ML17261A833

Responds to NRC 881229 Ltr Re Violations 88-24-01 & 88-24-03 Noted in Insp Rept 50-244/88-24.Corrective Actions:Conduit Supports Rewrapped to Provide 1 H Protection for ASTM E119 Fire & Installation Spec Revised

ML17261A833
Person / Time
Site:	Ginna
Issue date:	01/27/1989
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8902030232
Download: ML17261A833 (18)

Text

ROCHESTER GAS AND ELECTRIC CORPORATION ~ 89 EAST AVENUE, ROCHESTER, N.K 14649.0001 C

cccf, is 5 '6-2 i<>O a~-cia'~ca January 27, 1,989 Hr. william T. Russell Regi onal Administrator U.S. Nuclear Regu'- c-y Commissi'n Region 475 I

Allendale Road King of Prussia, PA 2.9406

Subject:

Inspection Report 50-244/88-24 Notice of Violation R.E. Ginna Nuclear Power Plant Docket No. 50-244 License No. DPR-18

Dear Hr. Russell:

Your letter of December 29, 1.988, from Hr. Jacque P. Durr regarding Inspection Report No. 50-244/88-24, Transmittal Notice of Violation, Appendix A, which identified two violations, 88 01, and 88-24-03.

Rochester Gas and Electric, after performing investigations and/or analysis, during and subsequent to the inspection, concur with the violations as stated.

Violation 88-24-01 Routine Inspection Report 50-244/88-24, Appendix A, Notice of Violation, states in part:

"10 CFR 50, Appendix R, Section II1'. G requires that fire protection features be provided to safe shutdown components so that one train of systems requi red to achieve hot shutdown is free of fire damage. One method of ensuring that one of the redundant trains remains free of fire damage is the enclosure of cables and equipment in a fire barrier having a one hour rating.

Page 2 Mr. William T. Russell January 27, 1988 Contrary to the above, as a result of an inspection conducted on September 8-22, 1988, it was determined that the redundant train that provides steam generator pressure indication would not be free of damage by fire in the Intermediate Building, elevation 253 ~-6". Also, the redundant train that provides primary coolant make up would not be free of damage from a fire in the Auxiliary Building, Fire area ABBM. These redundant safe shutdown trains would be damaged by 'fire because the one hour fire barrier i i l i provided for cabl e enclosure was improperly ns tall ed.

mproperly nstal ed fire barrier was the one hour rated fire The wrap which protects conduit R975 for steam generator pressure indication and the fire wrap of conduits L400 and L398 required for the operation of'harging pump 1A".

Reason of Violation:

The one hour conduit fire wrap was procured as a proprietary system to be installed under vendor supervision. The installation specification was written by the vendor with a Gi nna site specific addendum added by RG&E. The intent of the installation specification was for all interferences to be wrapped with a four inch extension or totally encapsulated. Addendum 1 to the specification stated that all supports and interferences shall be protected a minimum of four inches measured linearly from the structure being protected. Diagrams of a cable tray wrapped in this manner are shown in the specification. One vendor supervisor used the specification as intended and the wrap installed under hi s supervision was adequate. The other vendor supervisor di d not understand the physical processes involved in heat transfer through the supports and interferences and interpreted the specification to require that only the four inch of wrap around the conduit would provide four linear i nches of wrap from the conduit. The supports wrapped under his supervi'sion were in most cases not adequate to protect the conduit for one hour of the ASTM Z119 fire. Three specific causes for this occurrence are:

Lack of training of vendor supervisor in basic physical processes involved in the installation.

2. Lack of suffi ci ent margin in the vendors design to.

accommodate diverse raceway support configurations found in t'e field.

3 ~ Lack of discussion in the installation specification as to the reason for providing insulation extension along supports and interferences.

Page 3 Mr. Vi lli January 27, am T. Russell 1989'orrective Steps Taken and Results Achieved:

The subject conduit supports are being rewrapped to provide full one hour protection for the ASTM E119 fire.

Corrective Steps Taken to Prevent Future Occurrences:

The i nstal lati on specification has been revised to require the equivalent of twelve inches of insulati on

'long supports and interrerences in future installations.

This provides sufficient margin to assure the one hour rating.

2. Analytical methods have been developed to evaluate any configurations where twelve inches cannot be achieved.

Date Vhen Full Compliance Vill Be Achieved:

All rewrapping will be complete by February 15, 1989.

