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| issue date = 03/19/1993 | | issue date = 03/19/1993 | ||
| title = Responds to NRC 930210 Ltr Re Violations Noted in Insp Repts 50-287/92-23 & 50-388/92-23.C/As:surveillance Procedures Will Be Revised to Address Types of Fire Barrier Matl to Be Inspected to Provide Acceptance Criteria for Fire Barrier | | title = Responds to NRC 930210 Ltr Re Violations Noted in Insp Repts 50-287/92-23 & 50-388/92-23.C/As:surveillance Procedures Will Be Revised to Address Types of Fire Barrier Matl to Be Inspected to Provide Acceptance Criteria for Fire Barrier | ||
| author name = | | author name = Keiser H | ||
| author affiliation = PENNSYLVANIA POWER & LIGHT CO. | | author affiliation = PENNSYLVANIA POWER & LIGHT CO. | ||
| addressee name = | | addressee name = Hodges M | ||
| addressee affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | | addressee affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | ||
| docket = 05000387, 05000388 | | docket = 05000387, 05000388 |
Revision as of 03:21, 18 June 2019
ML18026A425 | |
Person / Time | |
---|---|
Site: | Susquehanna |
Issue date: | 03/19/1993 |
From: | Keiser H PENNSYLVANIA POWER & LIGHT CO. |
To: | Hodges M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
References | |
PLA-3933, NUDOCS 9303250120 | |
Download: ML18026A425 (13) | |
See also: IR 05000287/1992023
Text
ACCELERATED
DOCUMENT DISTRIBUTION
SYSTEM REGULATORY
INFORMATION
DISTRIBUTION
SYSTEM (RIDS)ACCESSION NBR:9303250120
DOC.DATE: 93/03/19 NOTARIZED:
NO=DOCKET CIL:50-387
Susquehanna
Steam Electric Station, Unit 1, Pennsylva 05000387 50-388 Susquehanna
Steam Electric Station, Unit 2, Pennsylva 05000388 AUTH.NAME AUTHOR AFFILIATION
" KEISERgH.W.
Power&Light Co.RECIP.NAME
RECIPIENT AFFILIATION
HODGES,M.W.
Region 1 (Post 820201)r SUBJECT: Responds to NRC 930210 ltr re violations
noted in insp repts 50-287/93-23
&50-388/93-23.C/As:surveillance
procedures
will be revised to address types of fire barrier matl to be inspected to provide acceptance
criteria for fire barrier.DISTRIBUTION
CODE: IE01D COPIES RECEIVED:LTR
ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice
of Vio ation Response NOTES: RECIPIENT ID CODE/NAME PD1-2 PD INTERNAL: ACRS AEOD/DSP/TPAB
DEDRO NRR/DRCH/HHFBPT
NRR/DRSS/PEPB
NRR/PMAS/ILPB2
DIR-REG IL 02 RGNI FILE 01 EXTERNAL EG&G/BRYCE
g J~H~NSIC COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME CLARK,R AEOD/DEIB AEOD/TTC NRR/DORS/OEAB
NRR/DRIL/RPEB
NRR/PMAS/ILPBl
NUDOCS-ABSTRACT
OGC/HDS2 RES MORISSEAUiD
NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1'D NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM PI-37 (EXT.504-2065)TO ELIMINATE YOUR NAME FROM DISTRIBUTION
LISTS FOR DOCUMENTS YOU DON'T NEED!D TOTAL NUMBER OF COPIES REQUIRED: LTTR 23 ENCL 23
Power 8 Light Company Two North Ninth Street~Allentown, PA 18101-1179
~215/774-5151
Harold W.Keiser Senior Vice President-Nuclear
215/7744194
MAR 1 9 1993 Mr.Marvin W.Hodges, Director Division of Reactor Safety U.S.Nuclear Regulatory
Commission
Region I 475 Allendale Road King of Prussia, PA 19406 SUSQUEHANNA
STEAM ELECTRIC STATION REPLY TO NOTICE OF VIOLATION (EA 92-234)(387/92-23
&388/92-23)
PLA-3933 FILE R41-2 Docket Nos.50-387 50-388 Dear Mr.Hodges: This letter provides Pennsylvania
Power&Light Company's response to the Notice of Violation (EA 92-234)for NRC Combined Inspection
Report 50-387/92-23
and 50-388/92-23.
The Notice of Violation was dated February 10, 1993.The notice required submittal of a written reply within thirty (30)days of the date of the letter.However, as discussed with Mr.John R.White of NRC Region I on February 19, 1993, PPkL has been authorized
to delay the response until March 19, 1993.We trust that the commission
will find the attached response acceptable.
