IR 05000425/1988052

Insp Rept 50-425/88-52 on 880829-0901.No Violations or Deviations Noted.Major Areas Inspected:Hot Functional Controlling Procedure Review & RCS Primary Hydrostatic Test Results Evaluation

ML20155E745
Person / Time
Site:	Vogtle
Issue date:	09/21/1988
From:	Jape F, Taylor P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20155E744	List: IR 05000425/1988052 ML20155E738
References
50-425-88-52, NUDOCS 8810120395
Download: ML20155E745 (4)

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. UNITED STATIS

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'N E NUCLEAR REGULATORY COMMISSION

'o REGION 11 Y g'O j[ 101 MARIETTA ST., N.W.

e,,,, ATLANTA, GEORGIA 30323 Report No. : 50-425/88-52 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-425 License No.: CPPR-109 Facility Name: Vogtle 2 Inspection Conducted: August 29 - September 1,1988 Inspector:[ d.. (/# */ - 2 /- t' F P. A. Tayldr Date Signed Approved by: 4M 12JL- I[2/ /.P8 F. Jape, Chief (/ / Date Signed Test Programs Section Engineering Branch Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection was conducted in the areas of hot functional controlling procedure review and reactor coolant system primary hydrostatic test results evaluation.

Results: In the areas inspected, violations or deviations were not identified.

The review of the controlling procedure for hot functional testing indicated a well planned document had been developed 'o establish requirements and to sequence intergrated hot functional testing. Hinor procedural corrections were identified (Paragraph 2) during the review.

8910120395 880923 PDR ADOCK 05000425 O PNU

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REPORT DETAILS

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1. Persons Contacted Licensee Employees

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j M. Ajulni, Operations Superintendent

• M. Bagale, Hot Functionals Test Manager

• B. D. Carter Hot Functionals Operations Manager

• A. B. Gallant, Project Compliance Coordinator

• E. D. Groover, Quality Assurance Site Manager - Construction

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• S. M. Hall, Procedures Superintendent - Unit 2

• H. M. Handfinger, Project Startup Manager

• M. Horton, Superintendent Test Engineers

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• P. D. Rice, Vice President and Project Director Other licensee employees contacted during this inspection ircluded engineers, and administrative personnel.

NRC Resident Inspector

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, R. S. Schepens

• Attended exit interview

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2. Review of Hot Functional Sequencing Procedure (70308)(70300)

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a. The licensee approved on June 21, 1988, RCS Hot Functional Test Procedure 2-300-07, Revision 0. This procedure is used to control and sequence hot functional testing during the heatup of the Reactor

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Coolant System (RCS) to normal operating conditions and the subsequent cooldown demonstration of the RCS. This test procedure was reviewed to confinn that:

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- The test procedure is consistent with FSAR Chapter 14 and Regulatory Guide (RG) 1,68 comitments regarding demonstration of component and systen operability in all modes and throughout full design operating range.

- Thermal ex vibration (piping and reactor vessel internals) pansion, and restraint tests are scheduled during hot

functionals.

- Water chemistry controls are established.

- Preconditioning criteria for RCS internals are established, a

- Overall plant testing has been identified and scheduled to be

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- Plant procedures are checked to detennine their adequacy.

- The test procedure contained the required reviews, management approvals, precautions and acceptance criteria.

- Prerequisites are provided which require that system open items, punch listed items, outstanding construction and preoperational tests are reviewed to determine that plant systems are ready to support the hot functional testing sequence.

The review of the controlling procedure for hot functional testing resulted in the following Inspector Followup Item.

(1) Inspector Followup iten (!FI) 425/88-52-01, Correct Hot functional Procedural items listed below:

(a) Procedure 2-300-07 Step 6.5.2.4 Test Results Review. Add the following preoperational tests to the list of tests requiring review prior to cooldown.

- Special Test-39, Metal Impact Monitoring System

- 2 388-02, Pressurizer Relief Tank

- 2-38G-03, Boro:: Thermal Regeneration System

- 2 3AE-01, Main Feedwater (b) Provide a method to ensure test personnel are aware of requirements to document any planned or unplanned actuation of safety injection during hot conditions, RG 1.79, Revision 2. Section C.2.a.

(c) 2-300-07 Step 6.6.1.4, Cooldown From Outside the Control Room. Add the specific RCS pressure which operator will be required to achieve.

