05000338/LER-2010-001, Regarding Non-Functional Fire Barrier Penetrations Containing Aluminum Conduit Due to Configuration

Regarding Non-Functional Fire Barrier Penetrations Containing Aluminum Conduit Due to Configuration

ML102020258
Person / Time
Site:	North Anna
Issue date:	07/12/2010
From:	Lane N Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LER 10-001-00
Download: ML102020258 (5)

LER-2010-001, Regarding Non-Functional Fire Barrier Penetrations Containing Aluminum Conduit Due to Configuration

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3382010001R00 - NRC Website

text

1 OCFR50.73 Virginia Electric and Power Company North Anna Power Station P. 0. Box 402 Mineral, Virginia 23117 July 12, 2010 Attention: Document Control Desk Serial No.:

10-350 U. S. Nuclear Regulatory Commission NAPS:

MPW Washington, DC 20555-0001 Docket No.: 50-338 50-339 License No.: NPF-4 NPF-7

Dear Sirs:

Pursuant to 10CFR50.73, Virginia Electric and Power Company hereby submits the following Licensee Event Report applicable to North Anna Power Station Units 1 & 2.

Report No. 50-338/2010-001-00 This report has been reviewed by the Facility Safety Review Committee and will be forwarded to the Management Safety Review Committee for its review.

Sincerely, N. Larry Lane Site Vice President North Anna Power Station Enclosure Commitments contained in this letter: None cc:

United States Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector North Anna Power Station

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSIO gýpI/oEDBY OMB NO. 3150-0104 EXPIRES:

(9-2007)

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

3. PAGE NORTH ANNA POWER STATION, UNITS 1 & 2 05000 338 1 OF 4

4. TITLE Non-Functional Fire Barrier Penetrations Containing Aluminum Conduit Due To Configuration

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL REV MONTH DAY YEAR FACILITY NAME DOCUMENTNUMBER I

NUMBER NO.

North Anna Unit 2 05000 339 05 13 2010 2010

-- 001 --

00 07 12 2010 FACILITY NAME DOCUMENTINUMBER 05000

9. OPERATING MODE

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)

[1] 20.2201(b)

El 20.2203(a)(3)(i) 0]

50.73(a)(2)(i)(C)

E]

50.73(a)(2)(vii)

El 20.2201(d)

[E 20.2203(a)(3)(ii) 50.73(a)(2)(ii)(A)

El 50.73(a)(2)(viii)(A) 1 El 20.2203(a)(1)

[-] 20.2203(a)(4)

[

50.73(a)(2)(ii)(B)

El 50.73(a)(2)(viii)(B)

[]

20.2203(a)(2)(i)

[] 50.36(c)(1)(i)(A)

E]

50.73(a)(2)(iii)

H 50.73(a)(2)(ix)(A)

10. POWER LEVEL

[]

20.2203(a)(2)(ii)

[]

50.36(c)(1)(ii)(A)

E]

50.73(a)(2)(iv)(A)

El 50.73(a)(2)(x)

Li 20.2203(a)(2)(iii)

El 50.36(c)(2)

[]

50.73(a)(2)(v)(A)

El 73.71(a)(4)

[]

20.2203(a)(2)(iv)

[]

50.46(a)(3)(ii)

[]

50.73(a)(2)(v)(B)

El 73.71(a)(5)

El 20.2203(a)(2)(v)

El 50.73(a)(2)(i)(A)

El 50.73(a)(2)(v)(C)

El OTHER 100%

El 20.2203(a)(2)(vi)

E]

50.73(a)(2)(i)(B)

El 50.73(a)(2)(v)(D)

VOLUNTARY LER

12. LICENSEE CONTACT FOR THIS LER FACILITY NAME TELEPHONE NUMBER (Include Area Code)

F. Mladen, Director Station Safety and Licensing (540) 894-2108CAUSE SYSTEM COMPONENT MANU-REPORTABLE

CAUSE

SYSTEM COMPONENT MANU-REPORTABLE FACTURER TO EPIX FACTURER TO EPIX

14. SUPPLEMENTAL REPORT EXPECTED

15. EXPECTED MONTH DAY YEAR SUBMISSION YES (If yes, complete 15. EXPECTED SUBMISSION DATE)

ElJ NO DATEI ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)

On May 13, 2010, results of aluminum conduit seal penetration tests determined certain fire barrier penetration configurations would not perform their design function. The North Anna Power Station has approximately 900 fire barrier penetrations containing aluminum conduit of which approximately 300 were identified as requiring modification to meet their design function. Degraded fire barriers, such that the required degree of separation for redundant safe shutdown trains is lacking, is reportable as an unanalyzed condition that significantly degraded plant safety.

Therefore, this report is being submitted pursuant to 10CFR50.73(a)(2)(ii)(B). At the time of discovery fire watches for the affected areas were already in place. This event posed no significant safety implications since fire suppression, detection and plant response along with the compensatory measures implemented provided an adequate level of protection for redundant equipment. This situation has not resulted in any significant safety consequences or implications and the health and safety of the public were not affected at any time. A fire has not occurred in the affected fire areas that has challenged these penetrations.

NRC FORM 366 (9-2007)

PRINTED ON RECYCLED PAPER (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of NRC Form 366A) (17)

Corporation to generate documentation for the penetration seal configurations (PSCs) existing at SPS. This led to the issuance of several calculations used to justify the PSCs.

The test reports referenced by the calculations utilized acceptance criteria/testing methods from standards IEEE P634/D2, IEEE 383-1974, ASTM E-119-1976, ASTM E-814 and NEL-PIA/MAERP. The test reports were incorporated into technical reports TR EP-001 1 and TR EP-001 6. North Anna Power Station adopted the test reports by reference of their respective technical report into the NAPS Appendix R Report. During the 2009 NRC Triennial Fire Protection Inspection at SPS, the NRC reviewed the test reports and determined that sufficient documentation did not exist to qualify the use of aluminum conduits with silicone foam seals penetrating fire rated barriers as three hour fire rated.

4.0 IMMEDIATE CORRECTIVE ACTION(S)

Upon identification of the potential fire barrier impairments, a station condition report was issued and compensatory measures were implemented in accordance with the North Anna Technical Requirements Manual.

5.0 ADDITIONAL CORRECTIVE ACTIONS

A vendor was contracted and tested fire barrier penetrations containing aluminum conduit lAW IEEE 634-1978, Standard Cable Penetration Fire Stop Qualification Test.

A design change will be implemented to correct the fire barrier penetrations containing aluminum conduit as needed based on the testing results and site evaluations.

Procedures controlling the Fire Protection Program are being revised to address the test results. Fire barrier installation and test procedures are also being revised to ensure acceptable maintenance and installationj of aluminum conduit configurations.

6.0 ACTIONS TO PREVENT RECURRENCE Actions completed and those in progress will ensure the program meets regulatory requirements and fire barrier penetratiors containing aluminum conduit are maintained in the required configurations.

7.0 SIMILAR EVENTS

None

8.0 ADDITIONAL INFORMATION

NonePRINTED ON RECYCLED PAPER