Violation 88-24-03 Routine Inspection Report 50-244/88-24, Appendix A, Notice of; Violation, states in part:

License Condition C. (3) Fire Protection, requires that the licensee maintain in effect all fire protection features described in the NRC's Fire Protection Safety Evaluation (SE) dated February 1,4, 1979. The SE in 3. 1. 31 requires that quarterly fire drills be conductedparagraph for each shift brigade and in paragraph 6.2 it requires that the quarterly drills be preplanned.

Contrary to the above, on November 15-17, 1988, determined that the li it was censee di d not perf orm prepl armed fire drills cparterly for all shift brigades. In the first quarter of 1988, four out of five shift brigades did not attend a preplanned fire drill, in the second quarter two out of five shift brigades did not participate in a preplan.,ed fire drill, and in the third quarter, three out of six shift brigades did not participate in a preplanned fire drill.

S Page 4 Mr. William T. Russell January 27, 2989 Reason for Violation:

RG&E was taking credit for actual fire brigade response to fire al arms. This practice was considered acceptable since cri tiques were conducted by the Brigade Leader following each credited, response. Additionally, each alarm response report was reviewed quarterly wi th all brigade members to discuss alarm response protocols. Under these auspices, each brigade did ',meet the quarterly training requirements. However, since the al arm responses could not be preplanned as required, drill credit would appear questionable and inconsistent with requirements.

Corrective Steps Taken and Results Achieved:

Remedial steps taken were to schedule and conduct preplanned fire drills for all shifts in the last quarter of 2988.

Corrective Steps Taken to Prevent Future Occurrences:

Administrative Procedure A-203. 9, "Fire Brigade Training",

has been changed to require all fire drills to be preplanned and to, delete the step taking credit for fire alarms as fire drills.

Date When Full Compliance Vi ll Be Achieved:

Full compliance was achieved during last quarter of 2.988.

Very truly yours, Robert C. M cred General Manager Nuclear Production xc: U.S. Nuclear Regulatory Commission (Ori ginal)

Document Control Desk Washington, DC 20555 Ginna Station NRC Senior Resident l'nspector

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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CESSION NBR:8902030232 DOC.DATE: 89/01/27 .NOTARIZED: NO DOCKET N FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION MECREDY,R.C. Rochester Gas & Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION RUSSELL,W.T. Region 1, Ofc of the Director

SUBJECT:

Responds to NRC 881229 50-244/88-24.

ltr re violations noted in Insp Rept DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244S RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL h.

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%OAK S'IATE ROCHESTER GAS AND ELECTRIC CORPORATION ~ 89 EAST AVENUE, ROCHESTER, N. Y. 14649-0001 TCLCP<ONL ARcA coot Tlat 546.2700 January 27, 2989 Mr. Wi Regional Administrator lli am T. Russell U.S. Nuclear Regulatory Commission Region 475 I

Allendale Road King of Prussia, PA 29406

Subject:

Inspection Report 50-244/88-24 Notice of Viol a ti on R.E. Ginna Nuclear Power Pl.ant Docket No. 50-244

,License No. DPR-28

Dear Mr. Russell:

Your letter of December 29, 2.988, from Mr. Jacque P. Durr regarding Inspection Report No. 50-244/88-24, Transmittal Notice of Violation, Appendix A, which identified two violations, 88 Ol, and 88-24-03.

Rochester Gas and Electri c, after performing investigations and/or analysis, during and subsequent to the inspection, concur

, with the violations as stated.

Violation 88-24-02, Routine Inspection Report 50-244/88-24, Appendix A, Notice of Violation, states in part:

"10 CFR 50, Appendix R, Section III.G requires that fire protection features be provided to safe shutdown components so that one train of systems required to achieve hot shutdown is free of fire damage. One method of ensuring that one of the redundant trains remains free of fire damage is the enclosure and equipment in a fire barrier having a one hour rating. of'ables

Pape 2 Mr . William T. Russell January 27, 1988 Contrary to the above, as a result of an inspection conducted on September

'train that 8-22, 1988, it was determined that the redundant provides steam generator pressure indication would not be free of damage by fire in the Intermediate Building, elevation 253 '-6". Also, the redundant train that provides primary coolant make up would not be free of damage from a fire in the Auxiliary Building, Fire area ABBM. These redundant safe shutdown trains woul d be damaged by fire because the one hour fire barrier provided for cable enclosure was improperly i nstal led. The improperly installed fire barrier was the one hour rated fire which protects condui t R975 for steam generator pressure 'rap indication and the fire wrap of conduits L400 and L398 required for the operation of charging pump 1A".

