ML18093B435

Supplemental Special Rept 88-3-6:on 880720,0809,0907,1011, 1107,1207 & 890105,impaired Penetrations Not Repaired within 7 Days as Specified by Tech Spec 3.7.11.a.Caused by Addl Review by Penetration Seal Task Force.Fire Watch Continued

ML18093B435
Person / Time
Site:	Salem
Issue date:	02/01/1989
From:	Miller L Public Service Enterprise Group
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
88-3-6, NUDOCS 8902090502
Download: ML18093B435 (7)

Text

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• ,. PS~G Public Service Electric and Gas Company P.O. Box E Hancocks B1*idge, New Jersey 08038 Salem Generating Station February 1, 1989 U~ S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Dear Sir:

S~LEM GENERATING STATION LICENSE NO. DPR-70 DOCKET NO. 50-272 UNIT NO. 1 SUPPLEMENTAL SPECIAL REPORT 88-3-6 This supple~ental Special Report addresses additional fire barrier penetration seal impairments which ha~e not been restored to functional status within seven (7) days. These impairments have been identified by the Penetration Seal Task Force. This report has been prepared in accordance with the reporting requirements of Technical Specification Action Statement 3.7.11.a pursuant to Technical Specification 6.9.2.

Sincerely yours, L. K. Miller General Manager-Salem Operations MJP:pc Distribution 8902090502 890201 PDR ADOCK 05000272 S PDC

UNIT 1 SPECIAL REPORT ~3-6 Salem Generating Station - Units 1 & 2

.Public Service Electric & Gas Company Hancock's Bridge, New Jersey 08038 Technical Specification 3.7.11; Fire Barriers Impaired For Greater Than 7 Days Event Date(s): 7/20/88, 8/09/88, 9/07/88, 10/11/88, 11/07/88, 12/07/88, 1/05/89 Report Date: 2/01/89 This report was initiated by Incident Report Nos.88-268, 88-531,88-536, 88-537,* 88-544, and 89-050.

N/A As identified in PSE&G letter NLR-N88037 dated March 4, 1988, PSE&G has initiated a comprehensive review/inspection of fire barrier penetration seals. Due to the additional review by the Penetration Seal Task Force, penetrations found impaired are not being r~paired within seven days as specified by Technical Specification Action Statement 3.7.11.a. This report summarizes the task force findings and Technical Specification 4.7.11 surveillance activity findings associated with inadequate penetration seals for both Unit 1 and Unit

2. The inadequate penetration seals found, to the date of issue of this report, include:

On July 13, 1988 two fire Barrier cable penetration were found degraded. The penetration contained electrical sleeving containing an electrical cable surrounded by foam type fire sealant. The area (approximately 1/8" gap and 1/4" gap respectively) surrounding the electrical sleeves were not sealed thereby constituting an impaired seal. The fire barrier is in the east wall of the 100' Elevation Relay Room.

On July 25, 1988 three (3) degraded fire barrier cable penetration seals were found on the south wall in the 100' Elevation Relay Room. Two (2) of these penetrations are 3" in diameter and the other is 5.5 (located .-13 feet above the floor). The 3" penetrations contain fire wrapped cabling. This fire wrap extends over the penetration. There is no foam behind the fire wrap. It provides a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated barrier, however, the wall is a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barrier. The 5.5" penetration contains a 4" conduit surrounded by foam. The foam contains an 1/8" gap at the base of the conduit.

On July 28, 1988 one (J.) 3.5" degraded fire barrier cable p *m::: tr a t i o T'_ ~ ea l wo. s f o u n d on th e north wa J. J i '"1 t he 1 0 0 '

Elevation Relay Room. The penetration contains cablinq

Unit 1 SPECIAL REPORT tt-3~6 surrounded by foam. The foam contains an 1/2" diameter hole.

Between August 2, 1988 and August 30, 1988, 138 additional penetration seals were found impaired of which 134 penetrations*

are located in the Unit 1 Relay Room and 4 penetrations are located in the Unit 1 lA 125 V Battery Room. The penetrations range in size from -3 inches to -6 inches in diameter. The nature of the impairments include 6 with no seal, 14 with a hole in the seal (unknown cause), 2 with foreign material imbedded in the seal (one imbedded with a rag and the other with duct tape),

30 with a void in the. seal (due to inadequate quantity of foam injection upon installation), 6 with apparent degradation (e.q.,

cable pulled through) 47 with inadequate color/cell structure

{reference LER 272/88-013-00) and 32 that are not deep enough into the penetration per design (less than 6 inches).

