ML18033B385
| ML18033B385 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/31/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18033B375 | List: |
| References | |
| NUDOCS 9006210253 | |
| Download: ML18033B385 (8) | |
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~o SAFETY kg**4 UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION EMPLOYEE CONCERN 30600 FIRE PROTECTION BROWNS FERRY UNITS 1, 2 AND 3 TENNESSEE VALLEY AUTHORITY DOCKET NOS.
1.0 STATEMENT OF EMPLOYEE CONCERN The subcategory, Fire Protection, is comprfsed of 13 employee concerns address-ing nine issues relating to areas within the ffre protection program.
These concerns and their issues were:
Element 306.01 Fire Protection E uf ment Works Im ro erl 306.01-1 DifficultyOpening Fire Hose Station Valves 306.02-2 Plant Fire Door Weatherstripping Damaged 306.01-3 Plant Fire Door Closure Problem 306.01-4 Penetration Seals Breached Without'Permfts t
306.01-5 Fire Protection fn Control Building Battery Board Room Inadequate 3G6.01-6
-Fire Alarm Activation Method Inadequate 306.01-7 Fire Protection Equipment Inspection Inadequate Element 306.02 Cable Tra Fire Barriers and Penetration Sleeves 306.02-1 Cable Tray Fire Barriers Improperly Installed 306.02-2 Penetration Sleeves Not Cross-Referenced to Conduit Numbers.
2.0 SUM!IARY AND EVALUATION Element 306.01 "Fire Protection E uf ment Works Im ro erl Of the seven issues under element 306.01 (Fire Protection Equipment Works Improperly),
TVA determined that only one was applicable to BFN.
The item determined to be applicable was the plant fire door closure problems (item 3).
The other issues were excluded as follows:
a) 306.01-1 "DifficultyOpening Fire Hose Station.Valve"-
Thfs concern originated because constructfon personnel had tight-ened down handwheel valves on fire hydrants at WBN to prevent leakage.
This was not considered a safety concern because fire brigade personnel have ready access to the tools required to open stuck valves.
Also valves to hydrants protecting safety-related equipment are inspected under Surveillance Instruction (SI) - 7.23, valves found to be too tight are corrected by maintenance requests.
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- b. 306.01-2
- c. 306.01<<4 "Plant Fire Door Weatherstripping Damaged" This concern originated because degraded weather stripping had been noted on fire doors at WBN.
This concern was not consi-dered generic because the problem was traced to procedural inadequacies at WBN.
These procedural inadequacies were not found at BFN.
"Penetration Seals Breached Without Permits" This concern originated when it was oiscovered that breached penetration seals were not being adequately tracked.
This concern was not considered generic because the problem was traced to procedural inadequacies at WBN.
These procedural inadequacies were not considered to exist at BFN and the item was not considered generic.
- d. 306.01-5 "Fire Protection in Control Building Battery Board Room Inadequate" This concern originated at WBN and was found to be unsubstan-tiated.
No other site evaluations were made and the item was not considered to be generic.
e.. 306.01-6
- f. 306.01-7 "Fire Alarm Activation Method Inadequate" This concern originated at WBN in regard to the use of the tele-phone for activating the fire alarm.
The method was determined to be within NFPA requirements and the concern was considered to be unsubstantiated.
"Fire Protection Equipment Inspection Inadequate" This concern originated at WBN in regard to testing frequency of fire protection equipment.
TVA determined that WBN performs surveillance instructions on fire protection equipment which protects nuclear safety-related equipment, in accordance with Technical Specification requirements.
Fire protection equipment surveillance instructions at other TVA plants are also based on Technical Specifications.'herefore, this item was considered to be unsubstantiated.
The NRC staff agree's with TVA's conclusion of no generic applicability for four of the above issues (306.01-1, 306.01-2, 306.01-6, and 3.06.01-7).
However, problems have been discovered at Sequoyah Units 1 and 2 (SgN) under concerns 306.01-4 and 306.01-5.
TVA. concluded that procedure inadequacies at WBN was the reason for issues 306.01-4 (Penetration Seals Breached Without Permits).
During the November 14-18 1988 inspection of Sequoyah Units 1
8 2 (Inspection Report 50-327/328, 88-54]
a deficiency was noted in regard to a penetration seai being breached without a permit.