(d) 2 300-10, Shutdown Panel Preoperational Test. Provide for recording RCS pressure decreases on existing data table.

RG 1.68.2 requires a demonstration of pressure control as well as tenperature control during the cooldown at the remote shutdown panels.

(e) 2-300-10, and Abnormal Operating Procedure 18038, Operation From Remote Shutdown Panels. These two documents do not agree as to appropriate step number to use in the AOP and plant pressure to obtained and maintain.

Within the areas inspected, no violations or deviations were identified.

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3. Reactor Coolant System Hydrostatic Test Results Evaluation (70562)

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The inspector reviewed the test results of Test Procedure 2-300-03, RCS t. Primary Hydrostatic Test, Revision 1. approved April 27, 1988, to verify j that:

- Test steps and data sheets identified data recorders

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- Test results met the acceptance criteria

- Changes made to the procedure did not change the purpose of the test

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- The licensee had evaluated the test results and management approval received as requ; red by administrative controls j - Deficiencies identified during the test were evaluated and corrective action ioantified as required.

l The RCS hydrostatic test was completed satisfactorily May 9,1988.

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With the areas inspected, no violation or deviations were identified.

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) 4 Exit Interview I

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The inspection scope and results were summarized on September 1.1988,

with those persons indicated in Paragraph 1. The inspector described the

areas inspected and discussed in detail the inspection results listed

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below. Proprietary informa tion is not contained in this report.

Dissenting comments were not received from the licensee.

IFI 425/83-52-01, Correct Hot Functional Procedural items, Paragraph 2.

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O >SEG Potmc Scruce Elecu .: and G as Cmor an / P O in E Hanuxts Bo I;e. tb ,< Jenn C3333 Salem Generating Station October 4, 1988 U. S. lluclear Regulatory Comminsion Document Co.itrol Desk Washington, DC 20555

Dear Sir:

SALEM GEllERATING STATIOli L I C Ell S E 11 0 . DPR-70 DOCKET 110, 50-272 Uti1T NO. 1 SUPPLEMEfiTAL SPECIAL REPORT 88-3-2

{ This supplemental Special Report addresses additional fire barrier penetration irepairments which have not been restored to functional status within seven (7) dayn. These impairments have been discovered by the Penetration Seal Task Force. This report satisfies the reporting requirements of Technical Specification Action 3.7.11.a pursuant to Technical Specification 6.9.2. It is being submitted within thirty (30) days as per the Action Statement.

Sincerely yours, a .-

L. A. Miller General Manager-Salem Operations HJP:pc Distribution 89101f 'e DR o'3  ;

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. UNIT 1 SPECIAb REPORT 88-3-2 P L ANT _I D ENTI FI_Q ATI_ON_;_

Salem Generating Station - Unit 1 Public Service Electric & Gas Company Hancock's Bridge, New Jersey 08038 IDENTIFICATION OF OCCURR_ENCE1 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 l Report Date: 10/04/88 l This report was initiated by Incident Report No.88-268.

CONDITIONS PRIOR 10_O_QQURRENQE:_

N/A DESCRIPTION _OF_OC.QURRENCE:_

As identified in PSE&G 1etter 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 repaired within seven days as specified by Technical Specification Action Statement 3.7.11.a. This report summarizes the task force findings associated with inadequate penetration seals. 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 '18 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 (1) 3.5" degraded fire barrier cable penetration seal was found on the north wall in the 100'

Elevation Relay Room. The penetration contains cabling surrounded by foam. The foam contains an 1/2" diameter hole.

Between August 2, 1988 and August 30, 1998, 138 additional penetration seals were found impaired of which 134 penetrations

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, UNIT 1 SPECIAL REPORT 88-3-2 -2-q.

DESCRIPTIO!LOF_pCC.URRENCE :_(cont'd)_

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are located in the Unit 1 Relay Room and 4 penetrations are located in the Unit 1 1A 125 V Dattery 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), i 30 with a void in the seal (due to inadequate quantity of foam l 1 injection upon installation), 6 with apparent degradation (e.g.,

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J cable pulled through) 47 with inadequate color / coll structure j (reference LER 272/88-013-00) and 32 that are not deep eaough

into the penetration per design (less than 6 inches),

i Between August 31, 1988 and September 30, 1988, 74 additional i

penetration seals were found impaired. The majority of :

penetrations range in size from ~3 inches to ~6 inches in ;

diameter. One floor penetration in the 84' Elevation Aisle #1 i

East Section is 47"x12".

