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B; - 10 CFR Part 50, Appendid PQ Cection III.G.1.b requires that systems

• necessdry to achieve and%iintain cold-shutdown from the control room

, y or emergency control station (s) can' be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, t D '

, Contrary to the above, as of.' August 10,-1984, the' redundant trains of equipment and cabling necessary to achieve cold shutdown conditions-were not ' capable of being repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as demonstrated-by the absence of planaing, proc'edures, and/or materials necessary. j n < to implement fire ddmage' repairs. Thirteen-areas existed in which -

both redundant trains of cabling.were11ocated'.in the same: fire area'.

Collective 1}, these violations have been. categorized as a Severity Level:II ,

problem (SupplementI). j II. Operating License DPR-79,:Section 2.C.(13)c-for' Unit'2 requires that TVA shall comply with Section III.G,.III.0,~~and III.0 of-Appendix-R of 10.CFR  !

Part 50, except where.NRC has approved deviations. The NRC has not approved i deviations in the areas of Sections III.0 and III.J, cited'below.

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A. 10 CFR Part 50, Appendix R, Section III.0,(requires'.the rea'ctor j coolant pumps to be equipped with an oil collection. system-if;the l containment is not' inerted ~ during nonnal operations. The system is- .;

required to be designed, engineered, and installed such that failure '

I will not lead-to fire during normal or design basis accident conditions'-

.and such that the system will withstand the Safe Shutdown Earthquake. .j All leakage from potential pressurized'and unpressurizedcleakage: i sites is to be collected and drained to'a vented closed container

> that can hold the entire lube oil system inventory.- i

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. o Notice of Violation Cortrary to the above, as of August 10, 1984, and with a containment not inerted during normal operations, the reactor coolant pump oil collection systems were not designed, engineered, or installed to withstand the Safe Shutdown Earthquake. In addition, the drainage tank was not designed to hold the entire reactor coolant pump lube oil system inventory.

B. Technical Specification, Section 6.8.1.f, requires that written procedures be established, implemented, and maintained for the fire protection program. TVA's approved fire protection program, as discussed in an October 23, 1979 response to the NRC's Auxiliary Systems Branch, indicates in Table 1.3 which circuits are to be protected by a 1/2-hour fire rated barrier.

Contrary to the above, as of January 14-18, 1985, TVA had not implemented its procedures for the approved fire protection program in that the 1/2-hour fire barriers. required by Table 1.3 for conduits 2PM1011, 2PM211411, and 2PM2084I in the auxiliary building were found to be partially missing or damaged and, therefore, did not meet the required fire rating.

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C. 10 CFR Part 50, Appendix R, Section III.J., requires emergency lighting units with at least an 8-hour battery power supply to be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.

Contrary to the above, as of January 14-18, 1985, the existing emergency lighting units had battery power supplies rated at 3 3/4-hours and lighting units were provided for only 76 of ,

approximately 150 areas needed for operation of safe shutdown -

equipment and in access and egress routes thereto.

Collectively, these violations have been categorized as a Severity Level IV problem (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley Authority is hereby required to submit a written statement or explanation to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Director, Office of Special Projects, and a copy to the NRC Resident Inspector within 30 days of the date of the letter trans-mitting this Notice. This reply snould be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation if admitted, (2) the corrective steps that have been taken  ;

and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

Where good cause is shown, consideration will be given to extending the response j I

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-r Notice of Violation time.. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the licensee should not be modified, suspended, or revoked or why such other action as may be proper )

should not be-taken. . Consideration may be given to extending the response '

time for good cause shown.

FOR THE NUCLEAR REGULATORY COMMISSION

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Q } KeppI2r, FJames G. Director Office of Special Projects Dated at Bethesda, Maryland d

this . a day of June 1987.

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