Between August 31, 1988 and January 30, 1989, 2450 penetration seals were reviewed. Of these, 660 penetration seals were determined to be impaired. The majority of penetrations range in size from -3 inches to -6 inches in diameter. There were 40 penetrations which were larger than 6 inches in diameter. These penetrations ranged from 3"x5" to 36"x42".

Page 3. of this report contains a table of the penetration seals found impaired, between August 2, 1988 and January 30, 1939, in relation to the fire zone where they were found. The impairment designator terms include:

No Seal NOS Hole in Seal HOL Void in Seal VIS Depth Not Great Enough DPT Color/Cell Structure CEL Seal Degradation DEG Foreign Material Imbedded FMT Planned Impairment PIM An hourly fire watch patrol had been established for the above areas previously due to other fire protection concerns. Therefore, the requirements of Tech. Spec. Action Statement 3.7.11.a are met.

Unit 1 Technical Specification 3.7.11 states:

"All*fire penetrations (including cable penetration barriers, fire doors and fire dampers), in fire zone boundaries, protecting safety related areas shall be functional."

Unit 1 Technical Specification Action Statement 3.7.11.a states:

"With one or more of the above required fire barrier penetrations non-functional, within one hour either establish a continuous fire watch on at least one side of the affected penetration, or verify the OPERABILITY of fire detectors on at least one side of the non-functional fire barrier and establish an hourly fire watch patrol. Restore tbe non-£1..inctionaJ fire

UNIT 1 SPECIAL REPORT tt-3-6 barrier penetration(s) to functional status within 7 days or, in lieu of any other report required by Specification 6.9.1, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within the next 30 days outlining the action taken, the cause of the non-functional penetration and plans and schedule for restoring the fire barrier penetration(s) to functional status."

NOTE - Unit 1 Technical Specification,3.7.11 differs from Unit 2. The words "functional" and "non-functional" are replaced by the words "OPERABLE and "inoperable".

TABLE OF INOPERABLE PENETRATION SEALS 8/02/88 - 1/30/89 AREA NOS HOL VIS DPT CEL DEG FMT PIM U-1 Relay Room 4 34 47 58. 91 7 2 l**

U-1 lA D/G Control Room 1 1 2 13 U-1 lB D/G Control Room 1 16 1 U-1 lC D/G Control Room 1 1 10 8 U-1 lA 125 V Battery Room 2 3 2 U-1 #1 250 V Battery Room 1 1 5 U-1 #3 Stairwell 1 1 U-1 84' Elevation, Aisle 4 1

1. 1 Auxiliary Buildino U-1 122' Elevation, N2 1 1 Bottle Storage Area U-1 84' Corridor; Unit 1 & 3 3 2 Common East & West

• U-1 78' Electrical Penetra. 1 Area U-1 100' Boric Acid Transfer 1 1 Pump Area U-1 100' El. Mechanical 1 5 2 1 Penetration Area - Blowdown Tanks U-1 100' El. Corridor 2 3 2 1 1 Service Building U-1 100' Elevation, Aisle 1 2 2 3 13

1. 1 Auxiliary Building

UNIT 1 SPECIAL REPORT tt-3-6 TABLE OF INOPERABLE PENETRATION SEALS _(_t;_Qn_t_'_fil

---

------- ----3-;~o-27~i8---:..- -i/".301s*9- ------

AREA NOS HOL VIS DPT CEL DEG FMT PIM U-1 100' Corridor; Unit 1 & 13 7 7 28 34 1 2 Common East & West

• U-1 84' Corridor; Unit 1 & 3 3 2 Common East & West

• U-1 100' Lobby 1 U-1 11/12 Containment Spray 3 4 Pumps & Spray Add. Tank Area U-1 100' Corridor; Unit 1 & 2 4 3 1 185 2 2 CommorrNorth & South U-1 100' Elevation Counting 6 1 1 Room U-1 #11 Diesel Oil Tk Room 1 1 3 U-1 #12 Diesel Oil Tk Room 2 U-1 84' Elev. Control Area 3 6 9 24 1

1. 1 Transformer Bus Rm.