Reason of Violation:

The one hour conduit fire wrap was procured as a proprietary system to be installed under vendor supervision. The installation specification was written by the vendor with a Ginna site specific addendum added by RGEE. The intent of the installation specification was for all interferences to be wrapped with a four inch extension or total ly encapsulated. Addendum 1 to the specification stated that all supports and interferences shall be protected a minimum of four inches measured linearly from the structure being protected. Diagrams of a cable tray wrapped in this manner are shown in the specification. One vendor supervisor used the specification as intended and the wrap installed under hi s supervi si on was adequate. The other vendor supervisor di d not understand the physical processes i nvol ved in heat transfer through the supports and interferences and interpreted the specification to require that only the four inch of wrap around the conduit woul d provide four linear inches of wrap from the conduit. The supports wrapped under his supervision were in most cases not adequate to protect the conduit for one hour of the ASTM E119 fire. Three specific causes for this occurrence are:

Lack of training of vendor supervisor in basic physical processes involved in the installation.

2. Lack of suffi ci ent margin in the vendors design to accommodate diverse raceway support configurations found in the fiel d.

3. Lack of discussion in the installation specification as to the reason for providing insulation extension along supports and interferences.

Page 3 Mr. William T. Russell January 27, 2989 Corrective Steps Taken and Results Achieved:

The subject conduit supports are being rewrapped to provide full one hour protection for the ASTM E229 fire.

Corrective Steps Taken to Prevent Future Occurrences:

The installation specification has been revised to i

require the equi valent of twelve inches of nsul ation along supports and interferences in future installations.

This provides sufficient margin to assure the one hour rating.

2. Analytical methods have been developed to evaluate any configurations where twelve inches cannot be achieved.

Date When Full Compliance Will Be Achieved:

All rewrapping will be complete by February 25, 2989.

Violation 88-24-03 Routine Inspection Report 50-244/88-24, Appendix A, Notice of Violation, states. in part:

License Condition C. (3) Fire Protection, requires that the licensee maintain in effect all fire protection features described in the NRC's Fire Protection Safety Evaluation (SE) dated February The SE in paragraph 3. 2. 32 requires that fire drills be conducted for each shift brigade and in quarterly 24, 2979.

6.2 it requires that'he quarterly drills be preplanned.

paragraph Contrary to the above, on November 25-27, 2988, determined tha t the li it censee di d not perform pre pl armed fire was drills quarterly for all shift brigades. In the first quarter of 2988, four out of five shift brigades did not attend a fire drill, in the second quarter two out of five shiftpreplanned brigades did not participate in a preplanned fire drill, and in the third quarter, three out of six shift brigades did not participate in a preplanned fire drill.

Page 4 Mr. William T. Russell January 27, 2989 Reason for Violation:

RG&E was taking credit for actual fire brigade response to fire alarms. This practice was considered since cri ti ques were conducted by the Brigade Leaderacceptable following each credited response. Additionally, each alarm response report was reviewed quarterly wi th all brigade members to discuss alarm response protocols. Under these auspices, each brigade did meet

=

the quarterly training requirements. However, since the alarm responses could not be preplanned as required, drill credit would appear questionable and inconsistent with requirements.

Corrective Steps Taken and Results Achieved:

Remedial steps taken were to schedule and conduct fire drills for all shifts in the last quarter of 2,988. preplanned Corrective Steps Taken to Prevent Future Occurrences:

Administrative Procedure A-103. 9, "Fire Brigade Trai ni ng",

has been changed to require all fire drills to be preplanned and to delete the step taking credit for fire alarms as fire drills.

Date When Full Compliance Will Be Achieved:

Full compliance was achieved during last quarter of 2,988.

Very truly yours, Robert C. M cred General Manager Nuclear Production xc: U.S. Nuclear Regulatory Commission (Original)

Document Control Desk Washington, DC 20555 Ginna Station NRC Senior Resident Inspector

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