Very truly yours, Keiser Attachment
CC: NRC Document Control Desk (original)
Mr.G.S.Barber, NRC Sr.Resident Inspector Mr.R.J.Clark, NRC Sr.Project Manager Region I-Regional Administrator
9303250i20
9303i9 PDR ADOCK 05000387 8 PDR
ATTACHMENT
TO PLA-3933 FILE R41-2 PAGE 1 OF 10 REPLY TO A NOTICE OF VIOLATION A.Violation A (387/92-23-07;
388/92-23-07)
Technical Specification 3.7.7 states: "All fire rated assemblies, including walls, floor/ceilings, cable tray enclosures
and other fire barriers separating
safety related fire areas or separating
portions of redundant systems important to safe shutdown within a fire area,'nd all sealing devices in fire rated assembly penetrations, including fire doors, fire windows, fire dampers, cable and piping penetrations, seals and ventilation
seals shall be OPERABLE." Technical Specification 4.7.7.1.states: "Each of the above required rated assemblies
and sealing devices shall be verified OPERABLE at least once per 18 months by performing
a visual inspection
of: a.The exposed surfaces of each fire rated assembly." Contrary to the above, between December 1989 and September 4, 1992, the exposed surfaces of each fire rated assembly constructed
of Kaowool and the gypsum board enclosures
in Fire Zones 0-28A and 0-28B had not been verified operable.~Res onse See LER 50-387/92-015-01
for additional
details.1.Reason or the Violation Surveillance
of the exposed surfaces of Kaowool for station common areas was not adequately
performed between July 1990 and December 1992, and gypsum board enclosures
in Fire Zones 0-28A and 0-28B were not surveilled
between December 1989 and September 4, 1992 due to inadequacies
in surveillance
procedure SM-013-013.
This"procedure, which was revised in 1990, did not specifically
identify Kaowool and gypsum board as being fire barrier material.Consequently, personnel performing
the surveillance
were not cognizant that Kaowool and gypsum board enclosure barrier materials were to be surveilled.
The procedural
weaknesses (contributing
factors)in the 1990 revision were: Deletion of specific raceways required to be surveilled.
The raceway designations
were replaced with a reference to incorrect C-1700 series drawings that identified
raceway locations.(see Violation B)
-ATTACHMENT
TO PLA-3933 FILE R41-2 PAGE 2 OF 10 A lack of a description
of fire.barrier material to be inspected, and 2.Corrective
Ste s Wiiich Have Been Taken and the Results Achieved:, a.Kaowool fire barrier material was surveilled
in common plant areas in December 1992.Gypsum board enclosures
in Fire Zones 0-28A and 0-28B were declared inoperable
on January 5, 1993 and subsequently
have been redesigned
and are currently being reinstalled
to approved UL design.b.Additional
training and engineering
overview were provided to personnel performing
the December 1992 and January 1993 surveillances.
3.Corrective
Ste s Which Will Be Taken to Avoid Further Violations:
a.Surveillance
procedures
SM-013/113/213-013
will be revised to address the types of fire barrier material to be inspected and to provide appropriate
acceptance
criteria for each type of fire barrier.These procedures
will be revised by April 30, 1993.b.Surveillances
required by SM-013/113/213-013
will be reperformed
beginning in May 1993 and will be completed no later than the start up following the Unit 2 sixth'efueling
and inspection
outage currently scheduled to end on May 20, 1994.Individuals
performing
these surveillances
will receive training on the revised surveillance
procedures
prior to performing
the surveillances.
4, Date o Full Corn liance: Based on (2a)above, PPEcL is in full compliance.
ATTACHMENT
TO PLA-3933 FILE R41-2 PAGE 3 OF 10 B.Violation B (387/92-23-08)
Technical Specification 6.8.1 states, in part, that written procedures
shall be implemented
for the Fire Protection
Program.Procedure NDI-QA-15.3.1, Revision 3, Fire Protection
Program, states, in part: "This NDI outlines the unique responsibilities
and interfaces
required to implement the Fire Protection
Program." Attachment
1,"Fire Protection
Features And Activities
Requiring Quality," of NDI-QA-15.3.1 specified, in part, that: "Quality requirements
shall be, applied to the fire protection
features in the following areas:-a.Unit 1 Reactor Building;...d.Control Structure;
...j.Fire barrier wrapping identified
as being wrapped to meet Appendix R (10 CFR 50)in Drawings E 294 and E 295;k.Fire-rated
walls, fire-rated
floors,...fire-rated
seals within and enclosing the above areas (as specified on engineering
drawings)Contrary to the above, as of September 4, 1992, the following are examples found where procedures
had not been properly implemented
and, therefore, adequate quality was not applied to two series of design drawings for required fire protection
features in the Unit 1 Reactor Building and Control Structure.
