LER 95-003-00:On 950315,Fire Barriers Was Outside Design Basis Due to Inadequate Testing Qualification Basis
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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) ACCESSION NBR-'9504190112 DOC.DATE: 95/04/14 NOTARIZED: NO DOCKET FACIL:50-275 Diablo Canyon Nuclear Power Plant, Unit 1, Pacific Ga 05000275 AUTH.NAME AUTHOR AFFILIATION BEHNKE,D.H. Pacific Gas & Electric Co. RUEGER,G.M. Pacific Gas 6 Electric Co. RECIP.NAME RECIPIENT AFFILIATION SUBJECT: LER 95-003-00:on 950315,fire barriers was outside design basis due to inadequate testing qualification basis. ltr.Implemented fire watches as compensatory measure.W/950414 DISTRIBUTION CODE: IE22T COPIES RECEIVED: LTR ! ENCL i SIZE: TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc. NOTES: RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD4-2 PD 1 1 MILLER,M 1 1 INTERNAL: ACRS 1 1 2 2 AEOD/SPD/RRAB 1 1 FIL CENTER 1 1 NRR/DE/ECGB 1 1 RR 1 1 NRR/DE/EMEB 1 1 NRR/DISP/PIPB 1 1 NRR/DOPS/OECB 1 1 NRR/DRCH/HHFB 1 1 NRR/DRCH/HICB 1 1 NRR/DRCH/HOLB 1 1 NRR/DRSS/PRPB 2 2 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 RES/DSIR/EIB 1 1 RGN4 FILE 01 1 1 EXTERNAL: L ST LOBBY WARD 1 1 LITCO BRYCE,J H 2 2 NOAC MURPHY,G.A 1 ~ 1 NOAC POORE,W. 1 1 NRC PDR 1 1 NUDOCS FULL TXT 1 1 NOTE TO ALL"RIDS" RECIPIENTS: PLEASE HELP US TO REDUCE iVASTE! CONTACI'THE DOCUMENTCONTROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAME FROM DISTRIBUTIONLISTS I'OR DOCUMENTS YOU DON'T NLED! FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 28 ENCL 28 t Pacilic Gas and Electric Company 77 Scale Street. Room 1451 Gregory M. Rueger P.O. Box 770000 Senior Vice President and San Francisco. CA 94177 General Manager 415/973-4684 Nuctear Pov,er Generation Fax 415/973-2313 April 14, 1995 PG&E Letter DCL-95-079 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Licensee Event Re ort 1-95-003-00 Fire Barriers Outside Desi n Basis Due to Inade uate Testin uglification Basis Gentlemen: Pursuant to 10 CFR 50.73(a)(2)(ii)(B), PG&E is submitting the enclosed Licensee Event Report regarding certain fire barriers being outside their design basis because the fire barrier testing information that PG&E used as a qualification basis did not meet the requirements of 10 CFR 50, Appendix R. A one-hour, non-emergency report was made to the NRC in accordance with 10 CFR 50.72(b)(1)(ii)(B). The health and safety of the public were not adversely affected by this condition. Sincerely, Gregory M. Rueger cc: L. J. Callan Melanic A. Miller Kenneth E. Perkins Michael D. Tschiltz Diablo Distribution INPO Enclosure N0001887 1290S/JER/2246 9504190112 950414 PDR ADOCK 05000275 S PDR LICENSEE EVENT REPORT (LER) fACILITTNAME11) Diablo Can on Unit 1 0500027518 Fire Barriers Outside Design Basis Due to Inadequate Testing Qualification Basis OTHER PACIlmES INVOLVEO O SEOVENTIALIAPA0ER REVISION COCKET NVMSER IS) IAPASER DiabloCan onUnit2 0 5 0 0 0 3 2 3 3 15 95 95 0 0 3 - 0 0 4 14 95 0 5 0 0 0 T)os REPCRT Is svSMATEo PORsvANT To 1HE REovIREMENTs of 10 cfR: 111) MOOEIO> X 10CFR 50.73 a 2 n B 110) OTHER- 100 (Specify In Abstract below and In text, NRC Form 366A) Donald H. Behnke, Senior Re ulato Su ort En ineer 805 545-2629 COMPLETE ONE LINEFOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT 13 REPORTASLE REPORTASLE TO NPROS TO NPROS SUPPLEMENTAL REPORT EXPECTEO II%) EXPECTED SUBMISSION IX] YES (Ifyes, compIete EXPECTED SUBMISSION, DATE) I I No DATE (15) 10 16 95 On March 15, 1995, at 1330 PST, with Unit 1 and Unit 2 in Mode 1 (Power Operation) at 100 percent power, PG&E determined that the fire rating of certain fire barrier material installed in various areas of both units was indeterminate. The fire barrier testing results that PG&E used as a qualification basis did not meet the requirements of 10 CFR 50, Appendix R. PG8 E conservatively declared the barriers inoperable. On March 15, 1995, at 1402 PST, a one-hour, non-emergency report was made to the NRC in accordance with 10 CFR 50.72(b)(1)(ii)(B). PG8 E implemented hourly fire watches as a compensatory measure. PG8E will inspect, evaluate, and modify the fire barriers, as necessary, to ensure that qualified fire barriers are used. PG&E is also reviewing the adequacy of the testing qualification basis of other fire barrier materials. The root cause and corrective actions for this event have not been determined. A supplemental LER will be issued by October 16, 1995, to report the finalized root cause and corrective actions. 