IR 05000285/1989022

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/89-22

ML20245J056
Person / Time
Site:	Fort Calhoun
Issue date:	08/07/1989
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Morris K OMAHA PUBLIC POWER DISTRICT
References
NUDOCS 8908170474
Download: ML20245J056 (1)

Text

_

.

"

. AUG 7 1999

In Reply Refer To:

Docket: ,50-285/89-22 q Omaha Public Power District i ATTN: Kenneth J. Morris, Division Manager )

Nuclear Operations i 444 South 16th Street Hall i

'

Omaha, Nebraska 68102-2247 Gentlemen:

Thank you for your letter of July 20, 1989, in response to our letter and I l

Notice of Violation dated June 20, 1989. We have reviewed your reply and find !

it responsive to the concerns raised in our Notice of Violation. We will j review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine i

Sincerely, OdginalSigned By:

Thomas P.Gwynn James L. Milhoan, Director Division of Reactor Projects cc:

Fort Calhoun Station ATTN: G. R. Peterson, Manager P.O. Box 399 Fort Calhoun, Nebraska 68023 Harry H. Voigt. Es LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, NW Washington, DC 20036 Nebraska Radiation Control Program Director bectoDMB(IE01) m bec distrib, by RIV: OgBiO$

P

$N p y R. D. Martin, RA RPB-DRSS G

SectionChief(DRP/B) MIS System RIV File DRP l RSTS Operator ProjectEngineer(DRP/B)

! Lisa Shea, RM/ALF DRS

' A. Bournia, NRR Project Manager ( r13-D-18) RRI , \

% / {/ RIV:DRP/BT g (

RPMullikin;df C:DRP/

TFWesterbg n g

DFDRP

,DLMilh 8/7 /89 n I s(

8/3/89 8/ 3 /89

- - - _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ - - _ _ _ _ _ _ _ _ _ - - _ _ _ . _ _ . _ -

,

.

.

.,

.

7 .:

-

-

-

.

. , ,

e ..

Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 2247 402'536 4000 July 20, 1989 T- Ev .- )

LIC-89-690 , l ; d.D ' ___

- ,

J ;'

i !iI JUL2Sl989 :R U. S. Nuclear Regulatory Comrnission ,

bU ~~--'d i l

)

Attn: Document Control Desk L- -

I l

Mail Station PI-137 I Washington, DC 20555 l i

References: Docket No. 50-285 Letter from NRC (J. L. Milhoan) to OPPD (K. J. Morris) dated June 20, 1989 Gentlemen:

SUBJECT: Response to Notice of Violation (Inspection Report 50-285/89-22)

Omaha Public Power District (OPPD) received the subject Notice of Violatio The report identified two violations. As stated in Reference 2 the second violation (285/8922-03) does not require a response. Attached please find OPPD's response to violation 285/8922-02 in accordance with 10 CFR Part 2.20 If you have any questions concerning this matter, please contact u ,

Sincerely,

'

J. Morris Division Manager Nuclear Operations KJM/pje Attachment c: LeBoeuf, Lamb, Leiby & MacRae

'tR. D. Martin, NRC Regional Administrator" A. Bournia, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector

, gqq- uq

. _ -

< - - ,. , , - -

__

.

t

'

. Attachment 1

.

RESPONSE TO NOTICE OF VIOLATION During'an NRC inspection conducted May 1-31, 1989, two violations of NRC requirements were identified. The violations involved the failure to institute a fire watch patrol and the failure to designate succession of authority. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violation requiring a response is listed below: Failure to Provide a Fire Watch Patrol Technical Specification 2.19(7) states, in part, that all. penetration fire barriers protecting safety-related areas shall be functional (intact).

With a penetration barrier nonfunctional, verify the operability of fire detectors on at least one side of the penetration and establish an hourly l fire watch patro I Contrary to the above, the licensee had not established a fire watch patrol on March 21, 1989, for all nonfunctional penetration fire barriers (fire doors). The doors had been installed with a 3/4-inch unprotecte.d hele on

~

one side of the door frame, thus making the doors potent 1 ally ;

nonfunctiona This is a Severity Level IV violatio (Supplement I) (285/8922-02)

OPPD RESPONSE (Violation A)

l Reason for the Violation. if Admitted

OPPD admits the violation occurred as state The reason for Violation A is incomplete acceptance criteria established in the installation procedure MP-FIRED 00R-2 Rev 3 " Replacement of Firedoors". ;

Twenty-three fire doors were procured with the 3/4 inch conduit connection holes, and the doors carried a UL label as a Class A (three hour) fire .

door. The doors were installed using an approved procedure designed to '

ensure the functional requirements of NFPA 80, " Standard for Fire Doors and

Windows", were met during installation. The installation procedure l l required the establishment of a fire watch patrol per Technical Specification 2.19(7) prior to removal of the existing door, and required that the fire watch patrol remain in place until final Quality Control acceptance of the installed door per the acceptance criteria in the procedur The installation procedure in effect at the time of the fire door replacement project (MP-FIRED 00R-2 Rev 3) did not require permanent conduit connection to the electric strike as a condition of acceptance for operability.

l Page 1 i

!

.

n

.' If the acceptance of the installation procedure criteria had included the requirement for provision of permanent conduit connections to the electric 1,1 strikes, the doors would not have been declared operable, and the fire watch patrol would not have been release It'was felt that the 3/4 inch hole was insignificant with regard to fire resistance, and with the proper installation of functional hardware such as closers, locksets, hinges, and strikes, as well as the proper alignment of the door with regard to maximum perimeter gaps,the installation was sufficient to ensure the operability of the resulting fire doo The fire door frame's primary purpose is to retain its structural integrity during a fire, and not to provide an insulating fire resistance. UL Standard 108, " Fire Tests of Door Assemblies" allows for limited flame-through in door to frame perimeter gaps, and sets no limitation on backside temperatures during a furnace fire test. Conditions for acceptability of a door during a fire test require the integrity of the assembly be maintained such that final perimeter gaps, as well as flame through distance and duration, are within maximum limit CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED A fire watch patrol was established, assuming the 3/4 inch holes on the door frames made the fire doors inoperable. A technical evaluation, PED-STE-89-72-J, using the provisions of Generic Letters 85-01, was performed to determine the adequacy of the fire resistance of the twenty-three doors in their existing configuration. The evaluation took into consideration the UL criteria for passing a three hour endurance test, the significance of the unprotected hole as it applies to the test criteria, and the combustible loadings involved in the areas affected. The evaluation concluded that the existing twenty-three fire doors provided a more than adequate margin of safety for protection from the hazards involved. Upon completion and approval of the evaluation, the fire watch patrols were discontinue CORRECTIVE ACTIONS WHICH HILL BE TAKEN TO AVOID FURTHER VIOLATIONS Procedure Change Number 28845 to the current fire door installation procedure, GM-RR-FP-0502 Rev 0 "Firedoor Replacement" (supercedes MP-FIRED 00R-2) has been submitted to the PRC for approval. The change incorporates comprehensive acceptance criteria to be met following installation of a fire door prior to declaring the dcor operable as a fire resistive assembly. The general issue of door attachments will be reviewed and incorporated into this change along with an overall rewrite of the acceptance criteria. The requirement for provision of permanent conduit connections to electric strike assemblies has been included in this acceptance criteria. Procedure change to GM-RR-FP-0502 will ce incorporated into the Operating Manual by July 26, 198 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED OPPD is currently in full compliance with Technical Specification 2.19(7)

regarding operability of Fort Calhoun Station firedoor Page 2

- - _ _ _ _