~Drawing E-294 did not show Kaowool as fire barrier wrap material on conduits A1P105, C1P107, and A1P071 in Fire Zone 0-28H located in the Control Structure.
~One of the C-1700 series of drawings, Drawing C-1754, failed to show correctly the conduit run for conduits E1P353 and C1P077 in Fire Zone 0-28B-I located in the Control Structure.
~Drawing C-1721, Sheet No.2, Revision 1, and E-294 omitted showing that conduits E1K586 and E1K758 were wrapped with The'rmo-Lag
where they entered Fire Zone 1-2D located in the Control Structure.
~Drawing E-294, had no designation
in the title block indicating
the quality level of the drawing, and the C-Series drawings were incorrectly
labelled in the title block"NONQUALITY-RELATED."
ATTACHMENT
TO PLA-3933 FILE R41-2 PAGE 4 OF 10~Additional
examples where quality was inadequately
applied to these two series of Fire Protection
design drawings are identified
in Section 5.1 and Attachment
3 of Region I Inspection
Report 50-387 and 388/92-23 and are considered
part of this violation.
~Res ense 1.Reason or the Violation The errors in the Reactor Buildings and Control Structure E-294/295 and C-1700 series drawings, utilized for fire protection
activities, resulted from inadequate
drawing verifications
when the drawings were originally
developed.
Following initial installation
of fire barriers (installed
under a nonquality-related
program), PP&L requested that our A/E develop drawings to identify the location of the installed fire barriers.These drawings, E-294/295, were never field verified as to fire barrier locations or type of material utilized.The C-1700 series drawings which identify raceway layouts were subsequently
developed utilizing the E-294/295 drawings.No field verifications
were performed on the C-1700 series drawings except for plant modification
work activities
that utilize these drawings.These drawing errors were then propagated
in surveillance
procedures (see Violation A), engineering
studies and calculations
that utilized inputs from these drawings.Plant modifications
were field verified prior to installation.
See Violation"C" for additional
deficiencies
identified
from this walkdown.2.Corrective
Ste s Which Have Been Taken and the Results When the drawing errors were identified, PP&L initiated a comprehensive
walkdown of plant areas that contained fire rated raceway wrap.All accessible
raceways have been inspected.
Drawing errors have been corrected.
Additionally, Drawing Change Notices have been attached to drawings to identify the actual fire barrier material installed if mischaracterized
on the drawings.Further, engineering
studies and calculations
which utilized these drawings have been reviewed and corrected, where necessary.
3.Corrective
Ste s Which Will Be Taken to Avoid Further Violations:
a.The appropriate
classification
of the E-294/295 and C-1700 series drawings are being dispositioned
and will be maintained
as"as-built" drawings.Additionally, by revision or attachment, the notation"Quality-F" will be added to the title block of these drawings.The estimated completion
date for these activities
is April 30, 1993.b.Inaccessible
area walkdowns will be completed no later than the start up following the Unit 2 sixth refueling and inspection
outage currently scheduled to end on May 20, 1994.
ATTACHMENT
TO PLA-3933 FILE R41-2 PAGES OF 10 4.Date o Fu1l Com liance: PPEcL will be in full compliance
no later than the start up following the Unit 2 sixth refueling and inspection
outage currently scheduled to end on May 20, 1994.
ATTACHMENT
TO PLA-3933 FILE R41-2 PAGE 6 OF 10 C.Violation C (387/92-23-06)
The Susquehanna
Steam Electric Station Unit 1 Facility Operating License, NPF-14, was amended on March 27, 1990, by Amendment 95 to revise License Condition 2.C.(6), which states, in part:~"Pennsylvania
Power 8 Light Company shall implement and maintain in effect all provisions
of the approved fire protection
program as described in the Fire Protection
Review Report for the facility and as approved in the NRC Safety Evaluation
dated August 9, 1989...." Table 5.0-1, part C.4,"Inspection," of the Fire Protection
Review Report under the heading of"Susquehanna
SES Compliance" states, in part, that field personnel witnessed the fire protection
installation
and verified conformance
with design drawings.Bechtel Specification
8856-E-61, Revision 1,"Technical
Specification
for Electrical
Raceway Fire Insulation
Barrier Materials for the Susquehanna
Steam Electric Station Units-1 and 2 of the Pennsylvania
Power A Light Company, Allentown, Pennsylvania," was Susquehanna
Steam Electric Station's (SSES)design specification
for installing
safe shutdown cable raceway fire barriers during construction.
