ML20236M204
| ML20236M204 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 10/30/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 87-001, 87-1, SL-3366, NUDOCS 8711120137 | |
| Download: ML20236M204 (8) | |
Text
, fGeorgia'Fower Cornpany'. +
333 Piednont Avenue
- Attanta_ Georgia 30308 -
Telephone 404 526 6526 l
Malling Address *.
Pbst ottice Box J545 '.
Atlanta, Georgia 30302:
h-l
' Georgia Power I heioulturiolecticsyMem L T. Gucwa '
t Manager Nuclear Safety 1
and Licensing j
SL-3366, 0004I X7GJ17-H540 o
q October 30, 1987
.I U. S. Nuclear Regulatory Commission
' ATTN: Document Control Desk 4
Washington, D. C.
20555 j
i i
PLANT HATCH - UNIT 2 NRC DOCKET 50-366
)
OPERATING LICENSE NPF-5 SPECIAL ' REPORT 87--001 FIRE RATED ASSEMBLY INOPERABLE FOR' LONGER THAN 14:
1 DAYS RESULTS IN SPECIAL REPORT AS REQUIRED BY FIRE HAZARDS' REPORT l
i Gentlemen:
i In accordance with' the requirements of.the Plant Hatch Unit '2 Technical Specifications section 6.9.2., and the? Fire Hazards Analysis.
(FHA) Appendix B,
Georgia Power Company is submitting the enclosed.
Special Report (SR) concerning an event. where a: fire rated. assembly.. was inoperable longer than 14 days.
Sincerely, Y
2.bn - &
L. T. Gucwa LGB/lc
Enclosure:
SR 50-366/1987-001 c:
(see next page).
8711120137 871030.
PDR ADOCK 05000366 S
PDRs 3p a
1 h
a_-____._a_____
1 1
Georgia Power d i
U. S. Nuclear Regulatory Commission 1
October 30, 1987
)
Page Two j
l c: Georata Power Comoany Mr. J. P. O'Reilly, Sr. Vice President - Nuclear Operations j
Mr. J. T. Beckham, Jr., Vice President - Plant Hatch i
GO-NORMS j
l U. S. Nuclear Regulaterv Commission. Hashington. D. C.
?
Mr. L. P. Crocker, Licensing Project Manager - Hatch U. S. Nuclear ReguD tory Commission. Reaion LL Dr. J. H. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector - Hatch 0004I 700T75
i u
Georgia Power A ENCLOSURE PLANT HATCH - UNIT 2 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 SPECIAL REPORT 87-001 FIRE RATED ASSEMBLY INOPERABLE FOR LONGER THAN 14 DAYS RESULTS IN SPECIAL REPORT AS REQUIRED BY FIRE HAJARDS REPORI A.
REQUIREMENT FOR REPORT
)
i This report is required per the Uait 2 Technical Specifications section 6.9.2.
This section of the Technical' Specifications states that special reports for fire protection equipment operating and surveillance requirements shall be submitted, as required, by the Fire Hazards Analysis (FHA) and its Appendix B requirements.
The FHA section 1.1.1 states that fire rated assemblies separating portions of redundant systems important to safe j
shutdown within a fire area shall be operable at all times.
Action statement "b"
allows a
fire rated assembly to be inoperable for up to 14 days.
If this time period is exceeded, j
a special report is required, i
B.
UNIT (s) STATUS AT TIME OF EVENT On 9/16/87 and 9/22/87, Unit 2 was in the run mode at an approximate power level of 2190 MHt (approximately 90 percent of i
rated thermal power).
0004I E-1 10/30/87 SL-3366 700775
Georgia Power A ENCLOSURE (Continued)
FIRE RATED ASSEMBLY INOPERABLE FOR l.ONGER THAN 14 DAYS RESULTS IN SPECIAL REPORT AS REQUIRED' DLEIRE HAZARDS REP 08I i
C.
