ML20077F700

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Special Rept 91-06:on 910531,noncompliances Noted Re License Condition 2.C.13.a on Fire Protection Plan.Caused by Incorrect Installation of Mod.Nonconformances in Configuration of Walls Will Be Corrected by 910701
ML20077F700
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 06/14/1991
From: Wallace E
TENNESSEE VALLEY AUTHORITY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
91-06, 91-6, NUDOCS 9106200138
Download: ML20077F700 (5)


Text

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k fennessee Vailey Authonty 1101 Mamet Street, Cha'tanooga fent'essee 37402 JUN 141991 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen: l I

In the Matter of ) Docket Nos. 50-327 l Tennessee Valley Authority ) 50-328  ;

SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 - DOCKET NOS. 50-327 AND 50-328 - FACILITY ODERATING LICENSES DPR-77 AND 79 'PECIAL REPORT 91 FIRE PROTECTION PLAN i l

The enclosed special report provides details concerning noncompliance with the requirements of License Condition Section 2.C.13.a of the Unit 2 Facility Operating License. This issue was initially reported by telephone notification at 1023 Eastern daylight time on June 1, IN1, and by facsimile dated June 3, 1991. The noncompliance conditions are applicable to both Units 1 and 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) 843-8422.

Very truly yours.

TENNESSEE VALLEY AUTHORITY

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! E. G. Wallace, Manager Nuclear Licensing and Regulatory Affairs Enclosure cc: See page 2

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2 U.S. Nuclear Regulatory Commission

<JUN 141991 cc (Enclosure):

Ms. S. C. Black, Deputy Director Project Directorate 11-4 U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. D. A. LaBarge, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville. Maryland 20852 NRC hesident Inspector Sequoyah Nucicar Plant 2600 Igou Ferry Road Soddy Daisy Tennessee 37379 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Ceorgia 30323 X

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I ENCLOSURE 14-Day Follow-Up Report Special Report 91-06 Description of_ Condition This special report addresses the requirements of Unit 2 License Condition 2.C.13.a requiring TVA to maintain and implement all provisions of the approved fire protection plan, which in part, commits to barriers of specified fire-rated durations in certain plant locations. The Units 1 and 2 auxiliary instrument rooms are required to be separated by two 1 1/2-hour fire resistant barriers. Contrary to this requirement, noncompliances with the above-cited license condition were identified during a May 31, 1991, walkdown in the area involving improper seals around ceiling support channels.

Additional nonconformances with the design requirements were noted in a follow-up walkdown during the initiation of the investigation. The o m.ompliances discovered are described below.

!. Casing bead for 18-gauge angle required by the drawing was not installed on the vertical edge of the gypsum board above the suspended ceiling.

Additionally, the wall board does not extend to the edge of the opening along the vertical edges, as required by the drawings.

2. A bed of joint compound was not applied at the intet e between the suspended ceiling and the vertical wall board as req %1.ed by the drawing.
3. Sections of the wall board on tha inside face of the wall located under an access platform near the suspended ceiling above Door C22 were missing.
4. The handrail of the access platform is embedded in the dditional layers of gypsum board on the inside face above Door C22, contrary to design specifications.
5. Portions of the top layer of gypsum were missing behind the kick plate on the platform.

These noncompliances are located on control building, Elevation 685, in the corridor area between the Units 1 and 2 auxiliary instriunent rooms above the suspended ceiling (the walls containing Doors C22 and C24). These nonconformances with the design requirements result in a configuration with an ,

indeterminate fire rating.

The affected areas are included in the surveillance of hourly, roving fira watch patrols. Telephone notification to NRC and subsequent confirmation by facsimile were made in accordance with Unit 2 License Condition 2.H.

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Cause of the Condition 6 These nonconformances are a consequence of the incorrect installation of a modification to correct a previous noncompliance reported in Special Report 90-06 involving inadequate consideration of thermal expansion in the wall design. This event has been attributed to inattention to detail by the craft installing the wall , and the Modifications' engineer verifying the installation. A lack of accountability of Modifications' personnel (both engineering and craf t) for the job performance resulted in no one ensuring -the work was adequately performed. Inadequate communication between the craft and engineering and over-reliance on the engineer by the craft and the craft by the engineer were also evidenced by this event.

The engineer that performed the verification of the installation was not previously involved with the' job and did not thoroughly review the design-

-drawings before inspecting the installation. When performing the verification, only the readily visible portions of the walls were inspected.

The work inspected was of high quality; therefore, the engineer assumed that the remaining areas were installed with the same quality of work. The unfamiliarity, in addition to reliance on the expertise of the craft and a lack of diligence during performance, led to the inadequate inspection. These factors indicate a lack of accountability and attention to detail with respect to the quality of work by the engineer.

Because of the elapsed time since the subject work was performed and changes in Modifications' craft personnel, TVA could not determine the exact cause of why the craft involved did not properly install the walls. A possible cause was that the mindset of the craft personnel performing the work appears to have been that the work was considered a simple sheetrock job. This indicates an inadequate understanding of the requirements, which abould have been conve><d during the prework briefing. Irrespective of the lack of full comprehension, the craft was to inctall the wall as required by the design drawings, which was not accomplished, indicating inadequate attention to detail during the performance of the work. Another potential contributing factor was that the jcb was not performed on a continuous basis by the same craftsmen, but was performed by a variety of personnel on.an as-available basis because of higher priority and emergent items on the craft work schedule. The lack of engineering support combined with an over-reliance by the craf t on the engineer may have also contributed to the event. These l factors strongly indicate a lack of accountability for the work.

Analysis of Condition-Although the full qualification of the barriers could not be assured with the

- described noncompliances, physical barriers did exist betweea the areas. The affected-areas have been included-in the surveillance of hourly, roving fire watch patrols as a result of other identified problems for the entire duration of-these noncompliances. The roving fire watch ,atrols, coupled with the existing fire detection in the corridor area and the automatic detection and suppression in the adjacent areas, provide assurance that a fire in these areas would be identified and appropriate response actions initiated.

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i Corrective Actions The nonconformances in the configuration nf the walls will be corrected by July 1, 1991. Modifications' management will discuss this incident with the Modifications' craft and engineering and will stress the importance of self-verification and strict adherence to work instructions, design drawings, and specifications. Additionally, a directive will be developed delineating specific requirements regarding prework briefings to include, among other things, clear definition of craft and rugineering responsibilities. A mandatory sign-off in the work instructtons attesting to completion of prework briefing by both the foreman and engineer will also be required. To increase accountability and ownership of work to the cratt, a philosophy has been adopted by Modifications' management to assign a lead to a job at the bidding phase; and he will continue to have the entire responsibility until completion of the job. Also to increase accountability, the Modifications' field engineers are now assigned to a particular lead foreman and are responsible for support of that foreman's work in entiruty; this action also reinforces communication between the engineers and crafL.

Commitments

1. The nonconformances in the configuration of the walls will be corrected by July 1, 1991.
2. Modifications' management will discuss this incident with Modifications' craf t and engineering and will stress t.he importance of self-verification and strict adherence to work instructions, design drawings, and specifications by July 1, 1991.
3. A directive will be developed delineating specific requirements regarding prework briefings to include, among other things, clear definition of craf t an- engineering responsibilities. A mandatory sign-off in the work instructions attesting to completion of prework briefing by both the foreman and engineer will also be required. These actions will be completed by August 1, 1991.

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