Drawing A-107, Revision 21,"Control Structure Upper Cable Sprdg Rm-El 744'-0" Battery Room-'El 771'-0"," describes construction
features and details of gypsum board enclosures
used to provide Appendix R protection
for redundant safe shutdown electrical
circuits and circuit breakers..
1.Bechtel Specification
8856-E-61, paragraph 6.4.6, states that Zetex shall have a minimum 3 inch overlap.Contrary to the above, on August 27, 1992, in Fire Zone 0-28H, the Cold Instrument
Shop, an approximately
20 square inches triangular
section of Kaowool was not covered with Zetex and the Zetex did not have the specified 3 inch overlap.2.Bechtel Specification
8856-E-61, paragraph 6.4.11, states that where the raceway penetrates
a fire barrier wall the juncture will then be sealed with mastic coating to not less than 1/4 inch thickness and shall not extend less than 8 inches onto the exterior of the blanket and surface of the fire barrier and wall.Contrary to the above, on September 1, 1992, in Fire Zone 1-4A-N, a conduit D1P008 fire barrier wrap junction at a fire rated wall was observed not to be sealed with mastic coating to the specified not less than 1/4 inch thickness and to not less than 8 inches onto the exterior of the blanket and surface of the fire barrier and wall.
ATTACHMENT
TO PLA-3933 FILE R41-2 PAGE 7 OF 10 3.Drawing A-107, Detail 4, Eley., provides details of a one hour gypsum fire barrier enclosure with an air gap between the inner and outer gypsum board.Contrary to the above, as of September 4, 1992, in Fire Zone 0-28B-II, a one-hour rated electrical
breaker enclosure fabricated
with gypsum board did not have the air gap between the inner and outer gypsum board making up the fire barrier enclosure as specified by the installation
drawing, A-107, in drawing detail number 4.4.Additional
examples where SSES's required fire protection
quality assurance inspections
failed to identify installation
deficiencies
that were not in conformance-
to the design specifications
are detailed in Section 4.3.4 and Attachment
3 of Region I Inspection
Report 50-387&, 388/92-23 and are considered
part of this violation.
~Res ossse 1.Reason or the Violation This violation incorporates
noncompliances
associated
with inadequate
surveillance
procedure acceptance
criteria and discrepancies
with initial construction
design documents.
Inadequate
surveillance
procedure acceptance
criteria (see Violation A)resulted in the following nonconformances
going undetected:
tom Zetex in Fire Zone 0-28H, and the interface between the raceway wrap and the wall was not sealed.The gypsum board construction
deficiency
in Fire Zone 0-28B-II would only have been identified
and dispositioned
at the time of construction.
Initial construction
of fire barriers at the Susquehanna
SES were not quality-related
activities
and inspections
of work activities
were determined
by responsible
field engineers.
No requirement
existed stating that all activities
be inspected.
Additionally, documentation
associated
with construction
of non-quality
inspection
activities
was only required to be maintained
until system turnover to PP&L.No documentation
on the gypsum board deviation was located, therefore the reason for this violation cannot be determined., In any case this deficiency
would not have been identified
through normal surveillance
activities.
2.Corrective
Ste s Which Have Been Taken and the Results Achieved: A comprehensive
walkdown of fire rated raceway wrap in accessible
areas was conducted (see Violation B).Results of these walkdowns identified
three raceways with incorrect materials, approximately
a dozen minor discrepancies, approximately
twenty minor maintenance
concerns (wear and tear items), and various drawing discrepancies.
The completion
date of the actions associated
with these deficiencies
is estimated to be April 30, 1993.
'ATTACHMENT
TO PLA-3933 FILE R41-2 PAGE 8 OF 10 3.Corrective
Ste s Which Will Be Taken to Avoid Further Violations:
a.Enhanced surveillance
procedures
will identify the type of issues noted in this violation;
therefore, additional
actions are not required.b.The improperly
installed gypsum board enclosure in Fire Zone 0-28B-II is being redesigned.
This new design is scheduled to be installed by April 30, 1993.c.Actions associated
with the drawing walkdown deficiencies
are scheduled to be completed by April 30, 1993.Any deficiencies-identified
in inaccessible
areas by the performance
of the revised surveillance
will be dispositioned
and resolved through currently established
processes.