TVA also concluded that their resolution of item 306.01-5 (Fire Protection in Control Building Battery Board Rooms Inadequate) was adequate and that there was no generic applicability for this item.
On October 5, 1988, TVA discovered t
that the Battery Board Room at Sequoyah Units 1 and 2 did not meet Appendix R
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3 requirements in regard to cn automatic suppression system.
A temporary devi-ation was requested by TVA and was granted by thc staff (Richardson to White, 11/14/88).
In regard to the item found applicable to Browns Ferry (306.01-3, Plant Fire Door Closure Problem), this item originated when a fire door at WBN was found to remain open because an improper closure mechanism had been installed.
When fire doors were evaluated at Browns Ferry Nuclear Plant (BFN) other problems werc discovered such as: Faflure to account for differential pressure ir the design of the closure mechanism, failure to specify ventilation conditions for
- testing, and failure to PORC approve an instruction being used to implement a
comoitment to NRC.
In addition there may be some installed fire door closure mechanisms which do not aarce with as-constructed drawings.
A Corrective Action Tracking Document (CATD) was initiated on February 6, 1987 by thc licensee.
The staff will review the resolution documents for these issues during the Appendfx R inspection prior to restart of BFH.
Element 306.02 Cable Tra Barriers and Penetration Sleeve Drawin Problem Issue 306.02-1, "Cable Tray Fire Barriers Improperly Installed" originated as a
concern regarding gaps between the pieces nf cable tray fire barriers at WBN.
TYA determined that there was no requirement for a maximum gap width between the board and cables in either the electrical penetration modification instruct;ions or the procedure for fire stops.
The requirement fn both of these procedures fs to place "Kaowool N" board snugly around cables and cable tray and to pack Kaowool fiber in cracks and voids.
TYA concluded that the concern was not valid.
Issue 306.02-2, "Penetration Sleeves Not Cross-referenced to Conduit Numbers",
originated as a concern regarding drawing numbers and the associated penetration numbers.
TVA determined that penetration
- seals, ccndufts, and drawings could be tied together using the Surveillance Instruction (SI) numbers.
The staff does not agree with TVA's closure of issue 306.02-1.
It is the staff's opinion that any gap between cables and solid seal material must bc limited if the installed seal is to be equated to a rated seal.
Thc fact that the drawing did not specify a maximum allowable gap width does not relieve TYA of the responsibility of assuring that the penetration seal as installed is equivalent to the tested configuration.
In response to staff questions, TYA provided copies of Hodiffcatfon/Addition Instructions.(YAI's) for various types of penetration seals.
After review of these MAI's the staff concluded that the TVA quality control inspection procedures were adequate to assure proper installation of the seals.
The staff agrees with TVA's resolution of issue 306.02-2.
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3.0 CONCLUSION
S In regard to element 306.01 "Fire Protection Equipment Works Improperly," the staff agrees with TVA's program findings with the following exception).
The staff bel'ieves that issue 306.01-4 "Penetration Seals Breached Without Permits" may have generic implications (due to the recent inspection at Sequoyah) and should be investigated further.
The fire barrier breaching at Sequoyah is described in TVA S(N Special Report 88-16 (12/19/88).
In regard to issue 306.01-5 "Fire Protection in Control Building Battery Board Rooms Inadequate,"
the Sequoyah findings may have been coincidental.
- However, had the Watts Bar findings been investigated on a generic basis, the Sequoyah deficiencies may have been discovered sooner.
Based on these conclusions, the NRC will monitor TVA progress in re-evaluating its program for issuing breach of fire barrier permits and re-evaluating the adequacy of fire protection in small rooms containing minimum shutdown systems and components.
In regard to issue 306.01-3 "Plant Fire Door Closure Problem," the staff will review the resolution documents for issues associated with this element during the Appendix R inspection.
The staff con'eludes that Element 306.02, "Cable Tray Fire Barriers and Penetration Sleeve Drawings" has been adequately resolved.
REVISION ONE NRC Inspection Reports 50-259/260/296/90-11 dated May 11, 1990, had inspection followup on items similar to the open issues in this safety evaluation report.
Closure of these items is a satisfactory resolution of the open issues.
A copy of the inspection report is attached.
Open Issue in Safety Evaluation Report 306.01-3 306.01-4 306.01-5 Closure of Similar Item in Inspection Report Paragraphs 2.K, 2.H, arid 2.N Paragraph 2.I"'aragraph2.L
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