ML20238A132

Informs of Unresolved Item in NRC 841011 Rept 84-22 Re Bisco Fire Seals Certification & Burned QA Records.Recommends That Ofc of Investigation Investigate What Appears to Be False Statements Made Re Seals Followed by Insp of QA Program

ML20238A132
Person / Time
Site:	Comanche Peak
Issue date:	11/25/1985
From:	Phillips H NRC
To:	Westerman T NRC
Shared Package
ML20237F760	List: IR 05000445/1980026 IR 05000445/1985018 IR 05000445/1986010 ML20237F757 ML20237K977 ML20237L009 ML20237L052 ML20237L058 ML20237L073 ML20237L183 ML20237L187 ML20237L193 ML20237L212 ML20237L221 ML20237L240 ML20237L244 ML20237L264 ML20237L285 ML20237L293 ML20237L327 ML20237L341 ML20237L352 ML20237L358 ML20237L369 ML20237L386 ML20237L409 ML20237L426 ML20237L431 ML20237L478 ML20237L496 ML20237L507 ML20237L519 ML20237L554 ML20237L564 ML20237L594 ML20237L616 ML20237L623 ML20237L628 ML20237L642 ML20237L652 ML20237L656 ML20237L679 ML20237L705 ML20237L711 ML20237L718 ML20237L754 ML20237L767 ML20237L814 ML20238A011 ML20238A033 ... further results
References
NUDOCS 8708200380
Download: ML20238A132 (3)

Text

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1. M UNITED STATES }

p .

%,k NUCLEAR REGULATORY COMMISSION f REGloN IV 611 RYAN PLAZA DRIVE, SUITE 1000

%, ,8 ARLINGTON. TEXAS 78011 ,

November 25, 1985 M N , A iT A/n 19 Docket Nos.: 40-445 and 40-446 MEMORANDUM FOR: T. Westerman, Chief, Comanche Peak Group and Enforcement Officer FROM: H. S. Phillips, Senior Resident Inspector Comanche Peak

SUBJECT:

BISCO FIRE SEALS CERTIFICATION AND OA RECORDS WHICH BURNED I identified an unresolved item in NRC Report 84-22 dated October 11, 1984 which dealt with questionable certification with respect to testing of BISCO seals. Recently I asked Mr. Thomas Young to followup on this item. During the last two weeks he has identified two statements that appear to be false with respect to meeting the test requirements of ASTM E-119 and IEE 634 as required by FSAR Section 9.5.1.5.3 and Gibbs

, & Hill Specification No. 2323-MS-38F and QA records. This work is being

! done under TUGC0 Contract No. CP-0707 (between TUGC0 and BISCO).

l The first problem deals with BISCO Letter Sequence No. 3346-271 (See l

Enclosure 1) and a Summary of Testing and American Nuclear Insurers (ANI) Acceptances Submitted to Comanche Peak (see Enclosure 2). -

Specifically, Test No. PCA-76 in Enclosure 2 shows that IEEE testing was not done, however, Enclosure 1, which responds to NRC questions, and in turn, TUGC0 Letter No. CPPA-41,594, states that BISCO design configuration (Enclosure 3) for cables in conduit meets IEEE 634 test requirements. There is no objective evidence that this design configuration was proof tested to IEEE 634 requirements.

In addition to the above, two separate fires have occurred at BISCO.

The first fire occurred in 1975 and the second fire in the summer of 1976. Mr. Young learned of these fires when he asked for infonnation pertaining to Test No. PCA-76. In a conversation with Mr. Gary Fedor, a BISCO Development Engineer at Park Ridge, Illinois, he stated that the insurer (ANI) had rescinded their acceptance of Test No. PCA-76 because test data / documentation had been destroyed in the fire of the summer of 1976. BISCO Letter dated September 16, 1985 (Enclosure 4) also states 8708200380 870819 PDR ADOCK 05000445 G PDR

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that these records were lost because of the fire. These statements j appear to be false because according to Mr. Fedor, the fire occurred i during the summer of 1976 and the test (which failed) and the partial retest were completed in October 1976. l l'

This infomation may never have come to light if the insurer had not rescinded the acceptance of BISCO testing. The extent of the fires )l at BISCO is unknown and the circumstances are unclear. BISCO is involved i with installing fire barriers at many different sites. How many QA l records have been lost and how many such tests failed with respect to i installed fire penetration barriers is not known. Should this have been reported under 10CFR Part 21 reporting requirements?

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Texas Utilities audited BISCO at Park Ridge, Illinois, in July 1983 bet did not audit Criterion XVII QA Records. It is not easy to understand why BISCO's entire QA Program was not audited, especially Criterion XVII because this would naturally include the two most important work areas:

(1) design of penetration barriers (Criterion III, Design Control) and (2) testing of such barriers (Criterion XI Test Control). A review of test documentation is essential to accepting certifications and test reports that would prove the design requirements were met. The SRI will document this in a report.

These matters are particularly significant because the applicant requested l to load fuel in September 1984 and would have loaded fuel if the NRC had l approved such a request. It appears that some documentation for Test No.

I PCA-76 dated October 1976 is missing. It is also significant that retest {

(748-183) requested by the insurer failed in 1985. On November 29, 1985 BISCO stated that they thought fire seals into the control room should i be removed but these seals were not tagged with Nonconformance tags. {

i Thus, there is reason to believe that the Applicant would have loaded j fuel with fire penetration barriers that did not meet IEEE'634 testing requirements.  ;

It is questionable if adequate evaluations of PCA-76 and '

other tests have been completely analyzed and resolved.  !

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Further, TUGC0 engineering personnel have infomed Mr. Thomas Young that -

they have not completed the review of all BISCO test reports for Unit I and such reviews are to be completed by January 1986. Again it appears s that they were willing to load fuel before such equipment qualification f tests were thoroughly reviewed and evaluated to assure that proof tests met the design requirements.  ;

TUGC0 Report TDDR No. FP-85-063 states that the failure of fire rated materials to meet the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> requirement is not potentially reportable. l i

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I disagree with this decision as the actual tested fire rating of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 35 minutes is a significant deviation from FSAR requirements (Section 9.5.1.5.3 and a comparison chart on pages 9.5-29; -58; -67;' I

-68; and -169 in Enclosure 5) which require 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> minimum. Al so ,

there is no evidence that IEEE 634 requirement were ever met..  ;

l It is recommended that the office of Investigation investigate what )

appears to be false statements made regarding BISCO Seals followed l by an NRC Vendor Branch inspection of the BISCO QA Program. The SRI will complete necessary site inspections and document the potential /

j violation in the November 1985 draft report; that is TUGCO's failure to review BISCO's design and test reports prior to installation of the fire barriers and TUGCO's failure to adequately audit BISCO QA program ,

and technical documentation.

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H.'S. Phillips, Senior Resident Inspector Comanche Peak

Enclosure:

1. BISCO Letter No. 3346-271

2. Summary of Testing

3. BISCO Design Configuration

4. BISCO Letter Dated 9-16-85

5. FSAR l

Cc:

Residence Files

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