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Page 3 of this report contains a table of the penetration seals found impaired, between August 31, 1988 and September 30, 1988, in relation to the fire zone where they were found. The

impairment designator terms include

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l No Seal NOS >

J Hole in Seal HOL i i Void in Seal VIS l Depth Not Creat Enough DPT l Color / Cell Structure CEL L l Seal Degradation DEG

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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. '

Technical Specification 3.7.11 states: f i  !

! "All fire penetrations (including cable penetration barriers, I

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fire doors and fire dampers), in fire zone boundaries, l protecting safety related areas shall be functional." I

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i l Technical Specification Action Statement 3.7.11.a states: :

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) "With one or more of the above required fire barrier i

, penetrations non-functional, within one (1) hour either l i establish a continuous fire watch on at least one (1) side of l 1 the affected penetration, or verify the OPERABILITY of fire i

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! detectors on at least one (1) side of the non-functional fire l barrier and establish an hourly fire watch patrol. Restore the 1 non-functional fire barrier penetration (s) to functional status i j within 7 days or, in lieu of any other report required by J 3 Specification 6.9.1, prepare and submit a Special Report to the !

l Commission pursuant to Specification 6.9.2 within the next 30 l

days outlining the action taken, the cause of the non-functional -

penetration and plans and schedule for restoring the fire [

j barrier penetration (s) to functional status."

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,N!/IT 1 SPECIAb REPORT 88-3-2 -3-TABLE OF INOPERABLE PENETRATION SMALS 8/31/88 - 9/30/88 i

AREA NOS HUIj VI S. DPT CEL DEG.

I U-1 Relay Room 8 16 17 8 2 U-1 1A 125 V Battery Room 1 * 2 1 U-l #1 250 V Battery Room 3 * 1 1 5

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1. 12 RHR Pump Room 2 U-1 #3 Stairwell 1 1 U-1 84' Elevation, Aisle #1 4 1 !

Auxiliary Buildinq  !

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Three of these penetrations are 18"x8" and one penetration is 8"x6"; all contain fire dampers with NOS around

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perimeter of dampers i

APPARENT _CAUSE_OF_ OCCURRENCE;

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The cause of the degraded fire barrier penetrations could not be positively determined.

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i The east wall penetrations (discovered 7/13/88) from the Relay Room

! side "appeared" nealed visually due to the use of a buching on the

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sleeve which hid the gap. The 3.5" south wall penetrations

(discovered 7/25/88) also appeared scaled from the Relay Room side, i as deceribed 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 nontha via a visual inspection. This inspection would not necessarily

identify the non-functional status of the subject penetrations.

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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 j (forming the cap). '

The 3.5" north wall pen etration (found July 28) is alao located in a l difficult to reach loca tion. The gap in the seal appearn to have i i formed as a result of a cable pull. It has not been determined when l or by whom the cable was pulled. l I

The penetrations with non-functional seals, found between August 2, -

1938 and September 30, 1988, are similar in configuration (except as l i noted) to the penetrations identified in the origial issue of this Special Report, The cause of their degraded condition also could not i positively be determined. l l

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, . PlIT 1 SPECIAL REPORT 88-3-2 -4-AN ALY S I S O r* OC " Wi.-

The funct' ne c. r rity of the penetration fire barriers ensures that firet; 5 i" confined or adequately retarded from spreading to adjacent po . e 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 pursuar.t 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 _ACTIOf[;

The hourly fire watch, as addressed in the Description of Occurrence ae: tion, will continue until all fire protection concerns associated with these areas are resolved.

l The repair of the penetrations was not accomplished within seven (7)

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days due to the additional review being conducted by the Penetration Seal Task Force. Upon completion of this review the penetrations will be sealed.

Those penetrations in the Relay Room (a halon discharge area) which either have no seal or holes through the seal have been sealed using approved station procedure M3Y-1, "Installation of Fire Barrier and Flood Protection Seals".

This review and corrective action will be completed in accordance

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with PSE&G letter NLC-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, 1938.

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General Manager -

Salem Operations

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i HJP:pe SORC Mtg.88-082