4.Date o Full Com liance: PAL will be in full compliance
upon installation
of the redesign gypsum board enclosure in.Fire Zone 0-28B-II and the repair of other discrepancies
noted in (3)above.The identified
activities
are scheduled to be.completed by April 30, 1993.
ATTACHMENT
TO PLA-3933 FILE R41-2 PAGE 9 OF 10 C..Violation D (387/92-23-04)
The Facility Operating License, NPF-14, was issued on July 17, 1982, for Susquehanna
Steam Electric Station Unit 1 and contained a condition, 2.C.(7), Battery Room Area[Section 9.5.4, Safety Evaluation
Report (SER), Supplemental
Safety Evaluation
Report SSER¹1 and SSER¹3]stated that: r"Prior to exceeding five percent of-full power and subject to NRC review and approval, PP&L shall either conduct at an approved'testing
laboratory
an ASTM E-119 test of the as-installed
one-hour cable wrap configuration
or install an automatic fire extinguishing
system." The Facility Operating License, NPF-14 was amended on March 27, 1990, by Amendment 95 to revise License Condition 2.C.(6), which states in part: "Pennsylvania
Power&Light Company shall implement and maintain in effect all provisions
of the approved fire protection
program as described in the fire Protection
Review Report for the facility and as approved in the Safety Evaluation
dated August 9, 2989..." Contrary to the above, as of September 4, 1992, Susquehanna
Steam Electric Station was found to have a Kaowool wrap fire barrier installed in Fire Zone 0-28H., PP8rL did not subject this Kaowool cable wrap to an ASTM E-119 test at an approved testing laboratory
and PPAL did not submit this Kaowool cable wrap configuration
to the NRC for review and approval for use in Unit 1 Battery Room Area, Fire Zone 0-28H, at the Susquehanna
Steam Electric Station.There is no automatic fire extinguishing
system installed in Unit 1 Battery Room Area, Fire Zone 0-28H.Additional
examples of how SSES's use of Kaowool in Fire Zone 0-28H do not meet the requirements
of Deviation Request 8 or 17 of the Susquehanna
Steam Electric Station Fire Protection
Review Report are documented
in Region I Inspection
Report 50-387/92-23
and are considered
part of this violation.
~Res onse 1.Reason or the Violation Deviation Request No.17 of the Susquehanna
Steam Electric Station Fire Protection
Review Report requested a deviation from the requirements
of 10 CFR 50, Appendix R, Section III.G.2.c to permit the use of Kaowool as a one-hour fire barrier in plant areas where Kaowool was already installed.
This deviation request was a conservative
action intended to document the plant configuration.
Kaowool was accepted by the NRC as an
ATTACHMENT
TO PLA-3933 FILE R41-2 PAGE 10 OF 10 adequate one hour fire barrier in, Generic Letter 86-10 which was issued prior to requesting
this deviation.
The deviation request listed the affected fire areas/zones
where Kaowool is installed.
The deviation request stated that fire zones that contained Kaowool also had automatic fire detection and suppression
installed.
PPEcL did not recognize that Kaowool was installed in Fire Zone 0-28H in Deviation Request No.17 because of incorrect drawings used to develop the Request (see Violation B).Deviation Request No.8 of the Susquehanna
Steam Electric Station Fire Protection
Review Report requested a deviation from the requirements
of 10CFR50, Appendix R, Section III,G.2.a to permit the use of a one-hour fire barrier to separate redundant safe shutdown equipment/cables
in Fire Zone 0-28B-I, 0-28B-II, 1-2D, and 0-28H when automatic suppression
is not present.In responding
to Deviation Request No.8, NRC implemented
License Condition 2.C.7 in Operating License NPF-14 for Susquehanna
Unit 1 which required PPEcL to either conduct" at an approved testing laboratory
an ASTM E-119 test of the as-installed
one-hour cable wrap configuration
or install an automatic fire extinguishing
system." Since PPAL did not recognize that Kaowool was installed in Fire Zone 0-28H, we did not provide an ASTM E-119 test as required by this License Condition.
2.Corrective
Ste s Which Have Been Taken and the Results Achieved;The Kaowool fire barriers in 0-28H were replaced with pre-formed
Thermo-Lag
fire barrier material.3.Corrective
Ste s Which Will Be Taken to Avoid Further Violations:
E Kaowool fire barrier material will not be utilized for new fire barrier installations.
Existing Kaowool fire barriers in use at Susquehanna
SES are being maintained.
4.Date o Full Com liance: By taking the actions required by Bulletin 92-01 and Supplement
1, PPEcL is in full compliance
with Thermo-Lag
fire barrier material requirements.