DESCRIPTION OF EVENT This report describes two events where the requirements. of the FHA and 10 CFR 50 Appendi'x R were not fully met.
The events were identified 9/16/86 and 9/22/87.
Prior to discussing the actual identified deficiencies, it is necessary to describe the program that detected these deficiencies and the reasons the program was instituted.
This discussion will precede the presentation of the actual deficiencies.
Program Description 10 CFR 50 Appendix R (Appendix R) modifications for both units (1 and 2) at Plant Hatch occurred throughout 1986.and compliance with the federal requirements was obtained on November 26, 1986.
Full compliance was achieved, based on documented and approved calculations, analyses and implementation of the program (including approved specific exemptions).
Georgia Power Company (GPC) views the intent of the Appendix R requirements as a long term, life of the plant program.
In order to ensure that compliance with the requirements is maintained for the life of the plant, GPC decided to augment some of the documentation already in place (the documentation was developed to support compliance with the Appendix R
requirements).
0004I E-2 10/30/87 SL-3366 700775
a' g, y 4
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! s Georgia Power A ENCLOSUREf(Continued)
FIPE RATED ASSEMBLY INOPERABLE FOR LONGER'THAN 14-DAYS-RESULTS. IN SPECIAL REPORT AS REQUIREDL BY FIRE HAZARDS REPORT-s, GPC believed : this1was 'necessary since f two )separateJArchitect Engineers (AEs) " worked on' Appendix; R- (one. for: each unit)..While-the results of - their work. met - the.." federal requirements, thew methodologies they. used =(including methodsfoff cross DindexingL data) were slightly different... In theE case of the cross indexing 'of data, one AE developed a computerized ;index, while-the.other AE relied on'a more manual' indexing technique.
The enhancements to the existing-documentation... involved, among other items,- the resolution and incorporation 'of outstanding.As '
(
Built Notices (ABNs) and L the 1 expansion: -of. some' of:.the L
documentation that correlateso equipment to specifico Appendix ~R
~
l related cables.
It is to be noted that the :information for..the-
[-
latter activity exists at. the plant.. However, concentrated:
i effort would'be needed.to perform the correlation. ' ThisJprogram (of enhancing the.: documentation) was. designed' to make the.
correlation easier and~more retrievable.
GPC also. recognized -that
'by.
implementing ~.-the
' document enhancement
- program, some -minor deficiencies. : could
'be.
encountered.
This ' was based' on the: fact that mostly control l'
circuits would be involved in the program.1.. Despite thel fact l
that.some discrepancies. were, anticipated,; GPC.' believed the..
j enhancement program was needed in order. to? have J the - highest quality, most easily retrievable information1 data' bas'e which i
documented the NRC approved Appendix R modification program.
The document enhancement program, 'to date, has found' two discrepancies.
Each is described as follows, l
-)
i.
1 1
0004I E-3
'10/30/87 SL-3366 l
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- 700Ti$
e 1
Georgia Powerd ENCLOSURE (Continued).
FIRE RATED ASSEMBLY INOPERABLE FOR LONGER THAN 14 DAYS RESULTS IN SPECIAL REPORT-AS: REQUIRED BY FIRE HAZARDS REPORI-Event of 9/16/87.
On. 9/16/87 at approximately 1443 CDT, representatives of the.
j Architect Engineer -(AE) reported-that -. a - Unit ' 2 : ' conduit,.
2E17073-1 A, did 'not meet the. fire rating requirements of the FHA ~
and 10 CFR.50. Appendix R. 'This activity occurred as :a part of
]
the documentation enhancement. program, ;specifically the: ABN; incorporation / verification activity.
Contract. personnel were in the.. process - of reviewing. an As Built Notice: '(ABN) 'for incorporation into the. final-design drawings of. the. plant. -The ABN was' issued against Design Change Request,(OCR)83-135'..
