ML18026A425

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

ML18026A425
Person / Time
Site:	Susquehanna
Issue date:	03/19/1993
From:	KEISER H W PENNSYLVANIA POWER & LIGHT CO.
To:	HODGES M W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
PLA-3933, NUDOCS 9303250120
Download: ML18026A425 (13)

See also: IR 05000287/1992023

Text

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INFORMATION

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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.

Pennsylvania

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

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Pennsylvania

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

penetration

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.