ML20043D713

Special Rept 90-10:on 900522,noncompliance W/License Condition 2.C.13.c Re Section III.G.2 of 10CFR50,App R Noted.Initially Reported on 900523.Caused by Oversight During Previous Efforts to Ensure Compliance W/App R

ML20043D713
Person / Time
Site:	Sequoyah
Issue date:	06/05/1990
From:	Wallace E TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
90-10, NUDOCS 9006110099
Download: ML20043D713 (5)

Text

4 TENNESSEE VALLEY AUTHORITY CH ATT ANOOG A. TENNESSEE 37401 SN 157B Lookout Place Chattanooga, Tennessee 37402-2801 JUN 051990 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk  :

Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket No. 50-328 Tennessee Valley Authority )

SEQUOYAH NUCLEAR Pl. ANT (SQN) UNIT 2 - DOCKEI NO. 50-328 - FACILITY OPERATING LICENSE - DPR 79 - SPECIAL REPORT 90 10 CFR 50, APPENDIX R The enclosed special report provides details concerning noncompliance with the requirement of License Condition 2.C.13.c. of the Unit 2 Facility Operating License. This issue was initially reported by telephone notification at 1100 Eastern daylight time on May 23, 1990, and by facsimile dated May 23, 1990. The noncompliance condition is applicable to Unit 2. This report is being made in accordance with Unit 2 License Condition 2.H.

If you have any questions concerning this submittal, please telephone M. A. Cooper at (615) 843-6651, t

Very truly yours, TENNESSEE-VALLEY AUTHORITY l -w E. G. Wallace, Manager Nuclear Licensing and Regulatory Affairs Enclosure

! See page 2 l

9006110099 900605

• g)

PDR ADOCK 0500o328 v $

S PDC g

An Equal Opportunity Employer

O

\

U.S. Nuclear Regulatory Commission M 051990 cc (Enclosure):

Ms. 5. C. Black, Assistant Director

, for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Filnt, North '

11555 Rockville Pike Rockville, Maryland 20852 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road ,

Soddy Daisy, Tennessee 37379 1

Mr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II ,

101 Marietta Street, NW, Suite 2900 i Atlanta, Georgia '30323  ;

i t

l t

l l

l >

l-

~

ENCLOSURE 14-DAY FOLLOW-UP REPORT <

SQN SPECIAL REPORT 90-10 Description of Condition This special report addresses the requirement of License Condition 2.C.13,c of the Unit 2 facility Operating License regarding compilance with Section III.G of 10 CFR 50, Appendix R. This condition is being reported in accordance with the Unit 2 License Condition 2.H anti is applicable to Unit 2. ,

A noncompliance with Unit 2 License Condition 2.C.13.c was identified on May 22, 1990, related to Section III.G.2 of Appendix R. This section stipulates several allowable configurations-to ensure that one redundant train of systems necessary to achieve and maintain hot shutdown conditions 1s free of fire damage. These allowable configurations for cables and equipment include, briefly:

1. Ihree-hour fire-rated barriers, or

2. Separation by more than 20 feet with no intervening combustible or fire hazards, and fire detectors, and an automatic fire suppression system, or

3. One-hour fire-rated barriers, and fire detectors, and an automatic fire suppression system.

During performance of a plant walkdown inspection in preparation for an unrelated Unit 2 design modification, it was discovered that cables related to indication of Unit 2 reactor coolant system (RCS) pressure, RCS temperature, pressurizer level, and steam generator pressure located in the area bounded by Column Lines All to A13 and Q to R of auxiliary building Elevation 690 (boric acia storage tank area; reference final Safety Analysis Report, figure 1 2.3-5) are enclosed in a 1-hour fire-related barrier, but that the area denoted by the above cocrdinates is not covered by fire detectors or an automatic fire suppression system. Therefore, those cables are not in full

! compliance with Section III.G of Appendix R and, consequently, with Unit 2 License Condition 2.C.13.c.

A condition adverse to quality report was immediately initiated to document l

the problem and its corrective action. The subject area has been and

! continues to be included in the surveillance of roving, hourly fire, watch i patrols. Telephone notification to NRC and subsequent confirmation by l facsimile were made in accordance with Unit 2 License Condition 2.H.

Cause of Condition l

The root cause of this condition has been attributed to an oversight during previous efforts-to ensure compilance with Appendix R requirements. It was previously thought that the subject area was covered by fire detection and an automatic fire suppression system. Sketches used during the earlier effort and a subsequently issued plant drawing Indicate that the area is covered.

Investigation into the errors in these drawings could not confirm the reason for the discrepancy.

\ .

An_alysil a of Condition There are no plant systems or components considered inoperable or incapable of performing their design functions as a result of the condition described in this report. The affected area is included in the surveillance of hourly, roving fire watch patrols that provide assurance that a fire in this area would be identified so that appropriate response actions could be initiated.

Additionally, the subject area has a very low in situ combustible loading.

The area is also contained within a radiological contamination zone, which is continuously regulated and periodically monitored. This will ensure that the zone is not arbitrarily used to store materials that are not needed for specific work activities in the zone. Based upon walkdowns of the affected area, preliminary indications are that an unmitigated fire would not have sufficient duration to compromise the extDing fire wrap during a worst-case fire. Hence, the subject Appendix R circM ts protected by the 1-hour fire wrap would not be damaged by such a fire.

Corrective Action The affected area is included in the :urveillance of hourly, roving fire watch i patrols. Several corrective action alternatives edist, including installing  ;

fire detectors and an automatic fire suppression system in the subject area, -

upgrading the fire barriers (wrap) to 3-hour fire-rated, or rerouting Appendix R cables through an area that has fire detectors and an automatic fire suppression system. Because of the magnitude of these modifications and the short time since discovery of the problem. TVA is still evaluating the i corrective action alternatives and has not yet selected the alternative to be  !

Implemented. In view of the preliminary walkdown indic6ttons of low combustible loading and consequent 1-hour fire wrap adequacy, the current configuration is considered adequate in the interlm.

To further define a basis for selecting the corrective action alternative, TVA will complete a fire hazards analysis calculation for the subject area by August 1, 1990. TVA~will complete evaluation of the alternatives and notify i NRC in a revised special report by September 1,1990, of the selected corrective action alternative and implementation schedule. Additionally, a drawing deviation has been issued to revise the affected plant drawing.

Based upon a preliminary review, the discrepancy on the plant drawing showing fire detector and automatic fire suppression system coverage is believed to be an isolated occurrence. However, a more thorough review will be made of plant areas containing Appendix R cables with 1-hour fire wrap to verify that the required coverage by fire detectors and an automatic fire suppression system  !

is in place. This review will be completed by August 1, 1990. Verifying i walkdowns have already been performed for those areas, taking credit for l 20-foot separation and no intervening combustibles.

Commitments

1. IVA will complete a fire hazards analysis calculation of the subject area by August 1, 1990.

L 1

. . ~

3 Commitments (Continued)

2. TVA will complete evaluation of the alternatives and notify NRC in a revised special report by September 1,1990, of the selected corrective action alternative and implementation schedule.

3. A more thorough review will be made of plant areas containing Appendix R cables with-1-hour fire wrap to ensure that the required coverage by fire

< detectors and an automatic fire suppression system is in place. This review will be completed by August 1, 1990.

0879h i

i I

l I

1

_ _ _ - _ _n