~
During the review, they noted' that 'there' were nine conduit supports that required fire wrapping.
These. supports were required to have a three hour. fire wrap.
However, the ABN information indicated that six of the.nine were wrapped with a.
one hour rated fire wrap.'
s In order to determine if.the discrepancy. was an.. approved deviation, plant personnel. reviewed the approved ~ exemptions - to
]
the Appendix R fire wrap requirements.. Theyl determined that an
' j exemption from the three hour fire rated.' wrapping 'requiremen.t.
for this conduit was requested but it was not> approved..
Personnel then performed a print-to-condJit walkdown of conduit 2E17073-1A.
They found that the conduit was protected with one-hour fire rated wrap material instead of three. hour ~ fire rated -
wrap.
This finding ~ 'was made 'at-a penetration near the south-west corner of Unit 2. reactor building 130 foot elevation.
4 1
.]
0004I E-4 10/30/87 o
SL-3366 1
a
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7001/5 J
Georgia Power A ENCLOSURE (Continued) i FIRE RATED ASSEMBLY IN0PERABLE FOR LONGER THAN 14 OAYS RESULTS IN SPECIAL REPORT AS REQUIRED BY FIRE HAZARDS REPORT Event of 9/22/87 On 9/22/87 at approximately 1045 CDT, representatives of the AE were performing a review of the current equipment-to-circuit list as part of the documentation enhancement program.
This review compared the current list to the original list.
The original list was completed between 1981 and 1982.
The review prccess was performed on'approximately 3000 circuits.
During the c' View, contract personnel determined that conduit c
2E21601-2A did not meet the fire rating requirement of the FHA l
Specifically thir one circuit did not have any fire wrap installed on it.
D.
CAUSE OF EVENT Event of 9/16/87 The cause of this event is personnel error on the part of Georgia Power Company (GPC) Appendix R personnel.
Specifically, project personnel failed to translate changed design information l
into work implementation packages.
The GPC personnel developed initial work packages based o~n the initial design.
Hhen the design changed, they failed to incorporate the changed information into revised work packages.
As a result of the out of date design information, the actual as built configuration of the plant was not in accordance with the approved final design.
It should be noted that the incorporation and review process for ABNs is not only part of the documentation enhancement program for Appendix R
documentation, but also. is part of the ongoing configuration control process at Plant Hatch.
l 0004I E-5 10/30/87 l
SL-3366 l
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700775
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l Georgia Power n(
i l
ENCLOSURE (Continued) i FIRE RATED ASSEMBLY IN0PERABLE FOR LONGER THAN 14 i
DAYS RESULTS IN SPECIAL REPORT AS REQUIRED BY FIRE HAZARDS REPORT j
i i
l l
Event of 9/22/87 a
1 The root cause of this event is personnel error on the part of-j AE (Bechtel). personnel.
Specifically, the AE. personnel l
committed an oversight when they performed the original safe shutdown analysis and the circuit _ in question was not initially j
identified as requiring any fire wrapping.
Since it was not
)
l identified on the original equipment-to-circuit list analysis as j
l requiring any fire wrap, none was installed during the f.ppendix l
l R modifications.
Based on the fact that this was the only J
example of this co.ndition in the 3000 citeuits reviewed, this i
event is believed to be isolated.
l l
E.
CORRECTIVE ACTIONS l
l The corrective actions.for these events included:
I 1.
Satisfying the requirements of the FHA once each event l
was reported to plant personnel.
.This included l
l establishing a fire watch.
2.
Continuing to implement the documentation enhancement program for the Appendix R documents.
3.
Initiating Design Change Request (DCR) 87-H2D-183 'to' correct the noted deficiency.
It is anticipated that-the corrective action associated with this DCR' will be completed by the end of the 1988 Unit 2 refueling outage.
This outage is tentatively sche _duled for the first quarter of 1988.
The requirements of the FHA will be maintained until the OCR is. fully implemented.
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700775
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