1290S.DOC LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACtLITYNAME(I) YEAR ':::; SEOVENTIAL 1 x ~ REYISIOI( ERASER "8 MPASER OF Diablo Can on Unit 1 0 5 0 0 0 2 7 5 95 - 0 0 3 '- 0 0 TEXT (111 Plant Conditions Units 1 and 2 have been in various modes and at various power levels with the conditions described below. Descri tion of Problem A. Summary On March 15, 1995, at 1330 PST, with Unit 1 and Unit 2 in Mode 1 (Power Operation) at 100 percent power, PG&E determined that Pyrocrete fire barrier enclosures did not have an acceptable fire test to support the requirements of 10 CFR 50, Appendix R. The purpose of the Pyrocrete fire barrier. enclosures (KQ) is to protect safe shutdown circuits in various areas of both units. The fire test data PG&E used to credit Pyrocrete fire barrier enclosures are not representative of the installed configurations. On March 15, 1995, at 1402 PST, a one-hour, non-emergency report was made to the NRC in accordance with 10 CFR 50.72(b)(1)(ii)(B). B. Background PG&E initiallycommitted to installing 2-hour rated fire barriers within fire zones to protect safe shutdown equipment and electrical cabling. This was done to meet the requirements of. Appendix A to Bechtel Topical Report (BTP) (APCSB) 9.5-1 as part of PG&E's application for an Operating License. The requirements for fire barriers were modified when 10 CFR 50, Appendix R was issued. 10 CFR 50, Appendix R, Section III.G.2, requires that one train of redundant systems necessary to achieve and maintain hot shutdown conditions, located within the same fire area, is free from fire damage by providing one of the following: 1. Separation of redundant circuits by a fire barrier having a 3-hour fire rating, ol 2. Separation of redundant trains by a horizontal distance of more than 20 feet with no intervening combustible or fire hazards, in conjunction with fire detectors and an automatic fire suppression system installed in the fire area, or 1290S.DOG LICENSEE EVENT REPORT (LER) TEXT CONTINUATION LER MANOR(0) c"..) MAI8ER:i".".i MPA8KR Diablo Can on Unit 1 0 5 0 0 0 2 7 5 95 - 0 0 3 - 0 0 3 8 1EXT {1)) 3. Enclosure of cable and equipment of one redundant train in a fire barrier having a 1-hour rating, in conjunction with fire detectors and an automatic fire suppression system installed in the fire area. Information Notice 84-09 states fire barriers installed to meet the requirements of Section III.G.2 of Appendix R must have a basis for their fire rating (such as u/L listing or testing conducted by a nationally recognized testing laboratory for the configuration used in the plant). Generic Letter 86-10 states that, ifan exact replication of a tested configuration cannot be achieved, the application or "end use" of the fire barrier should be unchanged from the tested configuration. As an example, Generic Letter 86-10 states that the use of a cable tray barrier to protect a cable tray that differs in configuration from those that were tested would be acceptable, but the use of structural steel fire proofing to protect a cable tray assembly may not be acceptable. C. Event Description On July 27, 1977, PG8 E transmitted Amendment 51, including the Fire Protection Review, to its Application for Operating License in accordance with the guidance provided in Appendix A to BTP (APCSB) 9.5-1. On January 30, 1978, the NRC requested PG&E to substantiate the fire resistance capability of rated fire barriers by verifying that their construction is in accordance with a particular design that has been fire tested. Also, the NRC requested PG8E to identify the design and the test method used and the acceptance criteria. In addition, the NRC stated that the design as tested was to be representative of field installation. On July 7, 1978, PG&E committed to installing 2-hour rated fire barriers within fire zones to protect safe shutdown equipment and electrical cabling. On August 3, 1978, PG&E identified where Pyrocrete would be used at DCPP (including its use for barriers to separate safe shutdown circuits) and provided a small-scale fire test report. This report, conducted by an independent laboratory, showed that a wall slab with a 2-inch thickness of Pyrocrete would qualify for more than a 2-hour rating based on the back side of the test assembly not exceeding 250 degrees F above ambient. On November 15, 1978, the NRC issued SER Supplement No.