U-1 Spent Fuel Pit Heat 1 14 Exchanger & Pump Area U-1 lA Diesel Generator Area 5 1 1 U-1 lB Diesel Generator Area 1 7 3 U-1 lC Diesel Generator Area 3 1 2 2 U-1 Waste Evaporator Room 3 1 1 U-1 100' Elevation Mechanical 4 Penetration Area U-1 UPS Battery Room 1 U-2 100' El. Mechanical Pene. 2 Area - Blowdown Tanks U-2 100' Elevation Mechanical 1 1 Penetration Area U-2 AC & Boric Acid Tank Room 2

- .U-2 Relay Room 4 1

• - The opposite room for the north and e~st walls is the Unit 2 Relay R0orr1.

• • - The Relay Room PIM was resealed thirteen days after opening

UNIT 1 SPECIAL REPORT ~3-6 The cause of the degraded fire barrier penetrations could not be positively determined.

The east-wall penetrations (discovered 7/13/88) from the Relay Room_

side appe~red" sealed visually due to the use of a bushing on the sleeve which hid the gap. The 3.5" south wall penetrations (discovered 7/25/88) also appeared sealed from the Relay Room side, as described in the Description of Occurrence section. Closer inspection, as required by the Seal Penetration Review Group procedures, revealed the nature of the impairments. Technical Specification Surveillance 4.7.11 requires verification of the functional status of fire barrier penetrations every eighteen months via a visual inspection. This inspection would not necessarily identify the non-functional status of the subject penetrations.

The 5.5" south wall penetration (found July 25) is located in a difficult to reach location. The gap in the seal may have formed due to shrinkage. It does not appear as though a cable was pulled (forming the gap).

The 3.5" north wall pen~tration (found July 28) is also located in a difficult to reach location. The gap in the seal appears to have formed as a result of a cable pull. It has not been determined when or by whom the cable was pulled.

The penetrations with non-f~ncti6nal seals, found between August 2, 1988 and January 30, 1989, are similar in configuration (except as noted) to the penetrations identified in the original issue of this Special Report. The cause of their degraded condition also could not positively be determined.

ANALYSIS OF OCCURRENCE:

The functional integrity of the penetration fire barriers ensures that fires will be confined or adequately retarded from spreading to adjacent portions of the facility. This design feature minimizes the possibility of a single fire involving several areas of the facility.

The fire barrier penetration seals are a passive element in the facility fire protection program and are subject to periodic inspections. This report satisfies the reporting requirements of Technical Specification 3.7.11.a pursuant to Technical Specification 6.9.2 since the time between discovery and eventual repair of the fire barrier impairments is* greater than seven (7)* days. Appropriate actions were already in place in accordance with the requirements of Technical Specification Action Statement 3.7.11.a to establish a one hour roving fire watch for the impaired fire barriers once the impairments were identified.

The subject fire area contains detection in addition to the roving fire watch patrol. Therefore, it is reasonable to assume that a fire in either area would be detected before it could involve an adjacent area. This occurrence therefore involved no undue risk to the health or safety of the public.

CORRECTIVE -- ACTION: . -

ThE hourly fire watch, as a~dresse~ in the Description of OccurreDce

UNIT_ 1 SPECIAL REPORT 6 section, will continue until all fire protection concerns associated with these areas are resolved.

The repair of the penetrations was not accomplished within seven (7) days due to the additional *review being conducted by the Penetration Seal Task Force. Upon completion of this review the penetrations will be sealed.

The majority of those penetrations in the Unit 1 and Unit. 2 Relay Rooms (halon discharge areas) which either have no seal or holes through the seal have been sealed using approved station procedure M3Y, "Installation and Repair of Fire Barrier and Flood Protection Seals".

This review and corrective action will be completed in accordance with PSE&G letter NLR-N88037, dated March 4, 1988, to the NRC which discusses the Penetration Seal Review Program schedule and the telecommunication between PSE&G and the NRC Region 1 office conducted on August 26, 1988.

tu.Jfl General Manager -

Salem Operations MJP:pc SORC Mtg.89-005